ET 10-0005, Response to Request for Additional Information Related to License Amendment Request for Deviation from Fire Protection Program Requirements

Response to Request for Additional Information Related to License Amendment Request for Deviation from Fire Protection Program Requirements

ML101040250
Person / Time
Site:	Wolf Creek
Issue date:	03/25/2010
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 10-0005
Download: ML101040250 (191)

Text

WOLF CREEK 'NUCLEAR OPERATING CORPORATION Terry J. Garrett March 25, 2010 Vice President Engineering ET 10-0005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 09-0007, dated March 4, 2009, from T. J. Garrett, WCNOC, to USNRC

2) Letter dated January 29, 2010, from B. K. Singal, USNRC, to R. A. Muench, WCNOC, "Wolf Creek Generating Station -

Request for Additional Information On License Amendment Request for Deviation from Fire Protection Program Requirements (TAC NO. ME0797)"

Subject:

Docket No. 50-482: Response to Request for Additional Information Related to License Amendment Request for Deviation from Fire Protection Program Requirements Gentlemen:

Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) License Amendment Request (LAR) to make changes to the approved fire protection program as described in the Wolf Creek Generating Station (WCGS) Updated Safety Analysis Report (USAR). Specifically, a deviation from certain technical requirements of 10 CFR 50, Appendix R, Section III.G.2, as documented in Appendix 9.5E of the WCGS USAR, was requested regarding the use of operator manual actions (OMAs) in lieu of meeting circuit separation protection criteria.

Reference 2 provided a Nuclear Regulatory Commission (NRC) request for additional information (RAI) related to the LAR to make changes to the approved fire protection program.

The Attachment provides a copy of that RAI with WCNOC's response following each RAI item.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 10-0005 Page 2 of 3 Note: On February 3, 2010, the NRC Senior Project Manager for WCGS telephoned WCNOC and indicated that references to "Attachment I" in the RAI should be changed to "Enclosure I."

Included as Enclosure 1 of Reference 1 was WCNOC's OMA Feasibility and Reliability Analysis, WIP-E-1F9900-004-A-1, Revision 0, "Post-Fire Safe Shutdown Operator Manual Actions." In response to this NRC RAI (Reference 2), WIP-E-1 F9900-004-A-1, Revision 1, was issued and replaces Revision 0 in its entirety. The Enclosure to this response provides Revision 1 of WIP-E-1F9900-004-A-1. The changes from Revision 0 are annotated by a revision bar. The Attachment to this response makes. reference to the latest revision (1).

This letter contains no additional commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Richard D. Flannigan at (620) 364-4117.

Sincerely, Terry J. Garrett TJG/rlt Attachment Enclosure cc: E. E. Collins (NRC), w/a, w/e T. A. Conley (KDHE), w/a, w/e G. B. Miller (NRC), w/a, w/e B. K. Singal (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, W/e

ET 10-0005 Page 3 of 3 STATE OF KANSAS )

COUNTY OF COFFEY )

Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By TerrysJ arrett Vice President Engineering SUBSCRIBED and sworn to before me this ,' day of /Y rC¢--- ,2010.

Notary Aublic GAYLE SHEPHEARD6 m& Notary Public - State of Kansas Expiration Date 7/2 o2/1 My Appt. Expires '1"2qizo(/

Attachment to ET 10-0005 Page 1 of 11 REQUEST FOR ADDITIONAL INFORMATION DEVIATION FROM FIRE PROTECTION PROGRAM REQUIREMENTS WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 By letter dated March 4, 2009 (Agencywide Documents Access and Management System, (ADAMS) Accession No. ML090771269), Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee) requested for approval to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR) for Wolf Creek Generating Station (WCGS), pursuant to the License Condition 2.C(5).

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by the licensee and determined that the following additional information is needed in order to complete the review. It was agreed that the licensee will provide the additional information being requested by March 26, 2010.

Please note that the licensee's submittal included interim compensatory operator manual actions (OMAs) for Fire Area A-27; however, interim compensatory measures are outside the scope of this license amendment request review. As such, these were not included in the review. The use of interim compensatory measures should be implemented in accordance with the licensee's approved fire.protection program.

Request for Additional Information (RAI)

Note/Correction: On February 3, 2010, the NRC Senior Project Manager for WCGS telephoned WCNOC and indicated that references to "Attachment I" should be changed to "Enclosure I." Therefore, when a reference is made to "Attachment I" in the following NRC RAI items, WCNOC understands that it is actually referring to "Enclosure I."

RAI-01: Ensuring That One of the Redundant Trains Is Free of Fire Damage Section 3.0 of Attachment I of the licensee's submittal includes a description of the OMAs and provides the history of correspondence with the NRC staff. This section also states that the licensee received a green non-cited violation (NCV) for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. It is also stated that the green NCV of License Condition 2.C.(5) existed because WCGS credited the use of manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix R, Section Ill.G.2.

The NCV was later re-categorized to an Apparent Violation with enforcement discretion.

The method described in the request appears to demonstrate safe shutdown capability independent of the fire area of origin consistent with Section III.G.3 of Appendix R to 10 CFR Part 50, yet the request is for deviation from the requirements of Section III.G.2.Section III.G.2

Attachment to ET 10-0005 Page 2 of 11 specifically states that measures must be taken to ensure that one of the redundant trains remains free of fire damage within the fire area.Section II.G.3 addresses alternative or dedicated shutdown capability independent of the fire area of origin-and establishes a series of requirements to achieve and maintain safe shutdown capability.

RAI-01.1: Please confirm and state whether deviation from Section Ill.G.2 requirements is the appropriate request for all of the OMAs in the request, since safe shutdown capability is provided independent of the fire area of origin for most of the fire areas.

WCNOC Response:

Section 1.2 of WIP-E-1F9900-004-A-1 was added to indicate the purpose of the document is to evaluate manual actions credited for Appendix R,Section III.G.2, areas. Section 3.0 of WIP-E-1F9900-004-A-1 was revised to identify that the Control Room (Fire Area C-27) is the only Appendix R,Section III.G.3, area at WCGS. Remaining plant fire areas are Appendix R,Section II.G.1 or Section III.G.2. This is consistent with the USAR comparison response to 10 CFR 50 Appendix R, Section Ill.G, which is part of the original fire protection program description approved by the NRC. WCNOC believes that it is appropriate for the fire areas identified in WIP-E-1F9900-004-A-1 to continue as Section lII.G.2 areas, with approved OMAs as a mitigating measure, where the separation criteria of Section IIl.G.2 is not directly satisfied for the limited number of non-compliant post-fire safe shutdown (PFSSD) credited circuits. The basis for this position is the feasibility and reliability analysis, coupled with the defense in depth discussion, provided in WIP-E-1F9900-004-A-1. Additionally, based on historical interaction with the NRC at various fire protection industry forums and workshops, it ýis WCNOC's understanding that the NRC Fire Protection Staff prefers to limit the use of Appendix R,Section III.G.3, to Control Room and common (both train) Cable Spreading Room areas.

RAI-01.2: Please state the specific requirements of Section II.G.2 that are not met for each of the requested OMAs (e.g., a lack of fire barriers, spatial separation, automatic suppression, etc.).

WCNOC Response:

Note: Reference to a Section "X" for Section 8 of WIP-E-1F9900-004-A-1, reflects that the corresponding section for each fire area within Section 8.1 to 8.15 was revised to address the RAI.

Section 8X2 "Spurious Equipment Operation requiring Operator Manual Action" of WIP-E-1F9900-004-A-1 was revised for each fire area to identify the attributes of Appendix R,Section III.G.2, that are not satisfied for each condition warranting the

Attachment to ET 10-0005 Page 3 of 11 implementation of a mitigating OMA. The generic methodology discussed in Section 5.1.2 was also revised to reflect this approach.

RAI-01.3: Please provide a summary of the plant specific features that compensate for the lack of Section III.G.2-required features, identified in RAI-01.2, for each of the requested OMAs. For example, note any enhanced defense-in-depth measures such as a lack of ignition sources or combustibles, partial spatial separation, more robust or supplemental detection and suppression systems, and other physical or administrative controls.

WCNOC Response:

Section 8.X.15 "Defense in Depth" of WIP-E-1F9900-004-A-1 was revised for each fire area to provide additional detail on the defense in depth fire protection features for the area. The generic methodology discussed in Section 5.1.15 was also revised to reflect the approach utilized, which involved the application of NRC Inspection Manual 0609, Appendix F, Fire Protection Significance Determination Process, as appropriate.

RAI-01.4: Appendix R to 10 CFR Part 50 establishes the concept of defense-in-depth and Section III.G.2 requires operators be able to safely and reliably achieve and maintain hot shutdown capability from the control room. Please provide a technical explanation that justifies how the proposed methods will result in a level of protection that is commensurate with that intended by Section III.G.2.

WCNOC Response:

The feasibility and reliability analysis coupled with the revised "Defense in Depth" discussion for each fire area provides reasonable assurance that the operator manual actions are an acceptable alternative measure to the requirements of Appendix R,Section III.G.2.

RAI-02: Other Evaluations Fire areas may have other evaluations that affect fire protection systems or safe shutdown capabilities. For example, Section 3.0 of Attachment I of the licensee's submittal mentions that some OMAs were eliminated based on analyses or modifications that were performed after the licensee received an Apparent Violation but does not indicate whether these efforts have been accounted for in the request.

RAI-02.1: Please provide a discussion of any other evaluation, including licensee-developed evaluations (e.g., Generic Letter 86-10 evaluations), which impact this request in any way and provide a justification for why such impact should be considered acceptable.

Attachment to ET 10-0005 Page 4 of 11 WCNOC Response:

The analyses and modifications referred to in Section 3.0 of WIP-E-1F9900-004-A-1 were performed to reduce reliance on OMAs in Section III.G.2 areas. These analyses and modifications are not included in this request. Analyses were performed to determine if credible circuit failures exist to cause a spurious operation or maloperation that warrants an OMA. Analyses were also performed to determine if the spurious operation or maloperation that warrants the OMA will adversely impact the ability to achieve and maintain hot standby and cold shutdown. Modifications were performed to either re-route cables or modify the circuit to eliminate the OMA.

Existing evaluations (Generic Letter 86-10 evaluations, National Fire Protection Association (NFPA) code compliance assessments, Wolf Creek Safety Evaluation Report (SER)) were reviewed to determine if they could adversely impact the request. Based on a review of these evaluations, it was determined that this request is not adversely impacted by existing evaluations.

WIP-E-1F9900-004-A-1 identifies the OMAs that are Required for Hot Standby or are Important to Safe Shutdown. The OMAs identified in WIP-E-1F9900-004-A-1 take into account all completed PFSSD modifications. Section 2.5 through 2.7 of WIP-E-1F9900-004-A-1 identifies impending actions that address the elimination of compensatory measure OMAs, which are not addressed by WIP-E-1 F9900-004-A-1 The intent of WIP-E-11F9900-004-A-1 is to demonstrate the feasibility and reliability of OMAs credited in lieu of direct compliance with Appendix R,Section III.G.2, protection. Consistent with NUREG-1852 guidance, the analysis conservatively assumes that the fire initiating event, necessitating OMA implementation, occurs.

Based on RAI content, it appears that the NRC focus is on fire protection features that would prevent the fire induced equipment maloperation and the probability of such a fire event occurring. These are elements that are not within the scope of NUREG-1852, as the Introduction for NUREG-1852 states that the feasibility and reliability analysis approach is deterministic.

In response to an RAI theme related predominantly to prevention/likelihood of fire event occurrence, Section 8.X.15 "Defense in Depth" in WIP-E-1F9900-004-A-1 was revised for each fire area to provide additional detail on the defense in depth fire protection features for the area. The generic methodology discussed in Section 5.1.15 was also revised to reflect the approach utilized, which involved application of NRC Inspection Manual 0609, Appendix F, Fire Protection Significance DeterminationProcess, as appropriate.

Generic Letter 86-10 evaluations, NFPA codes of record, and NFPA code compliance items are included within other elements of the fire protection program (predominantly USAR and fire protection documents incorporated by reference

Attachment to ET 10-0005 Page 5 of 11 within the USAR). Section 5.1.15 of WIP-E-1F9900-004-A-1 was revised to reflect the following:

• Fire protection systems are predominantly installed per the NFPA code of record delineated in the USAR;

• The Wolf Creek SER documents NRCs acceptance of the original installation of the fire protection systems.

• Code deficiencies are evaluated for acceptability;

• There are no code compliance items or unique/unbounded fire barrier features that present an adverse impact to OMA diagnosis or implementation.

RAI-03: Fire Protection System and Fire Barrier Design Criteria Section 8.0 of Attachment I of the licensee's submittal states that several areas are equipped with various fire detection and suppression systems but does not state whether the systems that are provided have been designed and installed in accordance with applicable design standards or requirements.

RAI-03.1: Where fire protection features are installed, such as detection and suppression systems and fire-rated assemblies, please describe the technical basis for such installations including the applicable codes, standards, and listings.

For example:

Section 8.1.1 of Attachment I of the licensee's submittal states that smoke detection is provided in Fire Area A-1 in areas where circuits of concern are routed.

Please state whether the detectors have been installed and maintained in accordance with a particular design standard or basis (e.g., National Fire Protection Association (NFPA) 72: National Fire Alarm Code, 1985 Edition).

Section 8.1.1 of Attachment I of the licensee's submittal states that a pre-action sprinkler system is located in Fire Area A-1 in areas with a high concentration of cable trays. Please state whether this system has been installed and maintained in accordance with a particular design standard or basis (e.g., NFPA 13: "Standard for the Installation of Sprinkler Systems," 1985 Edition). Where pre-action systems or interlocks are provided, please include the design standard and basis for the associated systems.

Section 8.4.1 of Attachment I of the licensee's submittal states that a total flooding Halon system is installed in Fire Area A-1 8. Please state whether the Halon system was installed and maintained in accordance with a particular design standard or basis (e.g., NFPA Standard 12A, 1985 Edition).

Attachment to ET 10-0005 Page 6 of 11 WCNOC Response:

See response to RAI-02.1.

RAI-03.2: Please provide a technical justification for any deviations from codes, standards, and listings by independent testing laboratories in the fire areas that could impact this evaluation.

WCNOC Response:

See response to RAI-02.1.

RAI-03.3: Please provide a technical justification for any non-rated fire protection assemblies.

WCNOC Response:

See response to RAI-02.1.

RAI-04: Ignition Sources and Combustible Fuel Load Section 8.0 of Attachment I of the licensee's submittal states that the areas included in the request have combustible loading allowances and hot work limitations that are consistent with other areas important to safe shut down but does not discuss what those allowances and limitations are or what the actual hazards are in each of the areas.

RAI-04.1: Please provide critical details or assumptions regarding the in-situ and transient fire hazards that could threaten redundant equipment for each fire area included in the requests. This information may include, but is not limited to:

° The number, type, and location of potential ignition sources,

° The number and types of equipment that may exhibit high-energy arcing faults, and the relationship between this equipment and any secondary combustibles, o The quantity of cables and other secondary combustibles and their relationship to potential ignition sources,

• The cable type (e.g., thermoplastic or thermoset); if thermoplastic cables are used, please provide a discussion of self-ignited cable fires,

• Ratings for cables (e.g., Institute of Electrical and Electronics Engineers (IEEE) 383, etc.); if not rated, please justify why fire spread would be assumed to be slow,

Attachment to ET 10-0005 Page 7 of 11 Controls on hot work and transient combustibles in the area, and the proximity of secondary combustibles that could be impacted by a transient fire, and Dimensions of the rooms, including ceiling heights.

WCNOC Response:

Section 5.1.15 of WIP-E-1F9900-004-A-1 was revised to discuss fire protection elements generic to multiple fire areas such as cable type, items not considered a credible ignition source, and fire protection administrative controls. Section 8.X.15 of WIP-E-1F9900-004-A-1 was revised for each fire area to provide an analysis to assess if there is a credible fire severity that would result in the need for OMA implementation. This analysis, which utilized NRC Inspection Manual 0609 Appendix F as guidance, determined the zone of influence fire effect on target cables taking into consideration area ignition sources, in-situ combustibles, and transient combustibles, where applicable.

Section 8.X.1 of WIP-E-1F9900-004-A-1 was revised for each fire area to identify approximate room dimensions. Room height is also identified in Attachment B1 of WIP-E-1F9900-004-A-1. Attachment D was added to WIP-E-1F9900-004-A-1, to provide a general plan view for each fire area.

RAI-05: Fire Scenarios The request identifies the OMAs needed in each fire area, but does not describe the fire scenarios that have been considered for the postulated events. For example, in the event of fire in Fire Area C-18, OMAs may be required to operate valves and breakers. However, no information is provided to describe the separation between the redundant train cables. It is also not clear where the cables are located relative to the floor, walls, and other trains or whether any spatial separation exists between the two trains.

RAI-05.1: Please provide a description of the proximity of the redundant train equipment to in-situ hazards and the spatial relationship between the redundant trains in the fire area such that if they are damaged, manual actions would be necessary. Note, that this question is distinct from the RAI -addressing Ignition Sources and Combustible Loading, which is generally focused on the combustibles in an area, whereas this RAI addresses the specific relationship between ignition sources and combustibles and the redundant trains.

WCNOC Response:

Section 8.X.2 of WIP-E-1F9900-004-A-1 was revised for each fire area to provide a general descriptive location of the circuits of concern including identification of the

Attachment to ET 10-0005 Page 8 of 11 worst-case spatial separation distance. Significant intervening in-situ combustibles and ignition sources are identified in Section 8.X.15.1, where applicable.

RAI-05.2: Please provide a discussion of the suppression, detection, and any other systems that are present and capable of mitigating the postulated events for the fire areas included in this request.

WCNOC Response:

Section 8.X.1 of WIP-E-1F9900-004-A-1 identifies the active and passive fire protection features for each fire area. Smoke fire alarm system response- time is identified in Attachment BI. Section 5.1.15 was revised to reflect that the NFPA code of record is identified in the USAR.

RAI-06: Required ODerator Stations The request does not specify what has been assumed for the location from which operators are dispatched to perform the OMAs or whether scenarios were evaluated where operators were not at their assumed locations at the beginning of an event. The location or activities of required plant personnel when the fire starts could delay their participation in executing the OMAs (e.g., they may be in a location that is on the opposite side of the plant from the main control room or may need to restore certain equipment before being able to participate or both).

RAI-06.1: Please provide a justification for the assumption that operators will be located at an assumed location when the OMA procedure begins. If there is no assurance that the operators will be at the assumed locations, provide the times required for them to reach the locations and indicate how these times are reflected in the analysis.

WCNOC Response:

Section 5.1.14.2 of WIP-E-1F9900-004-A-1 was revised to discuss the timing allowance for the initial procedure OFN KC-016, "Fire Response," operator response to the Control Room.

RAI-07: Pressure Interface Section 8.1 of Attachment 1 of the licensee's submittal states that either valve BGLCV0459 or BGLCV0460 must be closed "to ensure adequate charging flow." This section also states that if "letdown is the only flow diversion event," both valves "can remain open for one hundred eighty (180) minutes without any adverse consequence to reactor performance." However, for cases where fire causes a single atmospheric relief valve (ARV) to spuriously open, the time both valves can remain open decreases significantly to 50 minutes. The actions to close BGLCV0459 and BGLCV0460 are identified as being "'reactive actions" which are only implemented in response to indications of changing equipment conditions caused by the fire.

Attachment to ET 10-0005 Page 9 of 11 Thus, action to close BGLCV0459 and BGLCV0460 would not be initiated until the "relevant indications" are observed by operators.

Additionally, the request states that closure of KAV0201 will fail air to all air operated components within the Reactor Building and the historical performance of Integrated DIG

[diesel generator] and Safeguards Actuation Test, STS KJ-001A, shows that BGLCV0459 and BGLCV0460 will fail closed within 3 minutes following isolation of instrument air.

RAI-07.1: Please confirm that the evaluation of time available to close the letdown valves in the event of a single spurious ARV, bounds all potentially adverse fire damage impacts, including multiple spurious actuations, that could occur in any fire area which credits an OMA to close letdown isolation valves BGLCV0459 and BGLCV0460.

WCNOC Response The Wolf Creek thermal hydraulic analysis (WCNOC-CP-002, Rev. 0), Scenarios 1 and 3 analyze the time to mitigate letdown considering other potential multiple spurious operations (MSOs). The times vary from Fire Area to Fire Area because the postulated spurious operations differ. In some cases, calculation WCNOC-CP-002 indicates that letdown can remain open with no adverse impact on safe shutdown. Other scenarios require letdown to be isolated in 10,800 seconds (180 minutes), 7200 seconds (120 minutes) and 3000 seconds (50 minutes). These times were applied in the manual action timing analysis based on the fire area under consideration and the postulated spurious operations that could occur for that Fire Area. Therefore, the times utilized in WIP-E-1F9900-004-A-1 are bounded by the times determined by the thermal hydraulic analysis.

RAI-07.2: Please describe how, in the absence of other key parameters such as valve position indication or alarm annunciators, these indications are sufficient to ensure that operators will quickly and reliably identify the need to close BGLCV0459 and BGLCV0460.

WCNOC Response The protected indications that will allow operators to diagnose the failure of letdown to isolate are the pressurizer level indication and the volume control tank (VCT) level indication. In all areas where letdown may not isolate due to fire damage, both parameters are protected. The exact protected instrumentation that remains undamaged and available for diagnostic use is given to the operators in the fire response procedure, OFN KC-016. A volume change in the VCT due to uncontrolled letdown flow will be noticed by an increasing level while a volume change in the pressurizer due to uncontrolled letdown flow will be noticed by a decreasing level. This provides diverse indication that water is being transferred from the RCS to the VCT. The only path that can transfer water from the RCS to the VCT is the letdown line.

Attachment to ET 10-0005 Page 10 of 11 As discussed in section 5.1.14 of WIP-E-1F9900-004-A-1, the Control Room Supervisor is responsible for directing OFN KC-016 actions. The procedure is configured such that another Control Room Operator can assist in the review of the applicable procedure attachment for potential OMAs. The procedure directs OMA review immediately following fire brigade callout and the request for off-site fire department assistance, which are the initial actions following fire confirmation. The strategic approach to include the OMA review as soon as practical within the fire response procedure ensures that Control Room personnel are promptly made aware of potential OMAs, including the instrumentation that can be relied upon to assess the need for performing the OMA. The OMA review is a continuous action step within OFN KC-016, which means that the operator is responsible for observing the step for potential response throughout the fire event.

If the OMA operator were to isolate air to the containment based on only one of the two parameters changing in the direction indicating failure of letdown to isolate, there would be no negative consequences. Table 5.1.3.1-1 in WIP-E-1F9900-004-A-1 provides an analysis of all air-controlled components inside containment and shows that there is no negative consequence to PFSSD if all air to the containment were lost.

RAI-08: Diagnosis Time for Reactive OMAs Section 5.1.14 of Attachment 1 of the licensee's submittal states that "based on procedure structure and observed Control Room operator performance during fire brigade drill activities, it is conservatively concluded that Control Room personnel will consistently diagnose the need to perform a reactive OMA within seven (7) minutes of a confirmed fire alarm condition."

RAI-08.1 Please provide a technical justification to support the position that Control Room personnel will consistently diagnose the need to perform a reactive OMA within 7 minutes of a confirmed fire alarm condition or how procedure structure and Control Room observations support this position.

WCNOC Response Section 5.1.14.1 of WIP-E-1F9900-004-A-1 was revised to provide additional discussion regarding the structure of fire response procedure OFN KC-016 in relation to the timeliness of operator OMA review following fire confirmation.

Attachment to ET 10-0005 Page 11 of 11 RAI-09: Staffing Section 8.1.13 of Attachment 1 of the licensee's submittal states that the operator assigned OFN KC-016 (Fire Response Procedure) OMA duty for the shift is responsible for performing the OMA.

RAI-09.1 Please confirm that individuals that might be needed to perform the OMAs do not have collateral duties, such as firefighting, security duties, or control room operation, during a postulated fire event.

WCNOC Response Section 5.1.13 of WIP-E-1F9900-004-A-1 was revised to reflect that the operator assigned OFN KC-016 OMA duty also does not have any Security responsibilities.

The referenced section had previously identified that the OFN KC-016 OMA position had no Control Room, Fire Brigade, or Emergency Planning responsibility.

Enclosure to ET 10-0005 WIP-E-1F9900-004-A-1, Revision 1 "Post-Fire Safe Shutdown Operator Manual Actions"

Post-Fire Safe Shutdown Operator Manual Actions Page 1 of 148 WIP-E-1F9900-004-A-1, Rev. I COVER SHEET REVISED INCOPORATED Change CHC. DOC. PKG. No. 012954 Rev. 1 E] ISSUED THIS DWG. SUPERSEDED BY REV. THISDWG SUPERSEDES REV.

REVISION NOTES:

WIP-E-1F9900-004-A-1 is a complete replacement of E-11F9900, Revision 4. The WIP will not be released as a revision to E-1 F9900 until approval is received from the NRC. Correspondence ET 09-0007 documents Wolf Creek's license amendment request for the feasibility and reliability analysis provided in WIP-E-1F9900-004-A-1.

Revision 1 of WIP-E-1 F9900-004-A-1 addresses NRC Request for Additional Information, documented in ET 10-0005.

Post-Fire Safe Shutdown Operator Manual Actions SCALE DRAWING NUMBER REV NONE WIP-E-1F9900-004-A-1 1 Digitally signed by Brian R Fox Date:

2010.03.25 Kay Lynn Smith Document Control Release 15:39:12 -05'00' 2010.03.25 16:14:16 -05'00'

Post-Fire Safe Shutdown Operator Manual Actions Page 2 of 148 WIP-E-1F9900-004-A-1, Rev. I Table of Contents 1.0 Purpose 3 2.0 Scope 3 3.0 Background 4 4.0 Definitions 7 5.0 Methodology 13 6.0 E-1F9900 Revision Guidance 33 7.0 References 33 8.0 Feasibility and Reliability Review 36 8.1 Fire Area A-I, Auxiliary Building 1974' General Corridor 36 8.2 Fire Area A-11, Auxiliary Building 2000' Cable Chase 45 8.3 Fire Area A-16, Auxiliary Building 2026' General Corridor 51 8.4 Fire Area A-18, Auxiliary Building 2026' North Electrical Penetration Room 60 8.5 Fire Area C-7, Control Building 1984' Cable Chase 70 8.6 Fire Area C-12, Control Building 2000' North Cable Chase 76 8.7 Fire Area C-18, Control Building 2016' Cable Chase 82 8.8 Fire Area C-21, Control Building 2032' Lower Cable Spreading Room 89 8.9 Fire Area C-22, Control Building 2073'-6 Upper Cable Spreading Room 100 8.10 Fire Area C-23, Control Building 2032' South Cable Chase 108 8.11 Fire Area C-24, Control Building 2032' North Cable Chase 114 8.12 Fire Area C-30, Control Building 2047'-6 121 8.13 Fire Area C-33, Control Building 2073'-6 127 8.14 Fire Area RB, Reactor Building General Area 133 8.15 Fire Area A-27, Auxiliary Building 2026' Rod Drive MG Set Room 140 Attachment A Summary of OMAs to Achieve and Maintain Hot Standby A-1 Attachment B1 Fire Alarm System Response Time B1-1 Attachment B2 Sample FDT Data Sheet NUREG-1805 FDT 11. Estimating Smoke Detector Response Time B2-1 Attachment C Photos of Equipment Manipulated For Operator Manual Action C-1 Attachment D Fire Area Plan View Sketches D-1

Post-Fire Safe Shutdown Operator Manual Actions Page 3 of 148 WIP-E-1F9900-004-A-1, Rev. I 1.0 Purpose 1.1 The purpose of this document is to evaluate the feasibility and reliability of operator manual actions (OMA) that are potentially necessary to ensure the availability of a post-fire safe shutdown (PFSSD) success path to achieve and maintain hot standby conditions, in response to a single fire event outside the Control Room.

1.2 The OMAs, which are for 10 CFR 50 Appendix R, Section III.G.2, fire areas, are evaluated for feasibility and reliability utilizing the guidance provided in NUREG-1852.

1. The OMAs for Fire Area A-27 are evaluated for feasibility only. Refer to Section 2.6 for further discussion.

2.0 Scope 2.1 This feasibility and reliability review is applicable to OMAs, as defined in Section 4.11. Attachment A summarizes the OMAs, and the fire areas affected.

2.2 Consistent with the scope of NUREG-1 852, actions taken within the Control Room that are potentially necessary to mitigate or prevent the undesirable affects of fire induced spurious equipment operation are not addressed within this review for feasibility and reliability. Control Room Actions are identified in E-1 F9910, Post-Fire Safe Shutdown Fire Area Analysis, and procedural guidance is provided in OFN KC-016, Fire Response.

2.3 Fire areas that do not require a mitigating action to ensure preservation of a PFSSD success path, are not addressed within this review. Refer to E-1F9910 for the detailed PFSSD analysis for each fire area.

2.4 Actions required for transition to cold shutdown are not included. Hot standby is a safe, stable condition for the plant. Consistent with 10 CFR 50 Appendix R, Section III.G.l.b, cold shutdown repairs are required to be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

However, cold shutdown is not required to be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2.5 Interim compensatory OMAs that are being eliminated as a result of plant modifications are not included within this review. These modifications include the following:

1. Change Package 012368 and 012568 - Darmatt fire wrap protection for BGLT0185 and BGLCV0112C. This change will reduce vulnerability within Fire Area A-8 for the VCT outlet valves to spuriously stick open, resulting in the potential for charging pump gas binding. This modification addresses a Required for Safe Shutdown component (charging pump). It is a multiple spurious operation (MSO) from a PFSSD perspective, as both VCT outlet valves stick open and letdown is diverted from the VCT. In addition to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected area.

Post-Fire Safe Shutdown Operator Manual Actions Page 4 of 148 WIP-E-1F9900-004-A-1, Rev. I

2. Change Package 012944 - Pressurizer PORV Cable Reroute to allow PORV closure from Control Room. This modification is in response to LER 2008-009. The modification addresses an Important to Safe Shutdown element, as the pressurizer PORVs are not required for PFSSD. However, closure of the PORVs is desired to prevent an RCS flow diversion. It is a MSO equipment operation from a PFSSD perspective, as the fire induced mal-operation of both the PORV and its associated block valve must occur before the event would require outside Control Room response. In addition to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected areas.

2.6 The interim compensatory measure OMAs for Fire Area A-27 are evaluated for feasibility only. These interim OMAs will be eliminated with the implementation of Change Package 012418. This modification will install fire rated cable for protection of EGHV0016, CCW 'B' Return and EGHV0054 CCW 'B' Supply. The modification addresses a Required for Safe Shutdown element (component cooling water supporting 'B' Train Charging). It is a single spurious equipment operation from a PFSSD perspective as the fire induce failure, will affect CCW cooling to the seal water heat exchanger. The interim OMAs are included within this analysis, as they are manual actions that are within the March 5, 2009 enforcement discretion scope discussed in Section 3.0. In addition to an OMA compensatory measure for the issue, a fire watch compensatory measure has been established for the affected area.

2.7 The interim compensatory manual action for protection of reactor coolant pump (RCP) seals is not included within this review as the OMA is being eliminated by a Technical Specification (TS) change. The TS change will allow the seal injection containment isolation valves to be open with power to the motor operated valve removed. This modification addresses an Important to Safe Shutdown element, as the reactor coolant pumps are not required for PFSSD. However, RCP seal cooling is desired to prevent an RCS flow diversion, as a result of RCP seal failure. It is a MSO equipment operation from a PFSSD perspective, as both seal injection and thermal barrier cooling must be lost before the event would require outside Control Room response. In addition to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected areas.

3.0 Background The Wolf Creek comparison to 10 CFR 50, Appendix R is contained in USAR, Appendix 9.5E.Section III.G of Appendix R requires fire protection of safe shutdown capability to ensure the ability to achieve and maintain safe shutdown following a severe fire. Outside containment, three separation methods are recognized by the NRC to ensure at least one success path is available to achieve and maintain safe shutdown following a fire where redundant components are located in the same fire area. These methods are as follows:

1. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour fire rating.

Post-Fire Safe Shutdown Operator Manual Actions Page 5 of 148 WIP-E-1F9900-004-A-1, Rev. 1

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

3. Enclosure of cables and equipment and associated non-safety circuits of redundant trains in a fire barrier having a 1-hour fire rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the area.

Inside non-inerted containments, the following criteria apply:

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

2. Installation of fire detectors and an automatic fire suppression system.

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

The Wolf Creek response to the requirements of Section III.G of Appendix R is as follows:

USAR Appendix 9.5B provides an area-by-areaanalysis of the power block that demonstrates that no single fire can prevent safe shutdown. Redundant trains of systems requiredto achieve and maintain hot standby are separatedby 3- hour rated fire barriers,or the equivalent provided by I//. G. 2, or else a diverse means of providing the safe shutdown capabilityexists and is unaffected by the fire. For redundant trains of systems requiredto achieve and maintain cold shutdown that could potentially be affected by a single fire, repairs orlocal operator actions can be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. As describedin Appendix 9.5B and Section 7.4, an auxiliary shutdown panel is provided as a dedicated means of achieving and maintaininghot standby in the event that the main control room is uninhabitable due to a fire. The ESW pump house also complies.

Initially, Wolf Creek's position was that the license commitment described in the USAR comparison response to 10 CFR 50 Appendix R, Section III.G, allowed the use of "diverse means" to achieve safe shutdown. Diverse means was interpreted by Wolf Creek to mean any reasonable means, in compliance with other license requirements, necessary to ensure the plant can be brought to safe shutdown conditions following a fire. For example, valve or breaker manipulations are considered reasonable since they are performed as part of normal operator duties.

Repairs necessary to achieve hot standby conditions were not considered reasonable since they are not allowed by 10 CFR 50 Appendix R.

Post-Fire Safe Shutdown Operator Manual Actions Page 6 of 148 WIP-E-1F9900-004-A-1, Rev. 1 During the 2005 NRC Fire Protection Triennial Inspection, Wolf Creek received a green non-cited violation (NCV) of License Condition 2.C.(5), "Fire Protection (Section 9.5.1, SER; Section 9.5.1.8, SSER 5)," for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The NRC inspection report concluded that a green NCV of License Condition 2,C.(5) existed because Wolf Creek credited the use of manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2.

Wolf Creek denied the NCV, as documented in letter WM 06-0013 (Reference 7.10).

The NRC concluded in their response letter (Reference 7.11) to the denial, that the use of operator manual actions in lieu of direct compliance with the separation requirements of 10 CFR 50 Appendix R Section III.G.2, is not within Wolf Creek's current fire protection license basis. The NCV received for this issue during the 2005 NRC Fire Protection Triennial was re-categorized to an Apparent Violation with enforcement discretion. The enforcement discretion identified in the referenced NRC letter was consistent with that published in the March 6, 2006 Federal Register Notice regarding operator manual actions. This Federal Register Notice withdrew the proposed rule from 10 CFR 50 Appendix R to codify the acceptability of operator manual actions in lieu of compliance with the separation requirements of Appendix R,Section III.G.2. Wolf Creek accepted the Apparent Violation and is complying with the following requirements in effort to receive enforcement discretion through March 5, 2009:

" Implement compensatory measures and initiate corrective actions within 6 months of the publication date of the Federal Register Notice (i.e., by September 5, 2006).

• The enforcement discretion will continue provided the appropriate compensatory measures are maintained and the planned corrective actions are completed within 3 years of the publication date of the Federal Register Notice (i.e., March 5, 2009).

In response to the Apparent Violation Wolf Creek developed a plan to address resolution of the manual actions issue. The plan contained the following major milestones:

A. Perform a detailed circuit analysis to determine if a credible circuit fault condition is present to warrant the mitigating manual action currently credited.

No operator manual actions were eliminated as a result of this additional PFSSD review.

B. Perform a thermal hydraulic analysis (WCNOC-CP-002) to assess plant performance when an OMA was credited in response to fire induced spurious equipment operation.

Some OMAs were eliminated in cases where the thermal hydraulic analysis demonstrated that the OMA was not required to be implemented to achieve and maintain hot standby.

Post-Fire Safe Shutdown Operator Manual Actions Page 7 of 148 WIP-E-1F9900-004-A-1, Rev. 1 C. Where cost beneficial, implement plant modifications to comply with 10 CFR 50 Appendix R, Section III.G.2.

Several plant modifications were implemented to either completely eliminate the need for an operator manual action or improve the overall feasibility and reliability of remaining operator manual actions for a specific fire area.

Modifications included: cable reroute, instrument relocation, creation of a new fire area, and application of raceway fire barrier protection.

D. For remaining operator manual actions that were cost prohibitive to address by modification or presented a reasonable success probability for acceptance based on available time margin, a feasibility and reliability analysis, considering NUREG-1852 guidance, was conducted. The NUREG-1852 feasibility and reliability analysis is contained within this document. The information within SECY-08-0093 was utilized as guidance to determine if the identified OMA required prior NRC approval in order to credit an OMA as a permanent resolution. SECY-08-0093 divides equipment important to safe shutdown into the following two classifications:

• One train of systems necessary to achieve and maintain hot shutdown conditions (identified as "Required for Hot Standby" in this analysis). For fire induced spurious operation within this classification, SECY-08-0093 identifies there is no allowance for OMA without prior NRC approval.

• Equipment important to safety that could be damaged by a single fire, and the spurious equipment operation could result in either an indirect or direct affect on PFSSD capability. However, the equipment is not credited as an element of the analyzed PFSSD success path. This equipment subset is identified as "Important to Safe Shutdown" within this analysis. SECY-08-0093 indicates that prescriptive requirements of 10 CFR 50, Appendix R Sections III.G.1 .a and III.G.2 do not apply, and an OMA is an acceptable mitigating action for the spurious equipment operation. NRC approval is not required in this case.

Consistent with the USAR comparison response to 10 CFR 50 Appendix R, Section IIl.G, the Control Room (Fire Area C-27), is the only fire area analyzed for PFSSD utilizing the alternative/dedicated shutdown criteria described in Appendix R,Section III.G.3 and Section III.L. All other fire areas are analyzed utilizing Appendix R,Section III.G.1 or Section III.G.2 (redundant shutdown), criteria. In all cases, the identified OMAs mitigate conditions where the separation requirements of Appendix R,Section III.G.2, are not directly satisfied.

4.0 Definitions 4.1 Action 4.1.1 An activity, typically observable, and usually involving the manipulation of equipment, that is carried out by an operator(s) to achieve a certain outcome. The required diagnosis of the need to perform the activity, the subsequent decision to perform the activity, obtaining any necessary equipment, procedures, or other aids or devices necessary to perform the activity, traveling to the location to perform the activity, implementing the activity, and checking that the activity has had its desired effect, are all implied and encompassed by the term "action."

Post-Fire Safe Shutdown Operator Manual Actions Page 8 of 148 WIP-E-1F9900-004-A-1, Rev. 1 4.2 Available Time (or Time Available) 4.2.1 The time period from a presentation of a cue for an action to the time of adverse consequences if the action is not taken. This time is based on one of the following:

a. Thermal hydraulic analysis, where plant thermal performance is not adversely affected. The thermal hydraulic analysis is documented in WCNOC-CP-002 and SA-08-006. Fire induced spurious equipment actuation requiring OMA implementation are assumed to occur simultaneously at the onset of the event.

b. Established Technical Specification or Technical Requirements Manual for allowed equipment outage times.

c. Referenced source (calculation, analysis, industry document, etc.).

4.3 Cold Shutdown 4.3.1 Plant Mode 5, which is within the following parameters:

Reactivity Condition  % Rated Thermal Average Reactor Coolant (km) Power (excluding Temperature (°F) decay heat)

< 0.99 N/A < 200 4.4 Control Room Action 4.4.1 Action within the Control Room to mitigate or prevent the undesirable affects of fire induced spurious equipment operation.

4.5 Diagnosis Time 4.5.1 The time required for operator(s) to examine and evaluate data to determine the need for, and to make the decision to implement, an action.

4.6 Feasible Action 4.6.1 An action that is analyzed and demonstrated as being able to be performed within an available time so as to avoid a defined undesirable outcome. As compared to a reliable action (see definition), an action is considered feasible if it is shown that it is possible to be performed within the available time; but it does not necessarily demonstrate that the action is reliable. For instance, performing an action successfully one time out of three attempts within the available time shows that the action is feasible, but not necessarily reliable.

Post-Fire Safe Shutdown Operator Manual Actions Page 9 of 148 WIP-E-1F9900-004-A-1, Rev. 1 4.7 Fire Indicated 4.7.1 The point when the fire is detected by either human or automatic detection means. The duration of early fire growth before fire alarm indication is determined based on NUREG-1805 guidance regarding smoke detector response time. Refer to Attachment B1 for further discussion regarding the use of NUREG-1805 Fire Dynamics Tools (FDT).

4.8 Fire Initiation 4.8.1 The point when the fire event commences.

4.9 Hot Standby 4.9.1 Plant Mode 3, which is within the following parameters:

Reactivity Condition  % Rated Thermal Average Reactor Coolant (keff) Power (excluding Temperature ('F) decay heat)

< 0.99 N/A > 350 The residual heat removal (RHR) system is utilized for decay heat removal at RCS temperatures less than 350 0 F. RHR is a cold shutdown system.

4.10 Important to Safe Shutdown 4.10.1 Component that could be damaged by a single fire, and the spurious equipment operation could result in either an indirect or direct affect on PFSSD capability. However, the equipment is not credited as an element of the analyzed PFSSD success path. This is "orange box" equipment as, defined in Table 1 of SECY-08-0093.

4.11 Multiple Spurious Operation (MSO) 4.11.1 Condition where more than one fire induced equipment mal-operation is required before an undesired event, potentially affecting PFSSD, would occur.

4.12 Operator Manual Action (OMA) 4.12.1 Those actions performed by operators to manipulate components and equipment from outside the main Control Room to achieve and maintain post-fire hot standby, but not including "repairs." Operator manual actions comprise an integrated set of actions needed to help ensure that hot standby can be accomplished, given that a fire has occurred in a particular plant area.

Post-Fire Safe Shutdown Operator Manual Actions Page 10 of 148 WIP-E-1F9900-004-A-1, Rev. 1 4.13 OMA Implementation Time (or OMA Time) 4.13.1 The time required by the operator(s) to successfully perform the manipulative aspects of an action (i.e., not the diagnosis aspects themselves, but typically as a result of the diagnosis aspects), including obtaining any necessary equipment, procedures, or other aids or devices; traveling to the necessary location; implementing the action; and checking that the action has had its desired effect.

4.14 OMA Uncertainty Time 4.14.1 A time duration to account for varying conditions/uncertainties that could adversely affect overall OMA completion time. Examples considered include:

" Communication and feedback with Control Room

• Electronically controlled door requiring key access

• Obtain RCA access

• Human centered uncertainties such as size, physical strength, and cognitive difference

• Return trip to Control Room as a result of loss of Gaitronics and Radio communication capability 4.15 Preventive Action 4.15.1 Those actions that, upon entering a fire plan/procedure, the operator(s) takes (without needing further diagnosis) to mitigate the potential effects of possible spurious actuations or other fire-related failures, so as to ensure that hot standby can be achieved and maintained. For these actions, it is generally assumed that once the fire has been detected and located, per procedure, the Control Room crew will direct personnel to execute a number of actions, possibly even without the existence of other damage symptoms, to ensure the availability of equipment to achieve its function during the given fire scenario. In many cases, the only criterion for initiating these actions is the presence of the fire itself. The fire must be confirmed before a preventive action will be taken.

4.16 Reactive Action 4.16.1 Those actions taken during a fire in response to an undesired change in plant condition. In reactive actions, the operator(s) detects the undesired change and, with the support of procedural guidance, diagnoses the correct actions to be taken. Thus, with reactive actions, the plant staff responds to indications of changing equipment conditions caused by the fire, and then takes the steps necessary to ensure that the equipment will function when needed (e.g., manually reopening a spuriously closed valve). The plant staff may not initiate the actions until the procedure indicates that, given the relevant indications, the actions must be performed.

Post-Fire Safe Shutdown Operator Manual Actions Page 11 of 148 WIP-E-1F9900-004-A-1, Rev. 1 4.17 Reliable Action 4.17.1 A feasible action that is analyzed and demonstrated as being dependably repeatable within an available time, so as to avoid a defined adverse consequence, while considering varying conditions that could affect the available time and/or the time to perform the action. As compared to an action that is only feasible (see definition), an action is considered to be reliable as well if it is shown that it can be dependably and repeatably performed within the available time, by different crews, under somewhat varying conditions that typify uncertainties in the available time and the time to perform the action, with a high success rate.

4.18 Required for Hot Standby 4.18.1 Component on the required safe shutdown path for a particular fire area that is designated to perform one or more of the following safe shutdown functions:

" Reactivity control

• Pressure control

• Inventory control

• Decay heat removal

" Process monitoring

• Support systems This is "green box" equipment as defined in Table 1 of SECY-08-0093.

4.19 Single Spurious Equipment Operation 4.19.1 Condition where the fire induced mal-operation of a single component potentially affects PFSSD.

4.20 Time Margin 4.20.1 The amount of Available Time (see definition) remaining following OMA implementation, factoring in uncertainty.

4.21 Undetected Fire Growth Time from initial onset of fire before the fire event is detected.

Post-Fire Safe Shutdown Operator Manual Actions Page 12 of 148 WIP-E-1F9900-004-A-1, Rev. 1 4.22 Zone of Influence The distance (height and radius) from an ignition source, as shown below, considering the ignition source fire plume and radiant heating effects. The fire plume is represented by a cylinder that extends above the ignition source. The diameter of the cylinder (W) is based on the ignition source type. The height of the cylinder is calculated based on ignition temperature threshold for targets located above the fire source. Targets outside the Zone of Influence are postulated to be unaffected by fire involved failure of the ignition source. Only one element (height or radius) needs to be exceeded for the target to be outside of the Zone of Influence. Zone of Influence distances and corresponding heat release rates were developed utilizing information from NRC Inspection Manual 0609, Appendix F.

H I Oirigin R

j

Post-Fire Safe Shutdown Operator Manual Actions Page 13 of 148 WIP-E-1F9900-004-A-1, Rev. I 5.0 Methodology The following methodology was applied for each fire area where fire induced spurious equipment operation could result in the need to perform a mitigating OMA to ensure PFSSD capability. Section 8.0 contains the detailed evaluation for each fire area analyzed, utilizing the format described in Section 5.1. Information generically applicable to the fire areas analyzed in Section 8.0 is provided in Section 5.1.

5.1 Fire Area # and Location The specific fire area and location within the plant is identified. This is the location of the postulated fire.

5.1.1 Fire Area Features A general description of the fire area, including the active fire protection features provided.

A plan view sketch of each fire area is provided in Attachment D.

5.1.2 Spurious Equipment Operation requiring Operator Manual Action A discussion of the equipment that could spuriously operate as a result of the fire is identified. Where relevant, a descriptive location of the affected components within the fire area is provided, as well as the elements of 10 CFR 50 Appendix R, Section III.G.2, that are not directly satisfied.- The spuriously operated equipment is classified as either "Required for Hot Standby" or "Important to Safe Shutdown" and a basis is provided for the classification. Additionally, the equipment mal-operation is classified as either "Single Spurious Equipment Operation" or "Multiple Spurious Operation" (MSO), and a basis is provided for the classification.

5.1.3 Operator Manual Action Description The OMA and location of the action is identified. The OMA is identified as either a "Reactive Action" or "Preventive Action" based on when the OMA implementation occurs in relation to event diagnosis.

Some OMAs necessary to achieve and maintain PFSSD affect more than one component in the plant. The following assesses the impact to PFSSD concerning components affected by OMA implementation. The review determined that implementation of the OMAs identified in Attachment A will not result in an adverse consequence to PFSSD capability.

Post-Fire Safe Shutdown Operator Manual Actions Page 14 of 148 WIP-E-1F9900-004-A-1, Rev. 1 5.1.3.1 Close KAV0201 Closing instrument air valve KAV0201 will fail air to the air operated components within the Reactor Building. This is performed in order to fail letdown isolation valves BGLCV0459 and BGLCV0460. Table 5.1.3.1-1 identifies all other components affected by closing KAV0201. Based on the table, there is not adverse impact of safe shutdown by closing KAV0201.

Table 5.1.3.1-1, OMA Consequence Review for Closing KAV0201 Component Description Consequence Review BBHV7141 Reactor coolant drain tank Valve is normally closed and fails closed on (RCDT) heat exchanger to loss of air. Neither the RCDT nor the PRT are pressurizer relief tank (PRT) PFSSD components. The position of this valve has no impact on safe shutdown.

BBHV8026 PRT nitrogen supply Valve is normally closed and fails closed on loss of air. The PRT is not a PFSSD component. This valve is a containment isolation valve and the safety position of this valve is closed. The position of this valve has no impact on safe shutdown.

BBHV8031 PRT drain to reactor coolant Valve is normally closed and fails closed on drain tank (RCDT) loss of air. Neither the PRT nor the RCDT are PFSSD components. The position of this valve has no impact on safe shutdown.

BBHV8032 Reactor vessel flange leak off Valve is normally open and fails open on loss of air. This valve allows any leakage from the reactor vessel flange to pass to the RCDT.

Flange leakage is not considered in the PFSSD analysis, as it is mechanical. The position of this valve has no impact on safe shutdown.

BBHV8045 Reactor makeup water to PRT Valve is normally closed and fails closed on loss of air. This valve assists in maintaining water level in the PRT. The PRT is not a PFSSD component. The position of this valve has no impact on safe shutdown.

BBHV8141A Reactor coolant pump (RCP) A These valves are on the individual RCP seal seal water outlet return lines. They are normally open and fail open on loss of air. This is the assumed BBHV8141B RCP B seal water outlet PFSSD position of these valves. A loss of air BBHV8141C RCP C seal water outlet to these valves has no negative impact on PFSSD.

BBHV8141D RCP D seal water outlet BBLCV0178 RCP D standpipe fill These valves are normally closed and fail closed on loss of air. The RCP seal BBLCV0179 RCP C standpipe fill standpipes are not PFSSD components. The BBLCV0180 RCP B standpipe fill position of these valves has no impact on safe shutdown.

BBLCV0181 RCP A standpipe fill BBPCV0455B Pressurizer spray valve Air feeds the controllers for the two pressurizer spray valves and modulates the valves.

BBPCV0455C Pressurizer spray valve Based on preoperational testing, loss of air to BBPY0455CA Pressurizer pressure controller the controller causes the spray valves to

Post-Fire Safe Shutdown Operator Manual Actions Page 15 of 148 WIP-E-1F9900-004-A-1, Rev. I Component Description Consequence Review BBPY0455BA Pressurizer pressure controller close. Based on thermal hydraulic analyses (WCNOC-CP-002), closing the pressurizer spray valves creates a more conservative condition inthe primary system.

BGHCV0123 Excess letdown heat exchanger Valve is normally closed and fails closed on isolation loss of air. This valve is not a PFSSD component, but in the failed position it would assist in isolating the excess letdown. The position of this valve has no impact on safe shutdown.

BGHV8143 Excess letdown to RCDT Valve is a three-way valve and fails open to the seal water heat exchanger on loss of air.

This valve is not a PFSSD component and the position of this valve has no impact on safe shutdown.

BGHV8146 Regenerative heat exchanger to These valves are the charging injection valves RCS Loop 1 Cold Leg to the Loop 1 and Loop 4 hot legs. They fail to the open position. For post-fire line-up, BGHV8147 Regenerative heat exchanger to charging is isolated using the containment RCS Loop 4 Cold Leg isolation valves BGHV8105 and BGHV8106.

The position of these valves has no impact on safe shutdown.

BGHV8149A Letdown orifice isolation These valves are the orifice isolation valves on the letdown lines. They fail closed on loss of BGHV8149B Letdown orifice isolation air. Letdown is isolated using BGLCV459 and BGHV8149C Letdown orifice isolation BGLCV460. Closing these valves assists in isolating letdown, but the position of these valves has no impact on safe shutdown.

BGHV8160 Letdown containment isolation Valve is the inboard containment isolation valve valve on the letdown line. It fails closed on loss of air. Letdown is isolated using BGLCV459 and BGLCV460. Closing this valve assists in isolating letdown, but the position of this valve has no impact on safe shutdown.

BGHY8145 Pressurizer spray from Valve is normally closed and fails closed on regenerative heat exchanger loss of air. Itallows charging water to spray in the Pressurizer. Charging is isolated upstream of this valve using BGHV8105 or BGHV8106. The position of this valve has no impact on safe shutdown.

BGLCV0459 Letdown isolation These valves are normally open and fail closed on loss of air. The PFSSD position of these two valves is closed. Failing air to these BGLCV0460 Letdown isolation two valves will place them inthe PFSSD position.

EJHCV8890A RHR A test line to safety These valves are normally closed and fail injection (SI) closed on loss of air. The RHR system is not impacted by the closure of these valves. They iRestiine tare not PFSSD components and their position injection has no impact on safe shutdown.

EJHCV8825 RHR test line to safety injection EMHV8823 SI / accumulator test line These valves are normally closed and fail EMHV8824 SI pump B test line closed on loss of air. The SI system is not

Post-Fire Safe Shutdown Operator Manual Actions Page 16 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Component Description Consequence Review EMHV8843 Boron injection upstream test used for PFSSD and it is not impacted by the line closure of these valves. They are not PFSSD components and their position has no impact EMHV8871 Containment isolation test line on safe shutdown.

EMHV8881 SI pump A test line EMHV8882 Boron injection downstream test line EMHV8889A Hot leg 1 test line EMHV8889B Hot leg 2 test line EMHV8889C Hot leg 3 test line EMHV8889D Hot leg 4 test line EPHCV0943 Nitrogen containment isolation These valves are normally closed and fail closed on loss of air. They are associated EPHV8875A Accumulator A nitrogen supply with the Nitrogen supply to the SI EPHV8875B Accumulator B nitrogen supply accumulators. The SI accumulators are not used for PFSSD. The valves are not PFSSD EPHV8875C Accumulator C nitrogen supply components and their position has no impact EPHV8875D Accumulator D nitrogen supply on safe shutdown.

EPHV8877A Accumulator A test line These valves are normally closed and fail closed on loss of air. They are associated EPHV8877B Accumulator B test line with the SI accumulators. The SI EPHV8877C Accumulator C test line accumulators are not used for PFSSD. The valves are not PFSSD components and their EPHV8877D Accumulator D test line position has no impact on safe shutdown.

EPHV8878A Accumulator A fill line These valves are normally closed and fail closed. They are used to maintain water level EPHV8878B Accumulator B fill line in the SI accumulators. The SI accumulators EPHY8878C Accumulator C fill line are not used for PFSSD. The valves are not PFSSD components and their position has no EPHV8878D Accumulator D fill line impact on safe shutdown.

EPHV8879A Accumulator A test line These valves are normally closed and fail closed on loss of air. They are associated EPHV8879B Accumulator B test line with the SI accumulators. The SI EPHV8879C Accumulator C test line accumulators are not used for PFSSD. The valves are not PFSSD components and their position has no impact on safe shutdown.

EPHV8879D Accumulator D test line EPPV0001 Steam generator nitrogen purge This is a control valve that fails closed on loss regulator of air. This valve was used to purge the Steam Generators with Nitrogen during plant shutdowns. The PIC for this valve is now valved out of service and a manual valve is used to control the Nitrogen flow. The position of this valve has no impact on safe shutdown.

GTHY0005 Containment purge supply The dampers are associated with the containment purge system. The dampers are GTHY0007 Containment purge supply normally closed and fail closed on loss of air.

GTHY0008 Containment purge exhaust The position of these dampers has no impact on safe shutdown.

GTHY001 I Mini purge exhaust HBHV7126 RCDT vent These seven components are associated with the reactor coolant drain tank. Some of the HBHV7127 RCDT outlet valves fail open and some fail closed on loss HBHV7143 RCDT recirculation of air. Loss of air to the controller causes

Post-Fire Safe Shutdown Operator Manual Actions Page 17 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Component Description Consequence Review*

HBHV7144 RCDT recirculation valve HBLCV1 003 to fail closed. However, the RCDT and associated valves are not HBHV7176 RCDT discharge PFSSD components. The position of these HBLCV1 003 RCDT level control valves has no impact on safe shutdown.

HBLY1003A RCDT level controller LFLVO097 Containment cooler A drain These valves are normally closed and fail open on loss of air. The valves allow normal LFLVO098 Containment cooler B drain drainage from the containment coolers to drain LFLVO099 Containment cooler C drain to the containment normal sumps. They fail open on loss of air to assure that the LFLVO100 Containment cooler D drain containment coolers will function properly in an accident case. The containment coolers and drain valves are not PFSSD components and the position of these valves has no impact on safe shutdown.

LFLVO122 Refueling pool standpipe drain to Valve is a normally closed and fails closed on containment sump loss of air. It is associated with the refueling pool leak detection system. The refueling pool leak detection system is not a PFSSD system.

The position of this valve has no impact on safe shutdown.

5.1.3.2 Manipulate Local Controller ABFHCO002 Steam generator atmospheric relief valve (ARV) ABPV0002 can be controlled/isolated by manipulation of ABFHCO002.

The local controller is not associated with any other component; so there is no adverse consequence to PFSSD capability.

5.1.3.3 Manipulate Local Controller ABFHCO003 Steam generator ARV ABPV0003 can be controlled/isolated by manipulation of ABFHCO003. The local controller is not associated with any other component; so there is no adverse consequence to PFSSD capability.

5.1.3.4 Isolate ARV ABPV0004 Steam generator ARV ABPV0004 can be isolated by closing air supply valve KAV1429 and nitrogen supply valve KAV1 365, and then bleeding air from the regulator. The manipulated equipment is not associated with any other component; so there is no adverse consequence to PFSSD capability.

Post-Fire Safe Shutdown Operator Manual Actions Page 18 of 148 WIP-E-1F9900-004-A-1, Rev. I 5.1.3.5 Open Breaker NB00203 Breaker NB00203 is opened to terminate the spurious operation of Train B containment spray. Breaker NB00203 is associated only with containment spray pump B. There are no other components that can be affected by manually opening the breaker. Therefore, there is no adverse consequence to PFSSD capability.

5.1.3.6 Open Breaker NBOO102 Breaker NB00102 is opened to terminate the spurious operation of Train A containment spray. Breaker NBOO102 is associated only with containment spray pump A. There are no other components that can be affected by manually opening the breaker. Therefore, there is no adverse consequence to PFSSD capability.

5.1.4 Feasibility Analysis of Time Available to Perform Operator Manual Action

1. An event timeline, similar to Figure 5.1.4-1, was developed for each fire area necessitating OMA implementation. The event timeline starts at fire initiation. This is more conservative than NUREG-1 852 guidance, which starts the event timeline at fire indicated. The fire induced spurious equipment operation is also postulated to occur at fire initiation. This is conservative, as the cable type utilized (IEEE-383) will not present an immediate failure mode when exposed to fire. Elements of the timeline include:

Fire Initiation - Reference Section 4.8 for definition.

Fire Indicated - Reference Section 4.7 for definition. As discussed in Section 5.1.14, OFN KC-016 Fire Response, is entered once the fire condition is confirmed, which is accomplished by one of the following:

a. Fire reported by personnel.

b. Fire alarm verified by inspection.

c. Multiple fire alarms for the same area are received at fire alarm control panel (FACP) KC-008, located in the Control Room.

Diagnosis Time - Reference Section 4.5 for definition. Diagnosis time will start following fire indication.

OMA Implementation Time - Reference Section 4.13 for definition.

OMA Uncertainty Time - Reference Section 4.14 for definition.

Post-Fire Safe Shutdown Operator Manual Actions Page 19 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Available Time - Reference Section 4.2 for definition.

Time Margin - Reference Section 4.20 for definition.

2. The timeline results are reviewed to determine if adequate time is available to ensure feasibility of the OMA. The OMA is considered feasible, from a timing perspective, ifthe OMA implementation time (excluding the OMA uncertainty time) for at least one demonstration does not exceed the available time for performing the OMA.

3. The timeline results are reviewed to determine if adequate time margin is available to ensure reliability of the OMA. The OMA is considered reliable, from a timing perspective, if the OMA time plus the OMA uncertainty time does not exceed the available time for OMA implementation.

Operator Manual Action Timeline (Minutes)

Fire Initiated

-, Fire Indicated

[Diagnosis Time OMATime OW uncertainty 1012 2 4 6 3 32 68 14 16 18 20 "2 2 2 4 26 28 4 36 38 4 0 42 44 46 48 50 5254565860 Time Margin Available Time Figure 5.1.4-1, Sample OMA Timeline 5.1.5 Reliability Analysis of Time Available to Perform Manual Actions This criterion addresses uncertainties to ensure that the OMA can be dependably and repeatedly performed within the available time. An OMA is considered reliable provided that a Time Margin remains when considering Fire Indicated Time, Diagnosis Time, OMA Implementation Time and OMA Uncertainty Time, within the OMA event timeline. The following uncertainty times were included, as applicable, in effort to address OMA reliability:

Post-Fire Safe Shutdown Operator Manual Actions Page 20 of 148 WIP-E-1F9900-004-A-1, Rev. I

1. For implementation of each OMA a delay of one (1) minute is included for the OMA action to be understood and repeated back to the Control Room. This delay is invoked in recognition that a limited delay will be present regarding the three-way communication method that will be utilized when the Control Room directs implementation of the OMA. Additional uncertainty time is added for implementation of multiple OMAs.

2. A time delay of three (3) minutes is included, where applicable, to account for cumulative delay through electronically controlled doors that could require key access in the event power is lost to the door. This is a reasonable timeframe for the operator to assess that key access is necessary, in order to obtain ingress beyond affected electronically controlled doors.

3. A time delay of two (2) minutes is included for obtaining necessary access and dosimetry when entering the radiological controlled area (RCA). This time delay is based on the typical processing time to log into and gain access into the RCA. It is recognized that during an emergency, such as fire response, conventional RCA entry may be waived provided a RDD is obtained. However, for conservatism, a time delay has been included within this analysis, which accounts for conventional RCA entry.

4. A time delay of three (3) minutes is included for human centered uncertainties such as size, physical strength, and cognitive difference.

5.1.6 Environmental Factors The expected environmental conditions for the OMA location and associated egress routes were reviewed for acceptability. Environmental factors considered were radiation, lighting, temperature, humidity, smoke, toxic gas, noise, and Halon fire suppression discharge. The following is the smoke propagation impact review for OMAs.

5.1.6.1 Smoke Propagation Review A single fire originating within a plant fire area will be contained within the fire area of origin until extinguished. This is the case due to the fire rated barrier construction and associated closure assemblies (fire doors, fire dampers, seismic gap seals, and penetration seals) provided for the fire area boundary. All OMAs are performed outside the fire area of origin and the affected fire area does not have to be traversed in order to perform mitigating manual actions.

Therefore, fire propagation does not present an impediment to the performance of OMAs. However, smoke migration beyond the fire boundary could potentially occur as a result of the following:

Post-Fire Safe Shutdown Operator Manual Actions Page 21 of 148 WIP-E-1F9900-004-A-1, Rev. 1

" Smoke migration through HVAC ductwork or transfer grille prior to activation of the fusible link operated fire damper within the fire barrier opening created by the ductwork.

• Smoke migration resulting from the momentary opening of a fire door within the boundary of the affected fire area to support fire-fighting activities.

Smoke migration via ventilation ductwork or a transfer grille only presents a potential concern during the incipient stage of fire development. Once the 165 0 F activation temperature of the fusible link is attained, the fire damper will close. This action will substantially reduce ventilation related smoke migration beyond the fire boundary, effectively eliminating it as a smoke propagation concern. For fire dampers within ductwork, initial smoke migration would be limited to that entering ventilation diffusers, with the overall internal duct volume presenting an initial repository for the smoke and hot gases. Transfer grilles are open entirely to the fire environment, which presents a more ready means to spread smoke to an adjacent fire area during incipient stage fire development.

In an effort to limit smoke migration via ventilation systems, AP 10-106, Fire Preplans, identifies the HVAC equipment serving each fire area and the respective controls to shutdown each unit. This information provides the necessary guidelines to minimize smoke migration via ventilation equipment during a fire event. Prior to shutdown of the fan, smoke would be drawn into the return ductwork of the respective fan unit. The smoke would then be carried through the ductwork, through the filters and either be exhausted to the outside or re-circulated back into the areas served via the supply ductwork.

After a period of time, the filters could become clogged, causing the fan unit to shut down due to low airflow or high dP across the filters, at which time smoke migration through the ductwork would be limited to natural buoyancy of the heated smoke and gases.

Regarding smoke migration via a fire damper protected transfer grille, Table 5.1.6.1-1 identifies the fire areas containing a transfer grille that also require a potential OMA within the same building if the subject fire area is involved in a fire event. OMAs occurring outside the building of fire origin are not a concern as no transfer grilles are present between power block buildings. Table 5.1.6.1-1 reveals that no transfer grilles directly communicate with an affected fire area and the location of an OMA. Additionally, the travel path necessary to perform the OMA is not subjected to a transfer grille within the affected fire area boundary. Therefore, initial smoke propagation through transfer grilles prior to fire damper activation, will not impede the performance of OMAs.

Post-Fire Safe Shutdown Operator Manual Actions Page 22 of 148 WIP-E-lF9900-004-A-1, Rev. 1 Table 5.1.6.1-1, Fire Locations with Transfer Grilles and OMAs Fire Room Where Location Fire Area Where om OMAWhere Discussion (Fire Ventilation Transfer Grille Review OMA Implemented Implemented Area)

A-1 Fire area A-1 contains the following A-25 1322 Note 1 transfer grilles, identified by fire damper and communicating fire area:

GLD040 -- RW-1 GLD059, GLD060, GLD061 -- A-4 GLD062, GLD063, GLD064 -- A-2 GLD167 - A-7 GLD095 -* A-3 A-16 Fire area A-16 contains the following A-23 1508 Note 1 transfer grilles, identified by fire damper 1509 and communicating fire area:

GLD020 - A-18 GLD027 - A-17 GLD170 -- A-3 GLD194, GLD195 -> A-28 GLD0407 -4 A-26 GLD0411 - A-34 A-18 Fire area A-18 contains the following A-25 1322 Note 2 transfer grille, identified by fire damper and communicating fire area:

GLD020 -- A-16 Notes:

1. Access to room or rooms where manual action is to be performed does not require the operator to traverse through any identified fire areas that communicate via a fusible link, fire damper protected transfer grille.

2. Transfer grill is provided with a volume control damper that closes prior to Halon release in fire area A-18. A fusible link operated fire damper is also provided for the ventilation opening.

The potential to spread smoke and hot gases as a result of fire fighting efforts only presents a concern if egress to the manual action area is potentially impeded or the area where the manual action occurs is directly subjected to smoke migration via the periodic opening of an access doorway for entry into the affected fire area. A review of OMAs require to achieve and maintain hot standby identified two areas where fire-fighting activities could potentially expose the OMA operator to the fire environment as a result of opening an access door to fight the fire. These areas are identified in Table 5.1.6.1-2.

Post-Fire Safe Shutdown Operator Manual Actions Page 23 of 148 WIP-E-1F9900-004-A-1, Rev. I Fire Area A-27 is the MG Set Room on the 2026' Elevation of the Auxiliary Building. This fire area is protected by a total flooding Halon system. It is accessible for fire fighting from the south end through door 14031. This door communicates with fire area A-16. As identified in Table 5.1.6-2, Fire Area A-16 is the location where OMA action may be required in response to an A-27 fire. The manual action at valves EGHV0016 and EGHV0054 are located more than 40 ft from door 14031. This will be the closest point that the operator will be from door 14031, as access to A-16 is remotely located at either the southeast or northeast ends of the building via enclosed stairwells. The ceiling height within A-16 varies from 19'-10" to 20'-6" with a corresponding'fire area size of approximately 7,900 ft2. This substantial room volume coupled with the separation distance between the communicating door and valves to be manipulated provides reasonable assurance that the periodic fire fighting entry through door 14031 will not present a smoke migration severity that would impede the performance of the OMAs in A-16.

Fire Area C-30 is a cable chase located on the 2047' elevation of the Control Building. The cable chase has no ventilation openings. However, the access door for the chase opens to the Control Room Cabinet area (south of general Control Room area). The OMA operator could potentially be exposed to the fire fighting efforts for the cable chase, since the initial operator response is to physically report to the Control Room for direction.

Considering the sensitivity of the cable chase location within the Control Room area, the fire brigade will be cautious to limit smoke propagation beyond the C-30 cable chase, and the duration for opening the cable chase door will be limited due to the small footprint (12' x 12') of the chase. Based on this, the OMA operator and overall OMA implementation will not be adversely affected by the fire fighting efforts for Fire Area C-30.

Table 5.1.6.1-2, Locations where OMA Operator Potentially Subiected to Fire Fighting Efforts Fire Location Fire Area Where OMA Room OMA Performed (Fire Area) Performed A-27 A-16 1402 C-30 C-27 3601 5.1.7 Equipment Functionality and Accessibility Equipment credited for implementation of OMA was reviewed to ensure it is accessible, available, and not damaged by the affects of the fire.

Post-Fire Safe Shutdown Operator Manual Actions Page 24 of 148 WIP-E-1F9900-004-A-1, Rev. 1 5.1.8 Available Indications Availability of relevant diagnostic indications was reviewed to ensure operators would be able to:

• Detect and diagnose fire location.

• Assess the need to perform OMA.

• Direct personnel performing OMA.

• Provide feedback to the operators, if not directly observable, to verify that the OMA has provided the expected result and the manipulated equipment will remain in the desired position.

5.1.9 Communications Communication equipment was reviewed, to ensure an acceptable communication method is available to the extent it is needed.

The two primary communication systems available for use are the plant public address system (Gaitronics) and the 900 MHz radio system. The following is a review of Gaitronics and radio availability in the event of a fire outside the Control Room.

5.1.9.1 Gaitronics The main Gaitronics panel (QF076) is located in the Control Room back panel area. The Gaitronics system is powered from two separate and independent 120/208 VAC sources.

The normal source is from PN0703 in Fire Area C-16. Cable routing from PN0703 to QF076 is through Fire Areas C-16, C-18, C-24, C-21 and C-27. The emergency source of power is from PN0803 in fire area C-15. Cable routing from PN0803 to QF076 is through fire areas C-15, C-17, C-23, C-30, C-33, C-22 and C-27. Therefore, except for Fire Area C-27, a fire in any area will not affect both sources of 120 VAC power to the Gaitronics system.

The Gaitronics system utilizes 16-conductor cables to distribute 120 VAC power and communication signals to the field devices. A hot short across conductors within this cable could create noise in the system and/or damage multiple components (amplifiers, power supplies, etc), which will prevent operation of the system. Cables associated with the Gaitronics system are run in conduit, which will provide some protection against the effects of a fire. It is reasonable to conclude that a fire will be detected and fire brigade callout will occur prior to the Gaitronics system becoming damaged. After that, Gaitronics functionality may be adversely affected.

Post-Fire Safe Shutdown Operator Manual Actions Page 25 of 148 WIP-E-1F9900-004-A-1, Rev. 1 5.1.9.2 Radio The 900 MHz radio system main panel (QF362) is located in the Communication Corridor, elevation 2061-6. Power for panel QF362 is from batteries located adjacent to the Radio Equipment Room in Fire Area CC-I. The batteries are charged from the QA lighting system and have sufficient capacity to operate the radio system during the fire. A fire induced short anywhere along the coaxial communication cable, used for the antenna system, will disable the entire 900 MHz radio system. Table 5.1.9.2-1 identifies the fire areas where the coaxial cable is routed.

Table 5.1.9.2-1, 900 MHz Radio System Cable Routing Auxiliary Building Control Building Other A-1 C-1 CC-1 A-6 C-2 Reactor Building A-8 C-3 RW-1 A-16 C-7 Fuel Building A-18 C-8 A-27 C-11 A-33 C-12 C-15 C-16 C-1 7 C-18 1 C-23 The on shift operator responsible for OFN KC-01 6 OMAs is trained to respond to the Control Room for instruction when a fire brigade callout announcement is made for a fire event.

This approach allows the Control Room operators to provide initial face-to-face direction to the operator responsible for implementing OFN KC-016 OMAs. For the majority of the plant OMAs, this is the only communication that will be required to successfully implement the OMAs. A copy of OFN KC-016 will also be available within the Control Room for OMA operator use, this will aid in ensuring that the operator manipulates the proper plant equipment.

The on shift operator responsible for OFN KC-016 OMAs is required to carry a radio on their person in effort to improve communication diversity.

5.1.10 Portable Equipment The portable equipment needed to successfully implement the OMA was identified and reviewed for availability and dedication to PFSSD, where appropriate.

Post-Fire Safe Shutdown Operator Manual Actions Page 26 of 148 WIP-E-1F9900-004-A-1, Rev. 1 In addition to the radio discussed above, the on shift operator responsible for OFN KC-016 OMAs is required to carry on their person the following portable equipment:

" Hand tool for cutting wire tab type locking devices on components that potentially would be required to be manipulated.

• Master key to unlock electronic card reader controlled doors, in the event electronic door function is affected by the fire.

• Flashlight to aid access/egress in the event normal lighting is affected by the fire.

" Key for ABFHCO002 and ABFHCO003 enclosure housings.

5.1.11 Personnel Protective Equipment (PPE)

The personnel protective equipment required to support the performance of the OMA is identified and assessed for availability. Hard hat, safety glasses, hearing protection, and gloves are not included in this review since this is the standard PPE complement, imposed by the WCNOC Safety Manual, for entry into industrial portions of the plant.

5.1.12 Procedures and Training Each OMA was reviewed to ensure it is included within OFN KC-016, Fire Response. This procedure contains the actions potentially necessary to ensure availability of a PFSSD success path following a single fire event outside the Control Room. The Operations department owns this procedure. Training for the procedure is on a biennial cycle. The procedure is also exercised during fire brigade drill activities that involve postulated fires affecting PFSSD success path. The procedure identifies the following information, per fire area with a potential OMA, to ensure Control Room personnel are aware of the potential fire impact on safe shutdown.

" Equipment susceptible to fire induced spurious operation that could affect PFSSD success path.

" OMAs that are required to achieve PFSSD hot standby.

" OMA to mitigate spurious equipment operation.

• Available diagnostic instrumentation to aid in determining the need to perform OMA.

Post-Fire Safe Shutdown Operator Manual Actions Page 27 of 148 WIP-E-1F9900-004-A-1, Rev. 1 5.1.13 Staffing The manpower requirements for OMA implementation are identified and reviewed against Operations staffing level, taking into account the NUREG-1852 guidance that Control Room or fire brigade personnel should not perform OMAs. This review is performed to ensure that an adequate number of qualified personnel will be available so that hot standby conditions can be achieved and maintained in the event of a fire.

One Operations individual is assigned OFN KC-016 OMA responsibility prior to taking the shift watch. This assignment is documented on the Shift Managers Relief Checklist (APF 21-001-01). This position assignment has no Control Room, Fire Brigade, Security, or Emergency Planning responsibility.

5.1.14 Demonstration

1. As previously identified, OMAs are identified within procedure OFN KC-016. The procedure is entered when a fire outside the Control Room is confirmed, as discussed in Section 5.1.4.

The Control Room Supervisor is responsible for directing OFN KC-016 actions. The procedure is configured such that another Control Room operator can assist in the review of the applicable procedure attachment for potential OMAs. The procedure directs OMA review immediately following fire brigade callout and the request for off-site fire department assistance, which are the initial actions following fire confirmation. The strategic approach to include the OMA review as soon as practical within the fire response procedure ensures that Control Room personnel are promptly made aware of potential OMAs, including the instrumentation that can be relied upon to assess the need for performing the OMA. The OMA review is a continuous action step within OFN KC-016, which means that the operator is responsible for observing the step for potential response throughout the fire event. Based on procedure structure and observed Control Room operator performance during fire brigade drill activities, it is conservatively concluded that Control Room personnel will consistently diagnose the need to perform a reactive OMA within seven (7) minutes of a confirmed fire alarm condition.

2. The seven (7) minute Control Room diagnosis allowance bounds the OFN KC-016 OMA operator initial response to the fire event.

As previously discussed in Section 5.1.9.2, the operator assigned OFN KC-016 OMA duty is trained to promptly respond to the Control Room following fire brigade callout. The OFN KC-016 OMA operator effectively has the seven (7) minute Control Room diagnosis time in which to physically respond to the Control Room.

This provides adequate time margin for the OFN KC-016 OMA operator to report to the Control Room from within power block structures.

Post-Fire Safe Shutdown Operator Manual Actions Page 28 of 148 WIP-E-1F9900-004-A-1, Rev. 1

3. The OMA response outside the Control Room was reviewed to determine that it could be successfully performed (to the extent practical) within the time constraints of this analysis. Multiple operations personnel were timed in the simulated performance of the OMA. The starting point for the timing evolution was the Work Control Center (Room 3613), which is adjacent to the Control Room on the 2047' elevation of the Communications Corridor.

Where multiple OMAs were involved for a particular fire area, the timing for each OMA was initiated from Room 3613. This approach was utilized in effort to conservatively account for each OMA response originating from the Control Room in the event that the fire affects radio and Gaitronics communication capability.

The following timing limitations were applied generically when conducting OMA demonstration timing:

a. A time delay of two (2) minutes is included where electrical safety personnel protective equipment is required to be donned prior to performing the OMA. This time constraint is consistent with electrical safety dress-out times that have been demonstrated for OFN RP-017.

b. For fire areas with multiple OMAs where both Gaitronics and radio communication capability could be affected by the fire, a return trip to the Control Room is assumed to be necessary following the implementation of individual OMAs. This action is necessary in order for the operator to receive direction regarding additional required OMA response activities. A five (5) minute duration is applied for return trips to the Control Room from the Auxiliary Building and three (3) minutes for Control and Turbine Building.

These times were based on walk down time efforts from the most remote components requiring OMA implementation. A return trip following implementation of the final OMA was not postulated within the OMA timeline as available Control Room indication will reflect OMA implementation.

4. Limitations (environmental, personnel protective equipment, tools, etc.) identified as applicable to the performance of the OMA were incorporated, to the extent practical, when conducting the OMA timed demonstration walkdowns.

5.1.15 Defense-In-Depth Analysis The concept of defense-in-depth, described in 10 CFR 50, Appendix R, is applied to fire protection in areas important to safety, with the following three objectives:

Post-Fire Safe Shutdown Operator Manual Actions Page 29 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 29 of 148 WIP-E-1F9900-004-A-1, Rev. 1

1. Prevent fires from starting.

a. One element of fire prevention is maintained through the design control process. The design change process invoked by AP 05-002, Dispositions and Change Packages,ensures that Fire Protection is involved with design changes that affect fire protection program items, including but not limited to, fire hazards analysis, PFSSD analysis, and combustible loading analysis. This review ensures that plant changes satisfy the fire protection program license basis.

b. With limited exception (example: cords and computer cable)

Wolf Creek utilizes IEEE-383 rated thermoset cable within safety related areas in effort to reduce the potential for fire ignition and propagation.

Appendix F, Attachment 5 of NRC Inspection Manual 0609, Significance DeterminationProcess,states the following regarding the plausibility of self-ignited cable fires:

"Self-ignited cable fires are consideredplausible only for thermoplastic or non-qualified thermoset cables. Self-ignited cable fires will be assumed to be implausible for Thermoset cables ratedas low flame spread per the IEEE-383 standard.

If self-ignited cable fires are not plausible, they will not be consideredin the Fire Protection SDP analysis (no self-ignited cable fire scenarios need to be developed)."

This approach is consistent with Electric Power Research Institute (EPRI) technical report TR-100370, Fire-Induced Vulnerability Evaluation (FIVE), which identifies that IEEE-383 rated cable is not typically considered a fire source initiator due to a low ignition frequency, considering past nuclear power plant experience and fire tests.

Considering the above discussion self-ignited cable fires involving IEEE-383 rated cable are not considered credible.

Due to the limited heat release rate associated with the failure of normal lighting fixtures, emergency lighting units, and public address equipment, these components are not considered a significant ignition source that would promote fire propagation.

This approach is supported by the fact that Appendix F of NRC Inspection Manual 0609 does not identify normal lighting or communication equipment as ignition sources to be tabulated.

Additionally, the inspection manual specifically excludes the tabulation of emergency lighting unit batteries as an ignition source.

Post-Fire Safe Shutdown Operator Manual Actions Page 30 of 148 WIP-E-1F9900-004-A-1, Rev. 1

c. Daily fire prevention is controlled though the implementation of administrative procedures.

Hot work activity is controlled by AP 10-101, Control of Transient Ignition Sources. This procedure requires the application of a qualified, dedicated fire watch when performing hot work activities within 35 ft. of a safety related area. Historically, Wolf Creek has not experienced an unreasonable amount of hot work fire events, and those that have occurred have been rapidly detected and extinguished in the incipient stage. Considering Wolf Creek's historical performance regarding the ability to prevent hot work fire events of magnitude, it is reasonable to conclude that the likelihood of a hot work induced fire event warranting OMA implementation is extremely low.

Transient combustible control is implemented by AP 10-102, Control of Combustible Materials,with transient combustible material allowances that are commensurate with PFSSD vulnerability. Areas credited with 20 ft. horizontal separation per 10 CFR 50 Appendix R, Section III.G.2.b, do not allow any unattended combustible material quantities without a review by Fire Protection. The transient combustible loading allowance for remaining plant areas are included within the Station's combustible loading calculation (XX-E-004) in effort to ensure the fire hazard categorization remains consistent with that considered in the Fire Hazard Analysis (E-1 F9905).

d. In areas were a Zone of Influence review is completed as an element of the defense in depth review, NRC Inspection Manual 0609 Appendix F is utilized as guidance to assess if the target cable requiring OMA implementation is within the ignition source Zone of Influence. Target cable that is beyond the Zone of Influence is postulated to be unaffected by fire involved failure of the ignition source. If the target cable is within the Zone of Influence, additional discussion is provided regarding acceptability of the configuration. This approach provides additional defense in depth review, as it identifies if the target cable is postulated to be affected by a credible fire originating from ignition sources in proximity to the target.

2. Detect rapidly, control, and extinguish promptly those fires that do occur; and,

a. Reliable, active fire detection and suppression systems, described in M-10KC and depicted on plant drawings, are provided, as required by the Fire Hazard Analysis. Active fire protection features (fire pumps, firewater distribution, automatic detection, sprinkler, and Halon) were installed predominantly per the National Fire Protection Association (NFPA) code of record delineated in the USAR. The NRC accepted the original installation of these systems as described in the Wolf Creek SER. Code deficiencies are evaluated for acceptability. No NFPA code compliance item

Post-Fire Safe Shutdown Operator Manual Actions Page 31 of 148 WIP-E-1F9900-004-A-1, Rev. 1 presents an adverse impact to OMA diagnosis or implementation. Fire protection systems are periodically tested in accordance with the frequency requirements specified in AP 10-100, Fire ProtectionProgram. Identified deficiencies are assessed for the need to invoke compensatory measure in accordance with AP 10-103, Fire Protection Impairment Control. Deficiencies are entered into the corrective action process for resolution.

b. Portable fire extinguishers and fire hose stations are provided throughout the plant for manual fire fighting efforts. They were installed predominantly per the NFPA code of record. Code deficiencies are evaluated for acceptability. No NFPA code compliance item presents an adverse impact to OMA diagnosis or implementation.

c. A qualified minimum five-member fire brigade is available to investigate and respond to fire events in a prompt and efficient manner. An initial and periodic continuing training program is applied to ensure fire brigade proficiency, which has historically been acceptable, as demonstrated by successful annual audits conducted by loss control representatives from the Station's insurer, Nuclear Electric Insurance Limited (NEIL).

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

a. Passive fire barrier features (walls, floors/ceilings, fire dampers, doors, penetration seals, fire wrap, and structural steel fireproofing) separating redundant PFSSD components were predominantly installed in accordance with industry standards and fire tested assemblies. Fire barrier configurations that are unique or are not directly bounded by fire testing are evaluated for acceptability in M-663-00017A.

No unique/unbounded fire barrier feature presents an adverse impact to OMA diagnosis or implementation. Passive fire barrier features are periodically tested/inspected (as applicable) in accordance with the frequency requirements specified in AP 10-100, Fire Protection Program. Identified deficiencies are assessed for the need to invoke compensatory measures in accordance with AP 10-104, Breach Authorization. Deficiencies are entered into the corrective action process for resolution.

Post-Fire Safe Shutdown Operator Manual Actions Page 32 of 148 WIP-E-1F9900-004-A-1, Rev. 1

b. E-1F9910 documents the PFSSD analysis for plant fire areas.

The majority of the fire areas directly comply with the requirements of 10 CFR 50 Appendix R, Section III.G.1 or Section III.G.2. Where the physical separation requirements of Section III.G.1 or Section III.G.2 are not satisfied, this defense in depth objective is not directly satisfied. The identified feasible and reliable OMAs are credited as the mitigating element for this deficiency.

These fire protection defense-in-depth objectives are assessed for each fire area where an OMA is credited for PFSSD. A justification basis is provided regarding the acceptability of the defense in depth approach considering that the PFSSD objective is not directly satisfied by physical separation requirements of 10 CFR 50 Appendix R, Section III.G.1 or Section III.G.2.

5.1.16 Conclusion Considering the cumulative results of the OMA review, a conclusion statement is provided regarding the overall feasibility and reliability of the OMA.

Post-Fire Safe Shutdown Operator Manual Actions Page 33 of 148 WIP-E-1F9900-004-A-1, Rev. 1 6.0 E-1F9900 Revision Guidance 6.1 E-1F9900 is part of the Approved Fire Protection Program, as it is incorporated by reference within Updated Safety Analysis Report (USAR). NRC review and approval was obtained for WIP-E-1F9900-004-A-1. Subsequent changes to E-1F9900 require prior NRC approval if any one of the following criteria is met:

6.1.1 A Required for Hot Standby OMA is being added.

6.1.2 The Time Margin for a Required for Hot Standby OMA is reduced by more than 10%.

6.2 Important to Safe Shutdown OMA additions or revisions do not require prior NRC approval provided analysis demonstrates that the OMA is feasible and reliable, considering NUREG-1852 guidance.

7.0 References 7.1 NRC Generic Letter 86-10, Implementation of Fire Protection Requirements, dated April 24, 1986 7.2 10 CFR 50 Appendix R, Fire Protection Program For Nuclear Power Facilities Operating Prior To January 1, 1979 7.3 NRC Inspection Manual 0609, Appendix F, Fire Protection Significant Determination Process, dated 02/28/05.

7.4 NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities, published 09/2005 7.5 NUREG-1805, Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods for the U.S. Nuclear Regulatory Commission Fire Protection Inspection Program, published 12/2004 7.6 NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications 7.7 NUREG-1852, Demonstration of the Feasibility and Reliability of Operator Manual Actions in Response to Fire, Published October 2007 7.8 Regulatory Guide 1.189, Fire Protection For Operating Nuclear Power Plants, March 2007 7.9 Federal Register Notice / Vol. 71, No. 43 / March 6, 2006, Fire Protection Program-Post-Fire Operator Manual Actions 7.10 Wolf Creek Letter WM 06-0013, from Richard Muench,

Subject:

Response to Noncited Violation 2008-08-03 NRC Inspection Report 2005-08, dated April 14, 2006 7.11 NRC Letter EA-06-170 from Dwight Chamberlain,

Subject:

Wolf Creek Generating Station - Revised Violation and Exercise of Enforcement Discretion 05000482/2005008-003 (NRC Inspection Report 05000482/2005008), dated July 25, 2006 [Wolf Creek Correspondence Number 06-00357]

Post-Fire Safe Shutdown Operator Manual Actions Page 34 of 148 WIP-E-1F9900-004-A-1, Rev. 1 7.12 SECY 08-093, Resolution of Issues Related to Fire-Inducted Circuit Failures, dated June 30, 2008 7.13 NRC Letter from Annette L. Vietti-Cook, Secretary to R. W. Borchardt Executive Director for Operations, Staff Requirements - SECY-08-0093 - Resolution Of Issues Related To Fire-Induced Circuit Failures, dated September 3, 2008 7.14 NUREG-0881 SER and SSER through Supplement 5 7.15 Technical Specifications, Wolf Creek Generating Station, Table 1.1-1 (Modes),

Amendment 142 7.16 NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1 7.17 EPRI technical report TR-1 00370, Fire-Induced Vulnerability Evaluation (FIVE),

dated April 1992 7.18 IEEE-383, Standard for Qualifying Class 1E Electric Cables and Field Splices for Nuclear Power Generating Stations 7.19 OFN KC-016, Fire Response Revision 21.

7.20 OFN RP-017, Control Room Evacuation, Revision 29.

7.21 AP 05-002, Dispositions and Change Packages, Revision 8 7.22 AP 10-100, Fire Protection Program, Revision 14 7.23 AP 10-101, Control of Transient Ignition Sources, Revision 12 7.24 AP 10-102, Control of Combustible Materials, Revision 13 7.25 AP 10-103, Fire Protection Impairment Control, Revision 23 7.26 AP 10-104, Breach Authorization, Revision 22 7.27 AP 10-106, Fire Preplans, Revision 7 7.28 AP 21-001, Conduct of Operations, Revision 43 7.29 STS KJ-001A, Integrated D/G And Safeguards Actuation Test - Train A, Revision 36 7.30 WCNOC Electrical Safety Manual, Revision 7 7.31 Wolf Creek Safety Manual, Revision 11 7.32 E-1F9905, Fire Hazard Analysis, Revision 3 7.33 E-1F9910, Post Fire Safe Shutdown Fire Area Analysis, Revision 5 7.34 XX-E-013, Post-Fire Safe Shutdown (PFSSD) Analysis, Revision 1 7.35 XX-X-004, Combustible Fire Loading For Each Room in the Various Fire Areas at WCNOC, Revision 4

Post-Fire Safe Shutdown Operator Manual Actions Page 35 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 35 of 148 WIP-E-1F9900-004-A-1, Rev. 1 7.36 M-1OKC, System Description Fire Protection System (KC & FP), Revision 5 7.37 M-663-00017A, Fire Protection Evaluations For Unique Or Unbounded Fire Barrier Configurations, Revision W03 7.38 Equipment Qualification Summary Document (EQSD)Section IV, Revision 0 7.39 WCNOC-CP-002, Thermal Hydraulic Analysis for Fires Outside Control Room, Revision 0 7.40 SA-08-006, Thermal Hydraulic Analysis [Control Room Fire], Revision 0 7.41 AN-96-062, RETRAN Analysis of Plant Shutdown Capability following a Postulated Fire in Fire Area A-18, Revision 0 7.42 NUREG/CR-6931, Cable Response to Live Fire (CAROLFIRE) Volume 1: Test Descriptions and Analysis of Circuit Response Data, Published April 2008

Post-Fire Safe Shutdown Operator Manual Actions Page 36 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.0 Feasibility and Reliability Review 8.1 Fire Area A-1, Auxiliary Buildinq 1974' General Corridor 8.1.1 Fire Area Features Fire Area A-1 is the general corridor area on the 1974' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection is provided in areas where the PFSSD circuits of concern are routed. A pre-action sprinkler system is located in areas with high concentration of cable trays. The cable tray of concern is routed in the north and east general corridor areas of the fire area. Identified dimensions for the affected corridor areas are based on a rectangular area within the larger footprint of the general corridor.

North Corridor

• Length - (Column line A1-A2) 11 ft. 9 in.

• Width (Column line CA-AK) 54 ft. 6 in.

" Height - 25 ft.

East Corridor

• Length - (Column line A1-A4) 59 ft. 3 in.

• Width - (Column line AK-AH) 36 ft.

" Height- 11 ft. to 25 ft.

Refer to Attachment D for a plan view sketch of the fire area.

8.1.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same cable tray within the fire area. At elevation 1994'-8", tray 5U5J, which is second from the top in a stack of five trays, transitions horizontally from Control Building Cable Chase (Fire Area C-7) at the north west corridor of Fire Area A-i. Tray 5U5J traverses down the north corridor and into the east corridor. Tray 5U5J changes elevation to 1993'-

7" before the letdown cables transition into vertical tray 5U5G, which is routed into Cable Chase (Fire Area A-1 1) on the 2000' elevation. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Post-Fire Safe Shutdown Operator Manual Actions Page 37 of 148 WIP-E-1F9900-004-A-1, Rev. I This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

8.1.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

8.1.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.1.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - An eight (8) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. Smoke detection is provided in areas where the PFSSD circuits of concern are routed. Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.1.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.1.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.

Time Margin - The time margin for OMA performance is one hundred forty one (141) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 38 of 148 WIP-E-1F9900-004-A-1, Rev. I Fire Area A-I, Operator ManualAction Timeline (Minutes)

Fire Initiated Fire Indicated

• Diagnosis Time 0VAim I,OMA Uncertainty 1 0J. ' 20* 30.... ,O.... ...i H i'" H: !:

• .. .;:H  : ; : :;. . :H  ;* '* '. .

10 20 30 0 50 60 70 80 90 100 110 120 130 140 150 160 170 180 Time Margin Available Time Figure 8.1.4-1, Fire Area A-1 OMA Timeline 8.1.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and-OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-1 reveals that a one hundred forty one (141) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.1.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within the general corridor area of the Auxiliary Building 1974' elevation. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area A-I. Access to Fire Area A-25 does not require transition through Fire Area A-1. Fire Area A-1 is within the normal travel path for obtaining access to the Auxiliary Building. However, OFN KC-016 identifies that the exit from the Control Room through CAS Room 3609 and into 2047' of the Auxiliary Building may be utilized since normal access could be affected by the fire event. This is an improved travel path versus A-1 access, as fewer stairwell elevations are required to be traversed. The demonstration timing conducted from the Work Controls Center (3613) effectively bounds travel time utilizing the alternative access means. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers.

Post-Fire Safe Shutdown Operator Manual Actions Page 39 of 148 WIP-E-1F9900-004-A-1, Rev. 1 The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.1.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.1.8 Available Indications Point addressable smoke detection is provided for the fire area. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

" Pressurizer level indicators BBLI0459A and BBLI0460A.

• VCT level indicators BGLI0112 and BGLI0185.

8.1.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire

Post-Fire Safe Shutdown Operator Manual Actions Page 40 of 148 WIP-E-1F9900-004-A-1, Rev. 1 brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.

8.1.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry master key.

8.1.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.1.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.1.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.1.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes

• Delay in obtaining and setting up ladder - 3 minutes 8.1.15 Defense-In-Depth

Post-Fire Safe Shutdown Operator Manual Actions Page 41 of 148 WIP-E-1F9900-004-A-1, Rev. 1

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.

The noteworthy ignition sources in proximity to the raceway containing the letdown cables in Fire Area A-1 are included in the ignition source Zone of Influence review documented in Tables 8.1.15.1-1 and 8.1.15.1-2. This review also includes a postulated transient combustible fire source and corresponding heat release rate consistent with NRC Inspection Manual 0609 Appendix F guidance. The Table 8.1.15.1-2 results reveal that the fixed ignition source and the postulated transient combustible ignition source are not within the Zone of Influence for the cable tray stack containing the target cable. There is reasonable assurance that a credible fire event within the area would not result in fire induced equipment mal-operation warranting OMA implementation.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

Table 8.1.15.1-1, Photos of Ignition Sources and Targets Ignition Source and Target Photo Comments Information I-gnition Source Ignition source is considered to be in an RP211 open area when Description -Auxiliary Relay Panel applying NRC Cabinet Height from Floor - 94" Inspection Manual Horizontal Distance to Target - 4" Target 0609 Appendix F Vertical Distance to Target - 103" guidance.

Distance from North Wall - 42" Distance from West Wall - 29" Target Bottom tray 5J 1 C, at elevation 1990'-

5", in tray stack containing 5U5J

Post-Fire Safe Shutdown Operator Manual Actions Page 42 of 148 WIP-E-1F9900-004-A-1, Rev. I Ignition Source and Target Photo Comments Information I.-

Ignition Source Ignition source is considered to be in an PG19N open area when Description - 480v MCC applying NRC Cabinet Height from Floor - 96" Inspection Manual Horizontal Distance to Target - 93" 0609 Appendix F Vertical Distance to Target - 101" guidance.

Distance from North Wall - 84" Distance from East Wall - 96" Target Bottom tray 5J 1 C, at elevation 1990'-

5", in tray stack containing 5U5J Ignition Source Ignition source is considered near a wall QJ 166A when applying NRC Description - Safety Injection Heat Inspection Manual Trace Panel 0609 Appendix F Cabinet Height from Floor - 95" guidance.

Horizontal Distance to Target - 4" Vertical Distance to Target - 89" Distance from Wall - 43" at cabinet level and 0" at 61" above cabinet Target Bottom tray 5J1C, at elevation 1989'-

4", in tray stack containing 5U5J

.L

Post-Fire Safe Shutdown Operator Manual Actions Page 43 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Ignition Source and Target Photo Comments Information Ignition Source Ignition source is considered near a wall Protective Clothing Bin when applying NRC Cabinet Height - 87" Inspection Manual Horizontal Distance to Target - 40" 0609 Appendix F Vertical Distance to Target - 110" guidance.

Distance from Wall - 0" The storage bins are Target comprised of metal storage racks Bottom tray 5J1C, at elevation 1990'- containing Class A 5", in tray stack containing 5U5J combustible clothing material. There are no ignition sources in proximity to the clothing storage bins.

The bins are sectionalized to prevent the likelihood of fire propagation between the bins.

A 70 kW / 200 kW fire size will be postulated based on the presence of the metal dividers between the bins.

A hydrogen line is located above the storage bins.

Post-Fire Safe Shutdown Operator Manual Actions Page 44 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.1.15.1-2, Zone of Influence Review for Ignition Sources and Targets Ignition Target Expected Target Critical Comments Source HRR Distance (ft) Distance (ft)

High H R H R Confidence HRR RP211 Bottom tray 70 kW 8.6 0.3 3.5 1.3 Based on the vertical separation in stack provided, cable tray 5U5J is not within containing 200 kW 5.3 2.1 the Zone of Influence for RP21 1.

5U5J PG19N Bottom tray 70 kW 8.4 7.8 3.5 1.3 Based on the vertical and radial in stack separation provided, cable tray 5U5J is containing 200 kW 5.3 2.1 not within the Zone of Influence for 5U5J PG19N.

QJ166A Bottom tray 70 kW 7.4 0.3 4.6 1.8 Based on the vertical separation in stack provided, cable tray 5U5J is not within containing 200 kW 7.0 3.0 the Zone of Influence for QJ166A.

5U5J Protective Bottom tray 70 kW 9.2 3.3 4.6 1.8 Based on the vertical and radial clothing bin in stack separation provided, cable tray 5U5J is containing 200 kW 7.0 3.0 not within the Zone of Influence for the 5U5J protective clothing bin. The hydrogen line located above the protective clothing bin is schedule 80 carbon steel per ANSI B31.1. The line, which is provided with welded fittings, is seismically supported.

This pipe segment is not considered an ignition source contributor for the corridor, as it is not connected to any equipment or valves within the area.

Transient Bottom tray 70 kW 15.2 0 3.5 1.3 Based on the vertical separation Combustible fire in stack provided, the cable tray stack containing (open area) containing 200 kW 5.3 2.1 5U5J is not within the Zone of Influence 5U5J for an open area transient combustible fire.

Transient Bottom tray 70 kW 15.2 0 4.6 1.8 Based on the vertical separation Combustible fire in stack provided, the cable tray stack containing (near wall) containing 200 kW 7.0 3.0 5U5J is not within the Zone of Influence 5U5J for a transient combustible fire near a wall.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection is provided for the majority of Fire Area A-i, including the areas where the PFSSD circuits of concern are routed. A pre-action sprinkler system is located in areas with high concentration of cable trays.

Fire alarm annunciation is provided locally, and within the Control Room. Smoke detection is point addressable, allowing for prompt recognition of fire location. The pre-action sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

The administrative fire impairment controls for the area containing the letdown cables of concern require a continuous fire watch when either automatic detection or the pre-action sprinkler system is

Post-Fire Safe Shutdown Operator Manual Actions Page 45 of 148 WIP-E-1F9900-004-A-1, Rev. 1 inoperable. This ensures fire suppression response will occur in the incipient fire stage during conditions when the active fire protection system elements area out of service.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in A-1 does not challenge PFSSD.

This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.1.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-1 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty one (141) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

8.2 Fire Area A-1 1, Auxiliary Building 2000' Cable Chase 8.2.1 Fire Area Features Fire Area A-11 is a single room (1335) cable chase located on the 2000' elevation of the Auxiliary Building within the North Pipe Penetration Room. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.

Approximate cable chase size is as follows:

" Length - 14 ft.

" Width-7ft.

" Height-23 ft. 4 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.2.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial

Post-Fire Safe Shutdown Operator Manual Actions Page 46 of 148 WIP-E-1F9900-004-A-1, Rev. 1 separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same vertical tray (5U5G) within the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

8.2.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

8.2.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.2.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A six (6) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, A-1i1 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to eleven (11) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.2.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.2.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for

Post-Fire Safe Shutdown Operator Manual Actions Page 47 of 148 WIP-E-1F9900-004-A-1, Rev. I one hundred eighty (180) minutes without adverse consequence to reactor performance.

Time Margin - The time margin for OMA performance is one hundred thirty eight (138) minutes.

Fire Area A-11, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated

• - Diagnosis Time OMATime 1  ;OMA Uncertainty 10 20 30 4 1 50. 60 70 80 90 100 110 120 130 140 150 160 170 180 Time Margin Available Time Figure 8.2.4-1, Fire Area A-11 OMA Timeline 8.2.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-11 reveals that a one hundred thirty eight (138) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.2.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 1335 located on the 2000' elevation of the Auxiliary Building, within the North Pipe Penetration Room. The fire will be confined to the Fire Area A-1 1 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Post-Fire Safe Shutdown Operator Manual Actions Page 48 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.2.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.2.8 Available Indications Point addressable smoke detection is provided for Cable Chase 1335.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

• Pressurizer level indicator BBLI0460A.

• VCT level indicators BGLI0112 and BGLI0185.

8.2.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

Post-Fire Safe Shutdown Operator Manual Actions Page 49 of 148 WIP-E-1F9900-004-A-1, Rev. I 8.2.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.2.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.2.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.2.13 Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.2.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes

" Delay in obtaining and setting up ladder - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 50 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.2.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the general area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions Page 51 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 51 of 148 WIP-E-1F9900-004-A-1, Rev. 1

3. Protection of SSCs.so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in A-1 1 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.2.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-1 1 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred thirty eight (138) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

8.3 Fire Area A-16, Auxiliary Building 2026' General Corridor 8.3.1 Fire Area Features Fire Area A-16 is the general corridor area on the 2026' elevation of the Auxiliary Building. It is effectively separated into two areas (A-16N and A-16S) by a 10 CFR 50 Appendix R, Section III.G.2.b, 20' combustible control zone. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection is provided, and a pre-action sprinkler system is located in areas with a high concentration of cable trays. In addition to the ceiling level sprinkler protection, the east corridor, from column line Al to A4, is provided with an intermediate level of sprinkler protection, located below the lowest cable tray in the corridor.

Detection only is provided for 'A' Component Cooling Water (CCW) area, which is open to the east corridor. The raceways of concern are routed in the north and east general corridor areas, and the 'A' CCW area within A-16N. Identified dimensions for the affected areas are based on a rectangular area within the larger footprint of the general corridor.

North Corridor

• Length - (Column line AF-AK) 53 ft.

" Width - (Column line Al- 10' South of A2) 23 ft. 9 in.

0 Height- 20 ft. 6 in.

Post-Fire Safe Shutdown Operator Manual Actions Page 52 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 52 of 148 WIP-E-1F9900-004-A-1, Rev. 1 East Corridor

• Length - (Column line 10' South of A2-A5) 53 ft.

• Width - (Column line AJ-AK) 13 ft.

• Height-20 ft. 6 in.

'A' CCW

• Length-62 ft. 6 in.

• Width - 28 ft.

• Height- 20 ft. 6 in.

Refer to Attachment D for a plan view sketch of the fire area.

The conduits for ABPV0002 are provided with Thermo-Lag fire wrap protection for the entire transition within Fire Area A-16N. The conduits for ABPV0003 are provided with Thermo-Lag fire wrap protection for the entire transition within Fire Area A-16N with the exception of conduit 3J1 B1D located near the north wall/ceiling interface in the 'A' CCW area.

The Thermo-Lag was installed to satisfy IEEE-384 electrical separation requirements. It was installed to the initial design requirements for 1-hour fire rating (including thermal short protection), though the barrier was not credited for 10 CFR 50 Appendix R, Section III.G.2, protection. The Thermo-Lag is currently not credited for Appendix R,Section III.G.2, fire barrier protection as subsequent industry fire testing revealed that additional upgrade (stress skin joint reinforcement, trowel grade build-up and barrier interface protection) would be necessary in order for the barrier assembly to be directly qualified as a 1-hour raceway fire barrier system. Though not directly credited or qualified as a fire barrier assembly, the Thermo-Lag fire wrap does provide substantial protection for the circuits associated with ABPV0002 and ABPV0003. Refer to Photo 8.3.1-1 for a typical Thermo-Lag IEEE-384 Protection configuration.

Post-Fire Safe Shutdown Operator Manual Actions Page 53 of 148 WIP-E-1F9900-004-A-1, Rev. I Photo 8.3.1-1, Typical Thermo-Lag IEEE-384 Protection 8.3.2 Spurious Equipment Operation Requiringq Operator Manual Action In Fire Area A-16N, cables associated with steam generator atmospheric relief valves (ARV) ABPV0002 (steam generator 'B'), ABPV0003 (steam generator 'C'), and ABPV0004 (steam generator 'D') may be damaged, preventing control of theses valves from the Control Room. Additionally, a fire in this area could affect auxiliary feedwater for steam generators 'A' and 'D'. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for ABPV0002, ABPV0003, and ABPV0004 follow the same general routing along the northeast and east corridors. The ARV cables are in multiple raceways. The horizontal separation distance along the northeast corridor from column line AF-AK and the east corridor from column line A2-A5, which envelops all three ARVs, is approximately 5'. Typical vertical separation is approximately 8'-3" between the cable tray for ABPV004 and the conduits for ABPV002 and ABPV003, which are predominantly located at the same elevation. The cables for ABPV0003 (in conduit) exit the east corridor and transition north of column A3 near the north wall and ceiling interface in the 'A' CCW area. The cables for ABPV0002 (in conduit) transition through the 'A' CCW area north of column line A5. The cable tray for ABPV0004 transitions into the ceiling near the intersection of column lines A4-AK.

Fire wrap protection/upgrade is not practical due to the raceway distance and area congestion.

This is an Important to Safe Shutdown spurious equipment operation, as Thermal Hydraulic Analysis WCNOC-CP-002 determined that hot standby conditions could be maintained with no action taken to close three spuriously open ARVs. Additionally, WCNOC-CP-002 determined that, for three spuriously failed closed ARVs, hot standby could be maintained via

Post-Fire Safe Shutdown Operator Manual Actions Page 54 of 148 WIP-E-1F9900-004-A-1, Rev. 1 steam released through the steam generator safety valves. However, use of the safety valves is not the operational preferred method for maintaining post-fire hot standby. Therefore, it was conservatively concluded that a feasibility and reliability analysis would be completed for the A-16 actions addressing fire induced ARV mal-operation. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves multiple steam release paths from the main steam system.

8.3.3 Operator Manual Action Description Steam generator ARV ABPV0002 can be controlled/isolated by manipulation of ABFHCO002. Steam generator ARV ABPV0003 can be controlled/isolated by manipulation of ABFHCO003. These components are located at local control stations in Fire Area A-23 on the 2037'-7" elevation of the Auxiliary Building (Reference Attachment C, Photos C-2 and C-3).

Steam generator ARV ABPV0004 can be isolated by closing air supply valve KAV1 429 and nitrogen supply valve KAV1 365, and then bleeding air from the regulator. The air and nitrogen supply valves and regulator are also located in Fire Area A-23, on the 2037'-7" elevation of the Auxiliary Building (Reference Attachment C, Photos C-4 through C-6).

Based on thermal hydraulic analysis (Reference 7.39 and 7.41), the operator can close ABPV0004 and either ABPV0002 or ABPV0003 and leave either ABPV0002 or ABPV0003 full open. The operator will report back to the Control Room for further instructions. The initial OMA response will be a Reactive Action.

8.3.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.3.4-1 reflects the OMA timeline in response to ARV ABPV0002 ABPV0003, and ABPV0004 mal-operation. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. Area detection is provided for Fire Area A-16.

Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Diagnosis Time - A seven (7) minute diagnosis time is utilized, based on Section 5.1.14.1.

OMA Implementation Time - A cumulative twenty seven (27) minute operator implementation time for performing the three OMAs is utilized, based on the demonstrated OMA walkdown time documented in Section 8.3.14.

Post-Fire Safe Shutdown Operator Manual Actions Page 55 of 148 WIP-E-1F9900-004-A-1, Rev. 1 OMA Uncertainty Time - A twenty six (26) minute OMA uncertainty time is utilized based on Section 8.3.14.

Available Time - Thermal hydraulic analysis AN-96-062 identifies that RHR entry conditions can be achieved in 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br /> after reactor trip if a single steam generator ARV is used and; if a second ARV is placed in service in 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, RHR entry conditions can be achieved in 61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />.

Furthermore, if either ARV ABPV0002 or ABPV0003 is left in the full open position with all remaining ARVs closed, cool down can be controlled from the Control Room by adjusting auxiliary feedwater flow to the associated steam generator with an open ARV. This approach is also supported by thermal hydraulic analysis WCNOC-CP-002, which identifies that three ARVs can remain spuriously open or closed for at least 200 minutes without adverse consequence to reactor performance.

Time Margin - The time margin for OMA performance is one hundred thirty six (136) minutes.

Fire Area A-16, Operator Manual Action Timeline (Minutes)

Fire Initiated 4H Fire Indicated EDagnosis Time OMIA "T, IOMA Uncertainty 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 Time Margin Available Time Figure 8.3.4-1, Fire Area A-16 OMA Timeline 8.3.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-16 reveals that a one hundred thirty six (136) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions Page 56 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.3.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within the general corridor area of the Auxiliary Building 2026' elevation. The location of the OMAs is within the Main Steam Enclosure on the 2037'-7" elevation of the Auxiliary Building (Fire Area A-23). Based on fire barrier separation, the fire will be confined to Fire Area A-16. Access to Fire Area A-23 does not require transition through Fire Area A-16. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths, and the components requiring OMA manipulation. Normal radiation conditions within the areas of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

Temperature and humidity conditions within the Main Steam Enclosure will be elevated in the proximity of a spuriously open ARV. Historically, Operations has successfully isolated an ARV by closing its respective local isolation valve, which requires closer, long-term proximity to the ARV discharge line than the prescribed OMA. This historical success demonstrates that the environment within the Main Steam Enclosure will remain tenable regarding local temperature and humidity exposure during the prescribed OMA implementation. Additionally, the discharge piping in the area where the OMA is performed is insulated, which protects against contact exposure with the hot piping.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.

8.3.7 Equipment Functionality and Accessibility The components requiring manipulation for ARV control/isolation are mechanical. No equipment support functions are required for successful manual action implementation. Each is readily accessible for manipulation. These components are physically separated from the fire event by fire rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control. Key access is also required for the enclosure housing ARV controllers ABFHCO002 and ABFHCO003. The OFN KC-016 OMA operator also carries this key.

Post-Fire Safe Shutdown Operator Manual Actions Page 57 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.3.8 Available Indications Point addressable smoke detection is provided for Fire Area A-16. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

To diagnose the spurious opening of an ARV, valve position indication or appropriate pressure instrumentation needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious opening of an ARV:

• ABPV0002 - Steam Generator 'B' pressure indication on ABPI524A

" ABPV0003 - Steam Generator 'C' pressure indication on ABPI534A

• ABPV0004 - Steam Generator 'D' pressure indication on ABPI544A 8.3.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout.

This approach allows the Control Room operators to provide face-to-face direction for the OMAs. OMA implementation approach provided in OFN KC-016 is based on availability of communication. If the fire affects communication, OFN KC-016 guidance will be followed to close ABPV0002 and open ABPV0003 and then physically report to the Control Room for further direction. The limiting scenario, reflected by the Figure 8.3.4-1 timeline is that the fire affects communication.

8.3.10 Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMAs. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. Wire cutters will be necessary to remove the lock tabs from the components to be manipulated for ARV ABPV0004 isolation. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters. Key access is also required for the enclosures housing ARV controllers ABFHCO002 and ABFHCO003. The OFN KC-016 OMA operator also carries this key.

8.3.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

Post-Fire Safe Shutdown Operator Manual Actions Page 58 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.3.12 Procedures and Training The OMAs are identified in OFN KC-016. Procedure direction is based on availability of communications. If communication is not affected by the fire, the direction for the ARVs, with a protected auxiliary feedwater source, is to close ABPV0002 and throttle open ABPV0003 per Control Room direction. If the fire affects communication, the direction is to close ABPV0002, open ABPV0003, and physically report back to the Control Room for further direction. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.3.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

8.3.14 Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. Each of the three OMAs were conservatively timed as independently originating from Room 3613 in recognition that radio and Gaitronics communication capability could be affected by the fire. The timing effort reflected that each OMA could be implemented in nine (9) minutes, for a cumulative OMA total of twenty-seven (27) minutes.

Once initial ARV control/isolation is established, PFSSD OMA capability is adequately demonstrated. Operations can continue to transition between the Main Steam Enclosure and the Control Room to affect ARV position change throughout the event course, or steam generator feedwater can be throttled from the Control Room to control decay heat removal. Based on the diversity of available decay heat removal options, timing considerations were that each ARV mal-operation would have to be visited once for OMA implementation.

In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twenty-six (26) minutes.

• Communication and feedback with Control Room for OMAs - 3 minutes

• Electronically controlled door key access - 3 minutes

" Obtain RCA access - 2 minutes

• Transition to Control Room from Fire Area A-23 after OMA implementation (three trips at 5 minutes per trip) - 15 minutes

" Human centered uncertainty - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 59 of 148 WI P-E-1 F9900-004-A-1, Rev. 1 8.3.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. A 10 CFR 50 Appendix R, 20' combustible control zone is provided for separation of redundant component cooling water components.

The noteworthy ignition source in proximity to the raceways containing the cables for ABPV002, ABPV003, and ABPV004 are as follows:

" RP266, Auxiliary Relay Panel

• RP331, Reverse Isolation Relay Panel

• XSK01A / XSK01B, Security Panels

" XQA21, Lighting Panel Transformer

• DPEG01C, 'C' CCW Pump Motor

• DPEG01A, 'A' CCW Pump Motor Due to the lower elevation (2036'-3") of tray 4J3C for ABPV0004, it could be involved in ignition source or transient combustible fire exposure. However, The Thermo-Lag protection for ABPV0002 and ABPV0003 provides additional defense in depth protection such that it is reasonable to conclude that a credible area A-16N fire would not result in the combined fire induced mal-operation of ABPV0002, ABPV0003, and ABPV0004 necessitating OMA implementation.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection is provided for the area. A pre-action sprinkler system is located in areas with high concentration of cable trays. In addition to the ceiling level sprinkler protection, the east corridor, from column line Al to A4, is provided with an intermediate level sprinkler protection, located below the lowest cable tray in the corridor. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The pre-action sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

The administrative fire impairment controls for the north and east corridor area require a continuous fire watch when either automatic detection or the pre-action sprinkler system is inoperable. This ensures fire suppression response will occur in the incipient fire

Post-Fire Safe Shutdown Operator Manual Actions Page 60 of 148 WIP-E-1F9900-004-A-1, Rev. 1 stage during conditions when the active fire protection system elements area out of service.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of Section III.G.2 protection to ensure a fire in Fire Area A-16 does not challenge PFSSD. The OMA is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.3.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area A-16 are dependable, reliable, and can be consistently performed within the required Available Time. A one hundred thirty six (136) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Therefore, the OMAs are considered both feasible and reliable. Considering that WCNOC-CP-002 demonstrates that the mal-operation of three ARVs does not require outside Control Room action to achieve and maintain post-fire hot standby, the feasibility and reliability analysis for A-16 provides an added defense in depth approach to ensure post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.

8.4 Fire Area A-18, Auxiliary Building 2026' North Electrical Penetration Room 8.4.1 Fire Area Features Fire Area A-18 is the North Electrical Penetration Room (1410) on the 2026' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Cross-zoned smoke detection is provided, which actuates a total flooding Halon system for the room. A wet pipe sprinkler system is provided for the open cable chase in the northwest corner of the room. The following identified dimensions are based a rectangular area within the irregular shaped footprint of the North Electrical Penetration room.

" Length - 35 ft 6 in. (11 ft South of A2 to A4)

" Width - 23 ft. (AH-AJ)

• Height- 20 ft 6 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.4.2 Spurious Eauipment Operation Reguiring Operator Manual Action

Post-Fire Safe Shutdown Operator Manual Actions Page 61 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same cable tray within the fire area. The letdown cables transition from the partially open cable chase (tray 5U5G) in the northwest corner of the room to horizontal tray 5U3C at elevation 2039-3". Tray 5U3C is third from the top in a stack of four horizontal trays. It transitions from the chase to an electrical penetration in the Reactor Building wall on the east side of the room. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

Atmospheric relief valve (ARV) ABPV0002 could spuriously open as a result of an A-18 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, conservative application of the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown. The cable for ABPV002 is located in conduit 2J1035. It transitions through the north wall of the penetration room at elevation 2039'-9" were the conduit traverses east near the north wall before penetrating the floor in the northeast corner of the room. The minimum separation distance between 2J1035 for (ABPV002) and 5U3C (for BGLCV0459 and BGLCV0460) is approximately 13 ft. with intervening cable tray combustibles between the raceways.

8.4.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Post-Fire Safe Shutdown Operator Manual Actions Page 62 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.4.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.4.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Area smoke detection is provided. Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.4.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.4.14. .

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.

Time Margin - The limiting time margin for OMA performance is fifteen (15) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 63 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Fire Area A-18, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated Diagnosis Time OMATime OMA Uncertainty 2468 10 12 14 16 18 20 22 24 26 28 32 34 36 38 40 42 44 46 48 50 Time Margin Available Time Figure 8.4.4-1, Fire Area A-18 OMA Timeline 8.4.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-18 reveals that a fifteen (15) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.4.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within the North Electrical Penetration Room on the 2026' elevation of the Auxiliary Building. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area A-18. Access to Fire Area A-25 does not require transition through Fire Area A-18. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not

Post-Fire Safe Shutdown Operator Manual Actions Page 64 of 148 WIP-E-1F9900-004-A-1, Rev. I be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.4.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.4.8 Available Indications Point addressable smoke detection is provided for the North Electrical Penetration Room. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

• Pressurizer level indicator BBLI0460A.

" VCT level indicators BGLI0185 and BGLI0112.

8.4.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

The OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.

Post-Fire Safe Shutdown Operator Manual Actions Page 65 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.4.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.4.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.4.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.4.13 Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.4.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

" Human centered uncertainty - 3 minutes

• Delay in obtaining and setting up ladder - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 66 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.4.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.

The noteworthy ignition sources in proximity to the raceway containing the cables for BGLCV0459 and BGLCV0460 are included in the ignition source Zone of Influence review documented in Tables 8.4.15.1-1 and 8.4.15.1-2. This review also includes postulated transient combustible fire sources and corresponding heat release rates consistent with NRC Inspection Manual 0609 Appendix F guidance. The Table 8.4.15.1-2 results reveal that all but one ignition source is outside the Zone of Influence for the expected heat release rate and the majority of the ignition sources are outside the Zone of Influence for the postulated high confidence heat release rate fire. The ignition sources that are within the Zone of Influence are acceptable based on the vertical separation distance between the lower target cable tray (5J3C) and the tray containing the letdown cables of concern (5U3C). Considering the total flooding halenHalon system that is provided for the fire area coupled with the administrative requirement for a continuous fire watch when either detection or haleRHalon suppression is out of service for the area, there is reasonable assurance that a North Electrical Penetration room fire event would be suppressed in the incipient stage, prior to the occurrence of fire induced equipment mal-operation warranting OMA implementation.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

Table 8.4.15.1-1, Photos of Ignition Sources and Targets Ignition Source and Target Photo Comments Information I-gnition Source Ignition source is considered to be in an PG21 open area when Description - 480v Load Center applying NRC Cabinet Height from Floor - 90" Inspection Manual 0609 Horizontal Distance to Target - 10" Appendix F guidance.

Vertical Distance to Target - 18" Distance to West Wall - 123" Target Bottom tray 5J3C, at elevation 2035',

in tray stack containing 5U3C

Post-Fire Safe Shutdown Operator Manual Actions Page 67 of 148 WIP-E-1F9900-004-A-1, Rev. I Ignition Source and Target Photo Comments Information Ignition Source Ignition source is considered near a wall PA03/PA04 when applying NRC Description - Cubicle PT for 'A' RCP Inspection Manual 0609 Motor Appendix F guidance.

Cabinet Height from Floor - 90" Horizontal Distance to Target - 46" Vertical Distance to Target - 18" Distance to West Wall - 20" Tar-et Bottom tray 5J3C, at elevation 2035',

in tray stack containing 5U3C Ignition Source RJ159 ignition source is considered near a wall RJ159 when applying NRt Description - BOP MUX Inspection Manual 0609 Cabinet Height from Floor - 73" Appendix F guidance.

Horizontal Distance to Target - 37" Vertical Distance to Target - 35" Distance to West Wall - 24" NG01B NG01B ignition source Description - 600v MCC is considered nearla Cabinet Height from Floor - 91" wall when applying Horizontal Distance to Target - 104" NRC Inspection Manual Vertical Distance to Target - 17" 0609 Appendix F Distance to North Wall - 36" guidance.

Distance to West Wall - 24" Target Bottom tray 5J3C, at elevation 2035',

in tray stack containing 5U3C I.-

Ignition Source Ignition source is considered to be in an NG01T open area when Description - 480v MCC applying NRC Cabinet Height from Floor - 91" Inspection Manual 0609 Horizontal Distance to Target - 4" Appendix F guidarfce.

Vertical Distance to Target - 71" Distance from North Wall - 36" Target Conduit 2J1035

Post-Fire Safe Shutdown Operator Manual Actions Page 68 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.4.15.1-2, Zone of Influence Review for Ignition Sources and Targets Ignition Target Expected Target Critical Comments Source HRR Distance (ft) Distance (ft)

High H R H R Confidence HRR PG21 Bottom tray 70 kW 1.5 .83 3.5 1.3 Tray 5J3C is within the Zone of in stack Influence. However, the tray of concern containing 200kW 5.3 2.1 (5U3C) associated with letdown 5U3C isolation, is located 45" above tray 5J3C.

Based on this vertical separation, fire propagation to 5U3C, as a secondary target, is not postulated to occur prior to application of automatic and/or manual suppression activities.

PA03/PA04 Bottom tray 70 kW 1.5 3.8 4.6 1.8 Based on the radial separation distance, in stack the cable tray stack containing 5U3C is containing 200kW 7.0 3.0 not within the Zone of Influence for 5U3C PA03/PA04.

RJ159 Bottom tray 70 kW 3.1 2.9 4.6 1.8 Based on the radial separation provided, in stack the cable tray stack containing 5U3C is containing 200kW 7.0 3.0 not within the Zone of Influence for an 5U3C expected 70 kW fire severity. Tray 5J3C is within the Zone of Influence for a high confidence heat release rate (200 kW) fire exposure. However, the tray of concern (5U3C) associated with letdown isolation, is located 45" above tray 5J3C.

Based on this vertical separation, fire propagation to 5U3C, as a secondary target, is not postulated to occur prior to application of automatic and/or manual suppression activities.

NG01 B Bottom tray 70 kW 1.4 8.7 4.6 1.8 Based on the radial separation distance, in stack the cable tray stack containing 5U3C is containing 200kW 7.0 3.0 not within the Zone of Influence for 5U3C NG01B.

NG01T Conduit 70 kW 5.9 0.3 3.5 1.3 Based on the vertical separation 2J1035 provided, conduit 2J1035 is not within 200kW 5.3 2.1 the Zone of Influence for NG01T.

Transient Bottom tray 70 kW 7 0 3.5 1.3 Based on the vertical separation Combustible fire (at El. provided, the cable tray stack containing (open area fire) 2035'-0") in 200 kW 7 0 5.3 2.1 5U3C is not within the Zone of Influence stack for an open area transient combustible containing fire, where tray 5J3C is located at 5U3C elevation 2035'-0".

Transient Bottom tray 70 kW 7 0 4.6 1.8 Based on the vertical separation Combustible fire (at El. provided, the cable tray stack containing (fire near wall) 2035'-0") in 200 kW 7.0 3.0 5U3C is not within the Zone of Influence stack for an expected 70 kW fire severity. I containing Tray 5J3C is equal to the limiting height 5113C Zone of Influence distance for a high confidence (200 kW) fire. This is acceptable as the tray of concern (5U3C) us located 45" above the target tray.

Based on this vertical separation, fire propagation to 5U3C, as a secondary target, is not postulated to occur prior to application of automatic and/or manual suppression activities.

Post-Fire Safe Shutdown Operator Manual Actions Page 69 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Ignition Target Expected Target Critical. Comments Source HRR 'Distance (ft) . Distance (ft)

High H R H R Confidence HRR Transient Bottom tray 70 kW 5.3 0 3.5 1.3 Based on the vertical separation Combustible fire (at El. provided, the cable tray stack containing (open area fire) 2031'-3") in 200 kW 5.3 2.1 5U3C is not within the Zone of Influence stack for an expected 70 kW fire severity. Tray containing 5J3C is equal to the limiting height Zone 5U3C of Influence distance for a high confidence (200 kW) fire. This is acceptable as the tray of concern (5U3C) us located 43" above the target tray.

Based on this vertical separation, fire propagation to 5U3C, as a secondary target, is not postulated to occur prior to application of automatic and/or manual suppression activities.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and a total flooding Halon system are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler protection for the open cable chase and the general area Halon protection will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided adjacent to the area for manual fire fighting.

The administrative fire impairment controls for this fire area require a continuous fire watch when either automatic detection or the Halon suppression system is inoperable. This ensures fire suppression response will occur in the incipient during conditions when the active fire protection system elements area out of service.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections IlI.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in A-18 does not challenge PFSSD.

8.4.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-18 is dependable, reliable, and can be consistently performed within the required Available Time. A fifteen (15) minute time margin remains when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.

Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions Page 70 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 70 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.5 Fire Area C-7, Control Building 1984' Cable Chase 8.5.1 Fire Area Features Fire Area C-7 is a single room (3230) cable chase located on the 1984' elevation of the Control Building. The chase contains cable only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.

Approximate cable chase size is as follows:

" Length- 5 ft. 10 in.

" Width-4 ft.

" Height- 15 ft. 2 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.5.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same raceway within the cable chase. The cables of concern transition within vertical cable tray 5U4A to horizontal cable tray 5U5J at elevation 1994'-8". The horizontal tray, which is second from the top in a stack of five trays, exits the east wall of the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

8.5.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and

Post-Fire Safe Shutdown Operator Manual Actions Page 71 of 148 WIP-E-1F9900-004-A-1, Rev. 1 BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

8.5.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.5.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-7 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.5.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.5.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.

Time Margin - The time margin for OMA performance is one hundred forty three (143) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 72 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Figure 8.5.4-1, Fire Area C-7 OMA Timeline 8.5.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-7 reveals that a one hundred forty three (143) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.5.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3230 located on the 1984' elevation of the Control Building. The OMA is in an adjacent structure within the Auxiliary Building. The fire will be confined to the Fire Area C-7 Cable Chase of origin, which contains no ventilation openings.

The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment. The cable chase door for C-7 opens into the normal travel path for obtaining access to the Auxiliary Building. However, OFN KC-016 identifies that the exit from the Control Room through CAS Room 3609 and into 2047' of the Auxiliary Building may be utilized since normal access could be affected by the fire event. This is an improved travel path versus Auxiliary Building access through Fire Area A-i, as fewer stairwell elevations are required to be traversed. The demonstration

Post-Fire Safe Shutdown Operator Manual Actions Page 73 of 148 WIP-E-1F9900-004-A-1, Rev. 1 timing conducted from the Work Controls Center (3613) effectively bounds travel time utilizing the alternative access means.

Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.5.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.5.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3230.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

" Pressurizer level indicators BBLI0459A and BBLI0460A.

• VCT level indicators BGLI0112 and BGLI0185.

8.5.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to

Post-Fire Safe Shutdown Operator Manual Actions Page 74 of 148 WIP-E-1F9900-004-A-1, Rev. 1 provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.

8.5.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.5.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.5.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.5.13 Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.5.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

• Electronically controlled door key access - 3 minutes

" Obtain RCA access - 2 minutes

" Human centered uncertainty - 3 minutes

• Delay in obtaining and setting up ladder - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 75 of 148 WI P-E-1 F9900-004-A-1, Rev. 1 8.5.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable only. As discussed in Section 5.1.15.1, IEEE-383 cable is not considered a credible ignition source that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-7 does not challenge PFSSD.

This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in

Post-Fire Safe Shutdown Operator Manual Actions Page 76 of 148 WIP-E-1F9900-004-A-1, Rev. 1 depth fire prevention, detection, and suppression measures discussed above.

8.5.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-7 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty three (143) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

8.6 Fire Area C-12, Control Building 2000' North Cable Chase 8.6.1 Fire Area Features Fire Area C-12 is a single room (3306) cable chase located on the 2000' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

" Length- 12 ft.

" Width- 12 ft.

" Height- 15 ft. 2 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.6.2 Spurious Equipment Operation Requirinq Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same raceway within the cable chase. From the floor, the cables of concern transition within vertical cable tray 5U4A through the ceiling of the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-

Post-Fire Safe Shutdown Operator Manual Actions Page 77 of 148 WIP-E-1F9900-004-A-1, Rev. 1 operation involves two series valves in the chemical and volume control system.

8.6.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

8.6.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.6.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, 0-12 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.6.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.6.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.

Time Margin - The time margin for OMA performance is one hundred forty three (143) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 78 of 148 WIP-E-IF9900-004-A-1, Rev. I Fire Area C-12, Operator Manual Action Timeline (Minutes)

Fire Initiated

-- Fire Indicated

-*_i Diagnosis Time

... 1 .. OM A Uncertainty

.1 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 Time Margin Available Time 4

Figure 8.6.4-1, Fire Area C-12 OMA Timeline 8.6.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-12 reveals that a one hundred forty three (143) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.6.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3306 located on the 2000' elevation of the Control Building. The OMA is in an adjacent structure within the Auxiliary Building. The fire will be confined to the Fire Area C-12 Cable Chase of origin, which contains no ventilation openings.

The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

Post-Fire Safe Shutdown Operator Manual Actions Page 79 of 148 WIP-E-1F9900-004-A-1, Rev. 1 There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.6.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.6.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3306.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

" Pressurizer level indicators BBLI0459A and BBLI0460A.

• VCT level indicators BGLI0112 and BGLI0185.

8.6.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.

Post-Fire Safe Shutdown Operator Manual Actions Page 80 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.6.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.6.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.6.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.6.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.6.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

" Human centered uncertainty - 3 minutes

• Delay in obtaining and setting up ladder - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 81 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.6.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-12 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering

Post-Fire Safe Shutdown Operator Manual Actions Page 82 of 148 WIP-E-1F9900-004-A-1, Rev. 1 the defense in depth fire prevention, detection, and suppression measures discussed above.

8.6.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-12 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty three (143) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

8.7 Fire Area C-18, Control Building 2016' Cable Chase 8.7.1 Fire Area Features Fire Area C-18 is a single room (3419) cable chase located on the 2016' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

E Length- 12 ft.

0 Width- 12 ft.

N Height- 15 ft. 4 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.7.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same raceway within the cable chase. From the floor, the cables of concern transition within vertical cable tray 5U4A through the ceiling of the cable chase. The tray of concern is located on the south side of the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Post-Fire Safe Shutdown Operator Manual Actions Page 83 of 148 WIP-E-1F9900-004-A-1, Rev. I This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

Atmospheric relief valve (ARV) ABPV0001 could spuriously open as a result of an area C-18 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, conservative application of the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown. ABPV0001 cable is located on the north side of the chase in vertical tray 1J1B and horizontal tray 1J1 E, which exits the west wall of the chase at elevation 2016'-2".

Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as control cables for the spurious start of PEN01A and spurious closure of ENHV0006 are located in separate cable trays within the same cable chase. Horizontal spatial separation between the trays of concern (vertical tray 1C8E for PEN01A; vertical tray 1C8B and horizontal tray 1U1G for ENHV0006) is approximately 5 ft. 6 in.

with multiple cable trays presenting intervening combustibles between the identified trays. The trays of concern are located on the north side of the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

The minimum horizontal separation distance that involves all of the above PFSSD circuit issues (with the exception of 1C8E for PEN01A) is approximately 5 ft.

8.7.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Post-Fire Safe Shutdown Operator Manual Actions Page 84 of 148 WI P-E-1 F9900-004-A-1, Rev. 1 Containment spray pump PEN01A can be stopped by opening breaker NB0102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to Attachment C Photo C-7, for a photograph of the respective breaker.

This is a Reactive OMA.

8.7.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.7.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NB0102. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. However, C-18 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.

A six (6) minute operator action time is utilized for opening NB01 02, based on the demonstrated OMA walkdown time documented in Section 8.7.14.

A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.7.14.

OMA Uncertainty Time - A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.7.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.

E-1F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Post-Fire Safe Shutdown Operator Manual Actions Page 85 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Time Margin - The limiting time margin for OMA performance is three (3) minutes.

Fire Area C-18, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated Diagnosis Time OMA Time CTMT Spray OMA Time Letdown OMA Uncertainty 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 3436 38 40 42 44 46 48 50 52 54 56 58 60 Limiting Time Available Time Margin Letdown Available Time CTMT Spray Figure 8.7.4-1, Fire Area C-18 OMA Timeline 8.7.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-18 reveals that a three (3) minute time margin remains for the most limiting OMA.

Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.

8.7.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Cable Chase 3419 located on the 2016' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000' elevation of the Control Building, within the north ESF Switchgear Room.

Post-Fire Safe Shutdown Operator Manual Actions Page 86 of 148 WIP-E-1F9900-004-A-1, Rev. 1 The fire will be confined to the Fire Area C-18 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.

8.7.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.7.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3419.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

0 Pressurizer level indicator BBLI0460A.

0 VCT level indicator BGLI0185.

Post-Fire Safe Shutdown Operator Manual Actions Page 87 of 148 WIP-E-1F9900-004-A-1, Rev. 1 To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

• RWST level indicators BNLI0931 and BNL1933.

" Containment pressure indicators GNP10934 and GNP10936.

8.7.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

The OMAs do not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.

8.7.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors ifthe fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.7.11 Personnel Protection Equipment Opening of breaker NBO102 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.

8.7.12 Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.7.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions Page 88 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.7.14 Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.

The timing effort reflected that the OMA for opening NB01 02 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.

The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NB01 02.

This results in a cumulative OMA implementation time of fifteen (15) minutes for KAV0201.

In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.

• Communication and feedback with Control Room - 2 minutes

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes

" Delay in obtaining and setting up ladder - 3 minutes 8.7.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to

Post-Fire Safe Shutdown Operator Manual Actions Page 89 of 148 WIP-E-1F9900-004-A-1, Rev. 1 the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the general area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of Section III.G.2 protection to ensure a fire in C-18 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.7.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-1 8 are dependable, reliable, and can be consistently performed within the required Available Time. A three (3) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

8.8 Fire Area C-21, Control Building 2032' Lower Cable Spreading Room

Post-Fire Safe Shutdown Operator Manual Actions Page 90 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.8.1 Fire Area Features Fire Area C-21 is the Lower Cable Spreading Room (3501) on the 2032' elevation of the Control Building. The Room contains predominantly cable. It is separated from adjacent areas by 3-hour fire rated barriers.

Smoke detection and a pre-action sprinkler system are provided for the area. Approximate room size is as follows:

" Length - 88 ft.

" Width - 66 ft.

" Height- 14 ft. 10 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.8.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are routed in two trays, one below the other, within a multi-cable tray stack.

Vertical separation distance between the two trays is less than 12".

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

Atmospheric relief valve (ARV) ABPV0001 and ABPV0003 could spuriously open as a result of a C-21 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with two spuriously open ARVs.

However, the thermal hydraulic analysis determined that spuriously open ARVs concurrent with letdown does affect the available time for isolating letdown.

Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as control cables for the spurious start of PEN01A and spurious closure of ENHV0006 are predominantly routed in two trays, one below the other, within a multi-cable tray stack. Vertical separation distance between the two trays is less than 12".

Post-Fire Safe Shutdown Operator Manual Actions Page 91 of 148 WIP-E-1F9900-004-A-1, Rev. I Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

The location where cables associated within each of the above OMA scenarios are closest to each other as a group is in the northeast corner of the spreading room, where each of the cables transition out of the west wall of Cable Chase C-24. The cables for PEN01A and ABPV0001 are in the same set of multi-stack horizontal trays, while cables for letdown are located approximately 3 ft. south within a multi-stack horizontal tray.

Horizontal separation distance for the ABPV0003 conduit from the chase area is approximately 19 ft.

In all the above cases, fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

8.8.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Containment spray pump PEN01A can be stopped by opening breaker NBO102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to Attachment C, Photo C-7, for a photograph of the respective breaker.

This is a Reactive OMA.

8.8.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.8.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NBO102. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area C-21.

Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Post-Fire Safe Shutdown Operator Manual Actions Page 92 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.

A six (6) minute operator action time is utilized for opening NB0102, based on the demonstrated OMA walkdown time documented in Section 8.8.14.

A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.8.14.

OMA Uncertainty Time - A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.8.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.

E-1F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Time Margin - The limiting time margin for OMA performance is eight (8) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 93 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Fire Area C-21, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated IDagnosis Time OMA Time CTMT Spray OMA Time Letdown OMA Uncertainty I 2 4 6 8 1012 14 16 18 20 22 24 26 28 30 3234363840 44 46 48 50 52 54 56 58 60 Limiting Time Available Time Margin Letdown Available Time CTMT Spray Figure 8.8.4-1, Fire Area C-21 OMA Timeline 8.8.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-21 reveals that an eight (8) minute time margin remains for the most limiting OMA.

Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.

8.8.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Lower Cable Spreading Room on the 2032' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000' elevation of the Control Building, within the north ESF Switchgear Room.

Post-Fire Safe Shutdown Operator Manual Actions Page 94 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Based on fire barrier separation, the fire will be confined to Fire Area C-21. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers.

The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.

8.8.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire-rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.8.8 Available Indications Point addressable smoke detection is provided for the Lower Cable Spreading Room. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

. Pressurizer level indicator BBLI0460A.

0 VCT level indicator BGLI0185.

Post-Fire Safe Shutdown Operator Manual Actions Page 95 of 148 WIP-E-1F9900-004-A-1, Rev. 1 To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

" RWST level indicators BNLI0931 and BNL1933.

• Containment pressure indicators GNP10934 and GNP10936.

8.8.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMAs do not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

8.8.10 Portable Eguipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.8.11 Personnel Protection Equipment Opening of breaker NBO102 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.

8.8.12 Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.8.13 Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions Page 96 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.8.14 Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.

The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NBO102 This is conservative, as radio communication will be available. The resulting cumulative OMA implementation time for KAV0201 is fifteen (15) minutes.

The timing effort reflected that the OMA for opening NBO102 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.

In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.

" Communication and feedback with Control Room - 2 minutes

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

" Human centered uncertainty - 3 minutes

" Delay in obtaining and setting up ladder - 3 minutes 8.8.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.

Post-Fire Safe Shutdown Operator Manual Actions Page 97 of 148 WIP-E-1F9900-004-A-1, Rev. I The Lower Cable Spreading Room contains IEEE-383 rated cable normal lighting, emergency lighting, public address equipment, and two electric unit heaters. As discussed in Section 5.1.15.1, IEEE-383 cable, normal lighting, emergency lighting, and public address equipment are not considered credible ignition sources that would promote significant fire propagation. The only noteworthy ignition sources in the room are the electric unit heaters, which are included in the ignition source Zone of Influence review documented in Tables 8.8.15.1-1 and 8.8.15.1-2. The Table 8.8.15.1-2 analysis provides reasonable assurance that a credible fire event within the area would not result in fire induced equipment mal-operation warranting OMA implementation..

The Lower Cable Spreading Room does not have restricted access.

However, it is not on the normal plant travel path, and access is typically limited to occasions associated with periodic area inspections and surveillance for the fire protection equipment. Due to the limited access, transient combustibles are generally not stored in the room, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the room. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable spreading room is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

Post-Fire Safe Shutdown Operator Manual Actions Page 98 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.8.15.1-1, Photos of Ignition Sources and Targets Ignition Source and Target Photo Comments Information I-gnition Source Target cable trays do not contain OMA cables EGK03A of concern Description - 10 kW electric heater located in the northwest corner of the Ignition source is cable spreading room considered near a wall Height from Floor - 136" when applying NRC Horizontal Distance to Target - 108" Inspection Manual 0609 Vertical Distance to Target - N/A Appendix F guidance.

Distance to North Wall - 44" Distance to West Wall - 24" Target Cable tray stack east of heater Ignition Source Target cable trays 5C8T and 5C8U (below 5C8T)

EGK03B contain cables Description - 10 kW electric heater associated with letdown located in the southwest corner of the isolation valves cable spreading room BGLCV0459 and Height from Floor - 137" BGLCV0460 Horizontal Distance to Target - 6" Vertical Distance to Target - 0" Ignition source is Distance to South Wall - 40" considered near a wall Distance to West Wall - 24" when applying NRC Inspection Manual 0609 Appendix F guidance.

Target Cable tray stack east of heater, which includes 5C8T and 5C8U

Post-Fire Safe Shutdown Operator Manual Actions Page 99 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.8.15.1-2, Zone of Influence Review for Ignition Sources and Targets Ignition Target Expected Target Critical Comments Source HRR Distance (ft) Distance (ft)

High H R H R Confidence HRR __

EGK03A Cable tray 70 kW N/A 9 4.6 1.8 Target is below ignition source height stack, east of heater 200 kW 7.0 3.0 and is outside the Zone of Influence.

This area originally was a construction opening during the initial plant assembly.

The approximate 24 ft. x 14 ft. area contains minimal cable concentration. It is not sprinkler protected. This area is procedurally maintained as a Combustible Control Zone per AP 10-102. No unattended transient combustibles are allowed in this area without Fire Protection review. Due to the lack of fixed combustible continuity, and the strict administrative control for transient combustibles in the area housing EGK03A, fire propagation involving heater failure would not transition to cable tray involvement within the room.

EGK03B Cable tray 70 kW 0 0.5 4.6 1.8 Target trays 5C8T and 5C8U are the stack east third and forth cable trays from the top in of heater, 200 kW 7.0 3.0 a stack of seven trays. The top two trays which are higher than the heater base. Both includes 5C8T and 5C8U are lower than the 5C8T and heater base. Bottom and topside steel 5C8U tray covers are provided for the top two trays beyond the zone of influence distance. Tray 5C8T is provided bottom and topside steel cover protection for a distance of 30" from the heater discharge and over 20' from the heater suction side. 5C8U is not provided with tray covers. The encapsulating steel cover protection provided for the trays above the heater ensures that they will not be involved in a fire event initiated from EGK03B failure. Trays 5C8T and 5C8U will not be within the heat plume from EGK03B since they are located at a lower elevation than the ignition source.

Additionally, with EGK03B being near the ceiling, sprinkler response in proximity to the heater will be prompt, providing reasonable assurance that automatic suppression activities would significantly limit fire damage. Trays 5C8T and 5C8U are not postulated to be affected by EGK03B failure.

Post-Fire Safe Shutdown Operator Manual Actions Page 100 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 100 of 148 WIP-E-1F9900-004-A-1, Rev. 1

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and pre-action sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, if necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of Section III.G.2 protection to ensure a fire in C-21 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.8.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-21 are dependable, reliable, and can be consistently performed within the required Available Time. An eight (8) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

8.9 Fire Area C-22, Control Buildinq 2073'-6 Upper Cable Spreading Room 8.9.1 Fire Area Features Fire Area C-22 is the Upper Cable Spreading Room (3801) on the 2073'-

6" elevation of the Control Building. The Room contains predominantly cable. It is separated from adjacent areas by 3-hour fire rated barriers.

Smoke detection and a pre-action sprinkler system are provided for the area. Approximate room size is as follows:

" Length - 88 ft.

" Width - 67 ft.

" Height- 12 ft.

Refer to Attachment D for a plan view sketch of the fire area.

8.9.2 Spurious Equipment Operation Requiring Operator Manual Action

Post-Fire Safe Shutdown Operator Manual Actions Page 101 of 148 WIP-E-lF9900-004-A-1, Rev. 1 Containment spray pump PEN01B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as control cables for the spurious start of PEN01B and spurious closure of ENHV0012 are predominantly routed in two trays, one below the other, within a multi-cable tray stack. Vertical separation distance between the two trays is less than 12". Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a MSO scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

8.9.3 Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-10). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.

8.9.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.9.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area C-22.

Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.9.14.

OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.9.14.

Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Post-Fire Safe Shutdown Operator Manual Actions Page 102 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Time Margin - The time margin for OMA performance is thirty nine (39) minutes.

Fire Area C-22, Operator Manual Action Timeline (Minutes)

SFire Initiated

-1 Fire Indicated OMagnosis Timet OMA~imeOMA uncertainty 2 4 6 8 10 12 14 161820 2 24 26 283 0 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Time Margin Available Time Figure 8.9.4-1, Fire Area C-22 OMA Timeline 8.9.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-22 reveals that a thirty nine (39) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.9.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Upper Cable Spreading Room on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to Fire Area C-22 Upper Cable Spreading Room.

The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire-rated barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Post-Fire Safe Shutdown Operator Manual Actions Page 103 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.9.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.9.8 Available Indications Point addressable smoke detection is provided for C-22. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

0 RWST level indicators BNLI0930 and BNLI0932.

• Containment pressure indicators GNP10935 and GNPI0937.

Post-Fire Safe Shutdown Operator Manual Actions Page 104 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.9.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

8.9.10 Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.9.11 Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMA.

8.9.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.9.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.9.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.

. Communication and feedback with Control Room - 1 minute 0 Electronically controlled door key access - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 105 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 105 of 148 WIP-E-1F9900-004-A-1, Rev. 1 0 Human centered uncertainty - 3 minutes 8.9.15 Defense-I n-De pth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.

The Upper Cable Spreading Room contains IEEE-383 rated cable normal lighting, emergency lighting, public address equipment, and two electric unit heaters. As discussed in Section 5.1.15.1, IEEE-383 cable, normal lighting, emergency lighting, and public address equipment are not considered credible ignition sources that would promote significant fire propagation. The only noteworthy ignition sources in the room are the electric unit heaters, which are included in the ignition source Zone of Influence review documented in Tables 8.9.15.1-1 and 8.9.15.1-2. The Table 8.9.15.1-2 results reveal that the fixed ignition sources are not within the Zone of Influence for the cable trays containing the OMA target cable, and fire propagation would not migrate to the cables of concern before implementation of suppression activities. There is reasonable assurance that a credible fire event within the area would not result in fire induced equipment malepeFatwenmal-operation warranting OMA implementation.

The Upper Cable Spreading Room does not have restricted access.

However, it is not on the normal plant travel path, and access is typically limited to occasions associated with periodic area inspections and surveillance for the fire protection equipment. Due to the limited access, transient combustibles are generally not stored in the room, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the room. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable spreading room is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

Post-Fire Safe Shutdown Operator Manual Actions Post-Fire Safe Shutdown Operator Manual Actions Page 106 of 148 WIP-E-1F9900-004-A-1, Rev. I Table 8.9.15.1-1, Photos of Ignition Sources and Targets Ignition Source and Target Photo Comments Information Ignition Source Target cable trays do not contain OMA cables EGK02A of concern.

Description - 40 kW electric heater located in the northwest corner of the Ignition source is cable spreading room considered near a wall Height from Floor - 101" when applying NRC Horizontal Distance to Target - 228" Inspection Manual 0609 Vertical Distance to Target - 24" Appendix F guidance.

Distance to North Wall - 37" Distance to West Wall - 12" Target Cable tray stack east of heater i

Ignition Source Target cable trays do not contain OMA cables EGK02B of concern.

Description - 40kW electric heater located in the southeast comer of the Ignition source is not cable spreading room, north of cable considered near a wall chase C-33 or corner when applying Height from Floor- 101" NRC Inspection Manual Horizontal Distance to Target - 26" 0609 Appendix F Vertical Distance to Target - 0" guidance.

Distance from South Wall - 29" Distance from East Wall - 26" Target Cable tray stack west of heater

Post-Fire Safe Shutdown Operator Manual Actions Page 107 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.9.15.1-2, Zone of Influence Review for Ignition Sources and Targets Ignition Target Expected Target Critical Comments Source HRR Distance (ft) Distance (ft)

High H R H R Confidence HRR EGK02A Cable tray 70 kW 2 19 4.6 1.8 Target is outside the Zone of Influence.

stack east 200 kW 7.0 3.0 This area originally was a construction of heater opening during the initial plant assembly.

The approximate 24 ft. x 14 ft. area is not sprinkler protected. This area is procedurally maintained as a Combustible Control Zone per AP 10-102. No unattended transient combustibles are allowed in this area without Fire Protection review. Due to the lack of fixed combustible continuity, and the strict administrative control for transient combustibles in the area housing EGK02A, fire propagation involving heater failure would not transition to cable tray involvement within the room.

EGK02B Cable tray 70 kW 0 2.1 3.5 1.3 The target cable trays, which do not stack west contain OMA cables of concern, are of heater 200 kW 5.3 2.1 outside the Zone of Influence for the expected fire exposure (70 kW) and are at the Zone of Influence boundary for a high confidence (200 kW) heat release rate. The closest distance from the trays potentially affected by EGK02B to the trays containing containment spray pump PEN01B valve ENHV0012 cables is approximately 14 horizontal feet.

Applying the horizontal tray flame spread rate of 10 ft. per hour from NRC Inspection Manual 0609 Appendix F reflects an approximate 75-minute fire duration before potential fire induced impact to the OMA cables of concern.

This duration provides more than adequate time for fire brigade suppression response prior to fire involvement of the OMA cables.

Additionally, with EGK02B being near the ceiling, sprinkler response in proximity to the heater will be prompt, providing reasonable assurance that automatic suppression activities would significantly limit fire damage.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and pre-action sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, if necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions Page 108 of 148 WIP-E-1F9900-004-A-1, Rev. 1

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-22 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.9.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-22 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty nine (39) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.

Therefore, the OMA is considered both feasible and reliable.

8.10 Fire Area C-23, Control Building 2032' South Cable Chase 8.10.1 Fire Area Features Fire Area C-23 is a single room (3505) cable chase located on the 2032' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

" Length- 12 ft.

" Width- 12 ft.

" Height- 14 ft.

Refer to Attachment D for a plan view sketch of the fire area.

8.10.2 Spurious Equipment Operation Requiring Operator Manual Action Containment spray pump PEN01 B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, 7are not satisfied, as control cables for the spurious start of PEN01B and spurious closure of ENHV0012 are located in separate cable trays within the same cable chase. Horizontal spatial separation between the trays of concern (vertical tray 4C8D for PEN01 B; vertical tray 4C8B and horizontal tray 4U3A for ENHV0012) is approximately 5 ft. 6

Post-Fire Safe Shutdown Operator Manual Actions Page 109 of 148 WIP-E-1F9900-004-A-1, Rev. 1 in., with multiple cable trays presenting intervening combustibles between the identified trays. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

8.10.3 Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-10). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.

8.10.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.10.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-23 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.10.14.

OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.10.14.

Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Time Margin - The time margin for OMA performance is thirty four (34) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 110 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Fire Area C-23, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated

' Diagnosis Time OMATime 2IOMA Uncertainty 2 4 6 8 10 1628 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Time Margin Available Time Figure 8.10.4-1, Fire Area C-23 OMA Timeline 8.10.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-23 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.10.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3505 located on the 2032' elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to the Fire Area C-23 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and the emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity

Post-Fire Safe Shutdown Operator Manual Actions Page 111 of 148 WIP-E-1F9900-004-A-1, Rev. 1 conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.10.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.10.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3505.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

• RWST level indicators BNLI0930 and BNLI0932.

• Containment pressure indicators GNP10935 and GNPI0937.

8.10.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

The OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room for further direction, if the fire affects the Gaitronics or radio system functionality.

Post-Fire Safe Shutdown Operator Manual Actions Page 112 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.10.10 Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.10.11 Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMA.

8.10.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.10.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.10.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.

• Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

" Human centered uncertainty - 3 minutes 8.10.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work

Post-Fire Safe Shutdown Operator Manual Actions Page 113 of 148 WIP-E-1F9900-004-A-1, Rev. I limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-23 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

Post-Fire Safe Shutdown Operator Manual Actions Page 114 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.10.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-23 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty four (34) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.

Therefore, the OMA is considered both feasible and reliable.

8.11 Fire Area C-24, Control Building 2032' North Cable Chase 8.11.1 Fire Area Features Fire Area C-24 is a single room (3504) cable chase located on the 2032' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

" Length- 12 ft.

" Width- 12 ft.

" Height- 14 ft. 10 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.11.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are in the same raceway within the cable chase. From the floor, the cables of concern transition within vertical cable tray 5U4A to horizontal cable tray 5C8T at elevation 2040'-4". The horizontal tray, which is third from the top in a stack of seven trays, exits the west wall of the cable chase. The identified cable trays are located on the south side of the cable chase.

Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-

Post-Fire Safe Shutdown Operator Manual Actions Page 115 of 148 WIP-E-1F9900-004-A-1, Rev. 1 operation involves two series valves in the chemical and volume control system.

Atmospheric relief valve (ARV) ABPV0001 could spuriously open as a result of a C-24 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, conservative application of the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown. Cabling for ABPV0001 is located on the north side of the chase within horizontal trays 1J1 G and 1JI1 H, and vertical trays 1J1 F and UJ1B.

Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as control cables for the spurious start of PEN01A and spurious closure of ENHV0006 are located in separate cable trays within the same cable chase. Worst-case horizontal spatial separation between the trays of concern (vertical tray 1C8E; horizontal tray 1C8J for PEN01A and vertical tray 1C8B; horizontal tray 1C8G for ENHV0006) is less than 12 in., with multiple cable trays presenting intervening combustibles between the identified trays. The identified cable trays are located on the north side of the cable chase. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

The minimum horizontal separation distance that involves all of the above PFSSD circuit issues is approximately 3 ft.

8.11.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Containment spray pump PEN01A can be stopped by opening breaker NB0102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to

Post-Fire Safe Shutdown Operator Manual Actions Page 116 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Attachment C, Photo C-7, for a photograph of the respective breaker.

This is a Reactive OMA.

8.11.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.11.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NB0102. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment BI application of NUREG-1805 for smoke detector response. However, C-24 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.

A six (6) minute operator action time is utilized for opening NB0102, based on the demonstrated OMA walkdown time documented in Section 8.11.14.

A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.11.14.

OMA Uncertainty Time - A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.11.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.

E-1F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Time Margin - The limiting time margin for OMA performance is three (3) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 117 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Fire Area C-24, Operator Manual Action Timeline (Minutes)

Fire Initiated Fire Indicated I Diagnosis Time OMA Time CTMT Spray OMA Timre Letdow n OM OMA Uncertainty 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Limiting Time Available Time Margin Letdown Available Time CTMT Spray Figure 8.11.4-1, Fire Area C-24 OMA Timeline 8.11.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-24 reveals that a three (3) minute time margin remains for the most limiting OMA.

Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.

8.11.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Cable Chase 3504 located on the 2032' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000' elevation of the Control Building, within the north ESF Switchgear Room.

The fire will be confined to the Fire Area C-24 Cable Chase of origin, which contains no ventilation openings. The travel path and location of

Post-Fire Safe Shutdown Operator Manual Actions Page 118 of 148 WIP-E-1F9900-004-A-1, Rev. 1 the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.

8.11.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire rated barriers. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.11.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3504.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

" Pressurizer level indicator BBLI0460A

• VCT level indicator BGLI0185.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

Post-Fire Safe Shutdown Operator Manual Actions Page 119 of 148 WIP-E-1F9900-004-A-1, Rev. 1

• RWST level indicators BNLI0931 and BNL1933.

" Containment pressure indicators GNP10934 and GNP10936.

8.11.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMAs do not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

8.11.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.11.11 Personnel Protection Equipment Opening of breaker NB0102 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.

8.11.12 Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.11.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

8.11.14 Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.

Post-Fire Safe Shutdown Operator Manual Actions Page 120 of 148 WIP-E-1F9900-004-A-1, Rev. I The timing effort reflected that the OMA for opening NB01 02 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.

The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NB01 02.

This is conservative, as radio communication will be available. The resulting cumulative OMA implementation time for KAV0201 is fifteen (15) minutes.

In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.

" Communication and feedback with Control Room - 2 minutes

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes

" Delay in obtaining and setting up ladder - 3 minutes 8.11.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented

Post-Fire Safe Shutdown Operator Manual Actions Page 121 of 148 WIP-E-1F9900-004-A-1, Rev. 1 by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of Section III.G.2 protection to ensure a fire in C-24 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.11.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-24 is dependable, reliable, and can be consistently performed within the required Available Time. A three (3) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

8.12 Fire Area C-30, Control Building 2047'-6" Cable Chase 8.12.1 Fire Area Features Fire Area C-30 is a single room (3617) cable chase located on the 2047'-

6" elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

0 Length- 12 ft.

Post-Fire Safe Shutdown Operator Manual Actions Page 122 of 148 WIP-E-1F9900-004-A-1, Rev. 1

" Width- 12 ft.

" Height-25 ft. 4 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.12.2 Spurious Equipment Operation Requirinq Operator Manual Action Containment spray pump PEN01 B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as control cables for the spurious start of PEN01B and spurious closure of ENHV0012 are located in separate cable trays within the same cable chase. Horizontal spatial separation between the trays of concern (vertical tray 4C8D for PEN01 B and vertical tray 4C8B for ENHV0012) is approximately 5 ft. 6 in., with multiple cable trays presenting intervening combustibles between the identified trays.

Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

8.12.3 Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-10). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.

8.12.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.12.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A nine (9) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-30 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to fourteen (14) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 123 of 148 WIP-E-1F9900-004-A-1, Rev. I Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.12.14.

OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.12.14.

Available Time - E-1 F991 0 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Time Margin - The time margin for OMA performance is twenty six (26) minutes.

Fire Area C-30, Operator Manual Action Timeline (Minutes)

Fire Initiated I Fire Indicated Diagnosis Time

/ OMA Time

/ WTieOMA Ouncertainty 2 4 6 8 10 1214161820222426283032 36384042444648505254565860 Time Margin Available Time Figure 8.12.4-1, Fire Area C-30 OMA Timeline 8.12.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-30 reveals that a twenty six (26) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions Page 124 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.12.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3617 located on the 2047' elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to the Fire Area C-30 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire-rated barriers. The access door for the cable chase opens to the back of the Control Room in the equipment cabinet area.

The OMA operator will be present in the Control Room in order to receive OMA implementation direction. Manual fire fighting efforts, if necessary, will require periodic opening of the cable chase door. However, the smoke propagation review documented in Section 5.1.6 determined that OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.12.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

Post-Fire Safe Shutdown Operator Manual Actions Page 125 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.12.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3617.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

• RWST level indicators BNLI0930 and BNLI0932.

" Containment pressure indicators GNP10935 and GNP10937.

8.12.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

8.12.10 Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters.

8.12.11 Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMAs.

8.12.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

Post-Fire Safe Shutdown Operator Manual Actions Page 126 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.12.13 Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.12.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.

" Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

• Human centered uncertainty - 3 minutes 8.12.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

Post-Fire Safe Shutdown Operator Manual Actions Page 127 of 148 WIP-E-1F9900-004-A-1, Rev. 1 As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-30 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.12.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-30 are dependable, reliable, and can be consistently performed within the required Available Time. A twenty six (26) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.

Therefore, the OMA is considered both feasible and reliable.

8.13 Fire Area C-33, Control Building 2073'-6" South Cable Chase 8.13.1 Fire Area Features Fire Area C-33 is a single room (3804) cable chase located on the 2073'-

6" elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door. Approximate cable chase size is as follows:

" Length- 13 ft.

" Width- 12 ft.

0 Height- 12 ft.

Post-Fire Safe Shutdown Operator Manual Actions Page 128 of 148 Post-Fire Safe Shutdown Operator Manual Actions Page 128 of 148 WIP-E-1F9900-004-A-1, Rev. I Refer to Attachment D for a plan view sketch of the fire area.

8.13.2 Spurious Equipment Operation Requiring Operator Manual Action Containment spray pump PEN01 B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, -are not satisfied, as control cables for the spurious start of PEN01B and spurious closure of ENHV0012 are located in separate cable trays within the same cable chase. Worst-case horizontal spatial separation between the trays of concern (vertical tray 4C8D; horizontal tray 4C8F for PEN01 B and vertical tray 4C8B; horizontal tray 4C8G for ENHV0012) is less than 12 in., with multiple cable trays presenting intervening combustibles between the identified trays. Fire wrap protection is not practical due to the cable tray congestion, and cable reroute is not a cost effective option considering the number of affected fire areas.

Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component mal-operation events are required before containment spray would be spuriously actuated.

8.13.3 Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-1 0). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.

8.13.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.13.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. However, C-33 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

Post-Fire Safe Shutdown Operator Manual Actions Page 129 of 148 WIP-E-1F9900-004-A-1, Rev. I OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.13.14.

OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.13.14.

Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Time Margin - The time margin for OMA performance is thirty four (34) minutes.

Fire Area C-33, Operator Manual Action Timeline (Minutes)

Fire Initiated

• - Fire Indicated EDagnosis Tine OMATime 0 OMA Uncertainty S2 4 6 8 101214 161820 2224 22 032 34 36384042 4446 4850* 2 5456 58 60 Time Margin Available Time I

Figure 8.13.4-1, Fire Area C-33 OMA Timeline 8.13.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-33 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions Page 130 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.13.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3804 located on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is on the 2000' elevation of the Control Building within the south ESF Switchgear Room.

The fire will be confined to the Fire Area C-33 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.

Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and the emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.13.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire-rated barriers.

This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.13.8 Available Indications Point addressable smoke detection is provided for Cable Chase 3804.

Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure

Post-Fire Safe Shutdown Operator Manual Actions Page 131 of 148 WIP-E-1F9900-004-A-1, Rev. 1 indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:

• RWST level indicators BNLI0930 and BNL10932.

" Containment pressure indicators GNP10935 and GNP10937.

8.13.9 Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.

8.13.10 Portable Eguipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors ifthe fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters.

8.13.11 Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.

No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMAs.

8.13.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.13.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.13.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could

Post-Fire Safe Shutdown Operator Manual Actions Page 132 of 148 WIP-E-1F9900-004-A-1, Rev. 1 be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.

" Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

• Human centered uncertainty - 3 minutes 8.13.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.

The cable chase contains IEEE-383 rated cable and a single light fixture. As discussed in Section 5.1.15.1, IEEE-383 cable and normal lighting are not considered credible ignition sources that would promote fire propagation. Therefore, there are no fixed ignition sources within the cable chase that would initiate a fire event warranting OMA implementation.

As previously discussed, the cable chase is normally locked. This restricts normal access to occasions associated with periodic area inspections and surveillance activities for the access door. Due to the access restriction, transient combustibles are generally not stored in the chase, and transient combustible introduction typically only occurs when implementing a modification requiring new cable addition within the chase. This is an infrequent occasion, which does not result in a significant contribution of transient combustibles or introduction of additional ignition sources beyond that presented by low voltage power tools. Therefore, the likelihood of a transient combustible induced fire within the cable chase is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.

Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions Page 133 of 148 WIP-E-1F9900-004-A-1, Rev. 1

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in C-33 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.13.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-33 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty four (34) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.

Therefore, the OMA is considered both feasible and reliable.

8.14 Fire Area RB, Reactor Building General Area 8.14.1 Fire Area Features Fire Area RB is all elevations of the Reactor Building. The 4-foot-thick Reactor Building walls serve as the fire barrier separation from adjacent buildings. There are no fire-rated barrier walls or floors internal to the Reactor Building, though substantial barrier and spatial separation are provided within the building. Linear heat detection is installed above each reactor coolant pump and in areas where cable trays are concentrated.

Duct smoke detection is provided for each containment cooler (four total).

A fixed, manually charged, closed head sprinkler system is provided for the north and south cable penetration areas on the 2026' elevation. The Reactor Building contains five major elevations and is approximately 140 ft. in diameter. Reactor Building height is approximately 136 ft. 6 in.

Refer to Attachment D for a plan view sketch of the fire area.

8.14.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, -are not satisfied, as the cables for both BGLCV0459 and BGLCV0460 are routed within the same cable tray from the 2026' north cable penetration area. The letdown cables traverse within a tray into the bioshield where the cables transition into the same conduit and ultimately terminate at the two series valves BGLCV0459 and BGLCV0460 east of 'C' Steam Generator.

Post-Fire Safe Shutdown Operator Manual Actions Page 134 of 148 WIP-E-1F9900-004-A-1, Rev. 1 This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced mal-operation involves two series valves in the chemical and volume control system.

Cables associated with excess letdown isolation valves BGHV8153A and BGHV8154A may be damaged, preventing these valves from being closed from the Control Room. Thermal hydraulic analysis WCNOC-CP-002 reveals that these valves may remain open, with no adverse impact to PFSSD, provided letdown is isolated within one hundred twenty (120) minutes. The excess letdown valves are located on the 2000' elevation east of 'D' Reactor Coolant Pump. Cable for BGHV8153A transitions in a counterclockwise direction around the annulus of the Reactor Building where it transitions up into the 2026' north electrical penetration area.

Cable for BGHV8154A transitions in a clockwise direction around the annulus of the Rector Building where it also transitions up into the 2026' north electrical penetration area.

8.14.3 Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment, C Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

8.14.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.14.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - Total coverage fire alarm detection is not provided for the Reactor Building. The majority of the detection provided responds to thermal change due to fire and not the smoke products of combustion (duct smoke detection is provided for the containment coolers). Thermal detection typically responds to a fire event slower than smoke detection.

Additionally, the Reactor Building is not normally occupied and is not as readily accessible as the Control or Auxiliary Buildings. Therefore, the time for Reactor Building fire indication is postulated to be up to sixty (60) minutes. This is a conservatively reasonable time as a fire that adversely affects all letdown/excess letdown isolation valves would be of significant severity that fire detection would occur within sixty (60) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 135 of 148 WIP-E-1F9900-004-A-1, Rev. I Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.14.14.

OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.14.14.

Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when both letdown and excess letdown flow diversion events are active concurrently, excess letdown may remain open provided letdown is isolated in one hundred and twenty (120) minutes. Implementation within the Available Time ensures there will be no adverse consequence to reactor performance.

Due to substantial spatial separation between cables and the valves of concern, it is unlikely that a fire event would involve the mal-operation of all isolation valves associated with letdown and excess letdown.

However, from an OMA timeline perspective, it is conservatively assumed that all excess letdown and letdown isolation valves are simultaneously affected by the same fire, since the literal separation of requirements of 10 CFR 50 Appendix R, Section Ill.G.2, are not fully satisfied.

Time Margin - The time margin for OMA performance is twenty nine (29) minutes.

Fire Area RB, Operator Manual Action Timeline (Mnutes)

Fire Initiated Fire Indicated EDagnosis Timre OMA Time OMA Uncertainty 10 20 30 40 50 60 70 80 9 100 110 120 6* Time Margin Available Time I

Figure 8.14.4-1, Fire Area RB OMA Timeline 8.14.5 Reliability Analysis of Time Available to Perform Manual Actions

Post-Fire Safe Shutdown Operator Manual Actions Page 136 of 148 WIP-E-1F9900-004-A-1, Rev. 1 As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area RB reveals that a twenty nine (29) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

8.14.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Reactor Building. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area RB. Access to Fire Area A-25 does not require transition through Fire Area RB. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.14.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by the Reactor Building external wall. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

Post-Fire Safe Shutdown Operator Manual Actions Page 137 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.14.8 Available Indications Point addressable duct smoke detection is provided for the containment coolers. Linear detection is provided for the reactor coolant pumps and areas with cable tray concentration. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the alarm. This will likely be the first indication of a fire event within area.

To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.

The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:

• Pressurizer level indicator BBLI0460A.

= VCT level indicators BGLI0112 and BGLI0185.

To diagnose a failure of the excess letdown valves, valve position indication of appropriate level indication needs to be available. The valve position indication cables are located in the same area of the Reactor Building as the valves, so position indication cannot be relied on. The excess letdown valves discharge to the Pressurizer Relief Tank (PRT) inside the Reactor Building. Since the PRT is also inside Reactor Building, the same fire could also affect its level indication. Therefore, there is no direct reliable indication of the failure for excess letdown to isolated. However, based on a thermal hydraulic analysis WCNOC-CP-002, a charging pump will adequately compensate for the loss of inventory from the one-inch excess letdown line, which flows approximately 50 gpm at full reactor pressure. Pressurizer level indicator BBLI0460A will be available and both of the VCT level indicators, BGLI0112 and BGL10185, will be available. However, as previously identified, no action is required for excess letdown isolation to maintain hot standby, provided letdown is isolated in one hundred twenty (120) minutes.

8.14.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room ifthe Gaitronics or radio system functionality are affected by the fire.

Post-Fire Safe Shutdown Operator Manual Actions Page 138 of 148 WIP-E-1F9900-004-A-1, Rev. I 8.14.10 Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.

Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.14.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.

8.14.12 Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.14.13 Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

8.14.14 Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.

This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

" Communication and feedback with Control Room - 1 minute

" Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes

" Delay in obtaining and setting up ladder - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions Page 139 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.14.15 Defense-In-Depth

1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the area is not normally occupied, which limits the potential for the introduction of transient fire hazards.

The noteworthy ignition sources within the Reactor Building are the reactor coolant pumps (RCPs). A fire involving RCPs A, B and C could affect cables associated with letdown isolation valves BGLCV0459 and BGLCV0460. A review of the cable routing database (Setroute) and the raceway drawings reflect that these cables are run in conduit in the vicinity of RCPs B and C and cable tray in the vicinity of RCP A. Based on circuit analysis, fire damage to the letdown cables in proximity to the RCPs will not result in the inability to close the letdown valves from the Control Room.

Exposed transient combustibles are not stored in the Reactor Building. During normal power operations personnel access within the Reactor Building is strictly limited. The few work activities conducted do not result in appreciable transient combustible introduction, as each item taken into the Reactor Building must be accounted for as a part of foreign material control. Therefore, the likelihood of a transient combustible fire within the Reactor Building at normal power is extremely low.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

2. Detect, Control, and Extinguish Fires Considering the conservative OMA timeline application for fire indication, this objective is not affected by the OMA. Linear heat detection is installed above each reactor coolant pump and in areas where cable trays are concentrated. Duct smoke detection is provided for each containment cooler. Fire alarm annunciation is provided locally, and within the Control Room. Alarms are zoned, allowing for prompt recognition of fire location.

A system is provided to collect and contain lubricating oil for each reactor coolant pump (RCP). The RCP oil spillage protection and control system consists of a package of splash guards, catch basins, and enclosure assemblies as attachments to the RCP motors at strategic locations to preclude the possibility of oil making contact with hot components and pipe.

All fire water system piping within the Reactor Building is maintained dry by two normally closed isolation valves located in series on the

Post-Fire Safe Shutdown Operator Manual Actions Page 140 of 148 WIP-E-1F9900-004-A-1, Rev. 1 same supply line. These valves are located in the south Pipe Penetration Room on the 2026' elevation of the Auxiliary Building.

A fixed, manually charged, closed head sprinkler system is provided for the north and south cable penetration areas on the 2026' elevation. The sprinkler system, will aid in controlling the fire event within the cable penetration areas. Fire extinguishers and hose stations are also provided within the Reactor Building for manual fire fighting.

3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of Section III.G.2 protection to ensure a fire in RB does not challenge PFSSD.

This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

8.14.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area RB is dependable, reliable, and can be consistently performed within the required Available Time. A twenty nine (29) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.

Therefore, the OMA is considered both feasible and reliable.

8.15 Fire Area A-27, Auxiliary Building 2026' Rod Drive MG Set Room 8.15.1 Fire Area Features Fire Area A-27 is the Rod Drive MG Set Room (1403) on the 2026' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Cross-zoned smoke detection is provided, which actuates a total flooding Halon system for the room. The following identified room dimensions are based on a rectangular area within the irregular shaped footprint of the Rod Drive MG Set Room.

" Length- 92 ft. 9 in.

" Width- 25 ft. 6 in.

" Height-20 ft. 6 in.

Refer to Attachment D for a plan view sketch of the fire area.

Post-Fire Safe Shutdown Operator Manual Actions Page 141 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.15.2 Spurious Equipment Operation Requiring Operator Manual Action Cables associated with component cooling water (CCW) isolation valves EGHV0016 andEGHV0054 may be damaged, preventing the valves from being opened from the Control Room. The fire induced failure mode for EGHV0016 and EGHV0054 is the as is position. These valves are normally closed when 'A' CCW is operating. 'B' CCW is credited for an A-27 fire, as the postulated fire can affect 'A' train CCW operability. Swap over from 'A' to 'B' CCW would require opening of EGHV0016 and EGHV0054, which could be failed in the closed position as a result of fire induced circuit interaction. No OMA is required if 'B' train CCW is operating prior to the fire event, as EGHV0016 and EGHV0054 will be open to support charging pump operability, and the valves will not mal-operate to the closed position as a result of the fire. The fire barrier and spatial separation requirements of 10 CFR 50 Appendix R, Section III.G.2, are not satisfied, as the cables for both EGHV0016 and EGHV0054 are in the same cable tray within the fire area. The horizontal tray (4U3A), which is located at the south end of the room, is the top tray in a stack of four trays. It is located at elevation 2041'-11".

As documented in Section 2.6, this issue is being addressed long term by the implementation of Change Package 012418. This modification will install fire rated cable for protection of EGHV0016 and EGHV0054.

8.15.3 Operator Manual Action Description Motor operated valve EGHV0016 is located on the 2026' elevation of the Auxiliary Building in the general corridor (1402) area of Fire Area A-16.

(Reference Attachment C, Photo C-9). The valve can be manipulated locally by declutching the motor and manually opening the valve.

Motor operated valve EGHV0054 is located on the 2026' elevation of the Auxiliary Building in the 'B' CCW (1401) area of Fire Area A-16.

(Reference Attachment C, Photo C-10). The valve can be manipulated locally by declutching the motor and manually opening the valve.

Local opening of EGHV0016 and EGHV0054 is a Reactive OMA.

8.15.4 Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.15.4-1 reflects the OMA timeline for opening EGHV0016 and EGHV0054. The identified times are based on the following:

Fire Initiated - This is the initiating event, which occurs at time zero.

Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area A-27.

Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Post-Fire Safe Shutdown Operator Manual Actions Page 142 of 148 WIP-E-1F9900-004-A-1, Rev. I Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

OMA Implementation Time -A cumulative twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.15.14.

OMA Uncertainty Time - A nine (9) minute OMA uncertainty time is utilized based on Section 8.15.14.

Available Time - Thermal hydraulic analysis SA-08-006 and E-1 F991 0 identify that charging, and thus CCW, must be established within twenty eight (28) minutes.

Time Margin - The time margin, without considering OMA uncertainty, is five (5) minutes. This demonstrates that the OMAs are feasible. The time margin for OMA performance, considering OMA uncertainty is, negative four (4) minutes.

Fire Area A-27, Operator Manual Action Timeline (Minutes)

Fire Initiated A

Fire Indicated Diagnosis Time OMA Time OMA Uncertainty 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 Time Margin (without Uncertainty)

Available Time Figure 8.15.4-1, Fire Area A-27 OMA Timeline 8.15.5 Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time. The Figure 8.15.4-1 OMA timeline does not support a conclusion that the OMAs are reliable. However, the feasible OMAs coupled with a fire watch, are acceptable interim compensatory measures until the OMAs are eliminated by the field implementation of change package 012418.

Post-Fire Safe Shutdown Operator Manual Actions Page 143 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.15.6 Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within the Rod Drive MG Set Room on the 2026' elevation of the Auxiliary Building (Fire Area A-27). Based on fire barrier separation, the fire will be confined to Fire Area A-27.

Access to Fire Area A-16 does not require transition through Fire Area A-

27. The travel path and location of the equipment requiring manipulation are physically separated from the fire by a rated fire barrier. Fire fighting access to A-27 could be from door 14031 within A-16. However, the smoke propagation review documented in Section 5.1.6 determined that the OMA implementation would not be impeded by smoke migration from the fire event.

Emergency lighting is provided for illumination of potential egress paths and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.

8.15.7 Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by a fire rated barrier. This ensures that the fire and its effects do not adversely affect the credited equipment.

The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

8.15.8 Available Indications Point addressable smoke detection is provided for the fire area. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.

To diagnose a failure of 'A' Train CCW, necessitating the need to swap to

'B' CCW, pump breaker position indication or CCW flow indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist the Control Room in diagnosing the need to locally open EGHV0016 and EGHV0054 to lineup 'B' CCW:

Post-Fire Safe Shutdown Operator Manual Actions Page 144 of 148 WIP-E-1F9900-004-A-1, Rev. I

" 'A" CCW Pump breaker position from hand indicating switch EGHIS0021.

" "C"CCW Pump breaker position from hand indicating switch EGHIS0023.

" CCW flow to service loop EGFI0055A.

8.15.9 Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.

The OMAs does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room Operators to provide face-to-face direction for the OMA. Once the OMAs have been implemented, the operator can physically report back to the Control Room if the fire affects the Gaitronics or radio system functionality.

Communication with the Control Room of OMA implementation is not required due to CCW service loop flow indication being available.

8.15.10 Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMAs. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.

8.15.11 Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMAs.

8.15.12 Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

8.15.13 Staffing The Operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

8.15.14 Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMAs could be consistently, sequentially performed within twelve (12) minutes.

Post-Fire Safe Shutdown Operator Manual Actions Page 145 of 148 WIP-E-1F9900-004-A-1, Rev. 1 In addition, the following uncertainty times have been included, resulting in a total uncertainty time of nine (9) minutes.

• Communication and feedback with Control Room - 1 minute

• Electronically controlled door key access - 3 minutes

• Obtain RCA access - 2 minutes

• Human centered uncertainty - 3 minutes 8.15.15 Defense-In -Depth

1. Fire Prevention The object of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.

The noteworthy ignition sources in proximity to the raceway containing the cables for EGHV0016 and EGHV0054 are included in the ignition source Zone of Influence review documented in Tables 8.15.15.1-1 and 8.15.15.1-2. This review also includes a postulated transient combustible fire source and corresponding heat release rate consistent with NRC Inspection Manual 0609 Appendix F guidance. The Table 8.15.15.1-2 results reveal that the fixed ignition source and the postulated transient combustible ignition source are not within the Zone of Influence for the cable tray stack containing the target cable. There is reasonable assurance that a credible fire event within the area would not result in fire induced equipment mal-operation warranting OMA implementation.

As discussed in Section 5.1.15.1.c, the likelihood of a hot work induced fire event requiring OMA implementation is extremely low.

Post-Fire Safe Shutdown Operator Manual Actions Page 146 of 148 WIP-E-1F9900-004-A-1, Rev. I Table 8.15.15.1-1, Photos of Ignition Sources and Targets Ignition Source and Target Photo Comments Information Igqnition Source The minimum distance of 4U3A from the cable PG20G tray stack to the north is Description - 480 Volt MCC 3'.

Cabinet Height from Floor - 92" Horizontal Distance to Target - 96" Ignition source is not Vertical Distance to Target - 60" considered near a wall Distance to West Wall - 94" or corner when applying NRC Inspection Manual 0609 Appendix F Target guidance.

Bottom tray (at elevation 2037'-8") in stack containing 4U3A

Post-Fire Safe Shutdown Operator Manual Actions Page 147 of 148 WIP-E-1F9900-004-A-1, Rev. 1 Table 8.15.15.1-2, Zone of Influence Review for Ignition Sources and Targets Ignition Target Expected Target Critical Comments Source HRR Distance (ft) Distance (ft)

High H R H R Confidence HRR PG20G Bottom tray 70 kW 5 8 3.5 1.3 Based on the radial separation distance, in stack the cable tray stack containing 4U3A is containing 200kW 5.3 2.1 not within the Zone of Influence for 4U3A PG20G. Additionally, considering the 3' horizontal separation between the tray stack north of 4U3A, a 70/200 kW fire involving the north tray would also not be within the Zone of influence for 4U3A.

Transient Bottom tray 70 kW 9.6 0 3.5 1.3 Based on the vertical separation Combustible fire instack provided, the cable tray stack containing (away from containing 200 kW 5.3 2.1 4U3A is not within the Zone of Influence wall) 4U3A for a transient combustible fire located away from a wall interface.

Transient Bottom tray 70 kW 9.6 0 4.6 1.8 Based on the vertical separation Combustible fire in stack provided, the cable tray stack containing (near wall) containing 200 kW 7.0 3.0 4U3A is not within the Zone of Influence 4U3A for a transient combustible fire located within 2 ft. of a wall interface.

2. Detection Control and Extinguish Fires Smoke detection and a total flooding Halon system are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room. Smoke detection is point addressable, allowing for prompt recognition of fire location. The Halon protection will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and a hose station are provided within the area for manual fire fighting.

The administrative fire impairment controls for this fire area require a continuous fire watch when either automatic detection or the Halon suppression system is inoperable. This ensures fire suppression response will occur in the incipient fire stage during conditions when the active fire protection system elements area out of service.

3. Protection of systems structures and components (SSC) so that fires will not prevent safe shutdown.

Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections II.G.1 or II.G.2. The subject OMAs, coupled with a fire watch are utilized in lieu of passive fire barrier protection to ensure a fire in A-27 does not challenge PFSSD. This is an acceptable alternative measure to direct compliance with 10 CFR 50 Appendix R, Section III.G.2, considering the defense in depth fire prevention, detection, and suppression measures discussed above.

Post-Fire Safe Shutdown Operator Manual Actions Page 148 of 148 WIP-E-1F9900-004-A-1, Rev. 1 8.15.16 Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-27 is feasible.

Reliability was not demonstrated by the analysis. Therefore, the OMAs are considered interim compensatory measures, coupled with a fire watch, until the OMAs are eliminated by the field implementation of change package 012418. These compensatory measures provide reasonable assurance that a fire in Fire Area A-27 will not adversely affect the ability to achieve and maintain safe shutdown.

Post-Fire Safe Shutdown Operator Manual Actions Page A-I of A-2 Attachment A WIP-E-1F9900-004-A-1, Rev. I Attachment A to WIP-E-1 F9900-004-A-1 Summary of OMAs to Achieve and Maintain Hot Standby

Post-Fire Safe Shutdown Operator Manual Actions Page A-2 of A-2 Attachment A WIP-E-1F9900-004-A-1, Rev. 1 Summary of OMAs to Achieve and Maintain Hot Standby Room / Fire Operator Manual Action Area Where A-i A-1I A-16N A-18 A-27 C-7 C-12 C-18 C-21 C-22 C-23 C-24 C-30 C-33 RB OMA Implemented Close valve KAV0201 to fail close letdown valves 1322 / A-25 x X X X X BGLCV0459 and BGLCV0460.

Use local controller ABFHC0002 to control/isolate steam 1509 / A-23 X release through ARV for Steam Generator B Use local controller ABFHCO003 to control/isolate steam 1509 / A-23 X release through ARV for Steam Generator C Isolate air and nitrogen to atmospheric relive valve 1508 / A-23 X ABPV0004 to fail the ARV closed Terminate Train B containment spray by 3302 / C-10 X X X X opening breaker NB0203.

Terminate Train A containment spray by 3301 / C-9 X X X opening breaker NB0102.

Open EGHV0016 and 1401, 1402/

EGHV0054 to support 'B' A-16 X Train CCW lineup

Post-Fire Safe Shutdown Operator Manual Actions Page B1-1 of BI-3 Attachment B1 WIP-E-1F9900-004-A-1, Rev. 1 Attachment B1 to WIP-E-1 F9900-004-A-1 Fire Alarm System Response Time

Post-Fire Safe Shutdown Operator Manual Actions Page B1-2 of B1-3 Attachment B1 WIP-E-1F9900-004-A-1, Rev. 1 NUREG-1805, Fire Dynamics Tools (FDT) was utilized to determine smoke detector response time in areas where fire induced spurious equipment actuation results in the potential need for mitigating action to preserve the analyzed PFSSD success path. The results of the fire modeling effort are applied to the OMA timeline analysis for the respective fire area. The FDT utilized in the fire modeling approach was developed, prepared, and validated by the Nuclear Regulatory Commission (NRC) to provide a consistent, simplified fire modeling approach.

NUREG-1805 FDT "11. Estimating Smoke Detector Response Time" (Version 1805.0), was utilized to determine smoke detector response time (where applicable) when applying a simple fire heat release rate from Appendix F of NRC Inspection Manual 0609 (Table 2.3.1). An example of the FDT is provided in Attachment B2.

Input information necessary for the FDT is as follows:

• Fire Heat Release Rate (kW) - a 70 kW fire was postulated, as it represents lowest kW output fire from generic fire bin types identified in Appendix F Table 2.3.1 of NRC Inspection Manual 0609. A lower intensity fire produces a slower detector response time, which is conservative for application to the OMA timeline. The use of 70 kW as a conservative heat release rate is further substantiated by the intermediate-scale cable burn tests documented in NUREG/CR-6931, where a 200 + kW fire was utilized to assess cable performance when subjected to fire exposure.

• Radial Distance to the Detector (ft) - The radial distance to the detector was postulated to be 15' (half the detector listed spacing) or room radial distance, ifthe room footprint is less than 15' x 15'.

• Height of Ceiling above Top of Fuel (ft) - Distance from ceiling to floor was utilized.

" Ambient air temperature (OF) - The lowest normal temperature identified in EQSD-IV Table 1, was utilized. A lower ambient temperature results in a slower detection response time, which is conservative for application to the OMA timeline.

The input data and resulting detector activation time are summarized in Table B1-1.

The detector activation time identified in the table is the longest detector activation time calculated from the three methods (Alpert, Mowrer, and Milke) rounded up to the next whole minute.

Post-Fire Safe Shutdown Operator Manual Actions Page B1-3 of B1-3 Attachment B1 WIP-E-1F9900-004-A-1, Rev. 1 Table B1-1, Detector Response Time NUREG-1805 FDT "11. Estimating Smoke Detector Response Time" Input Data Detector Fire Area Radial Ambient Activation time Heat Release Distance to Ceiling Temperature (minutes)

Rate (kW) Detector (ft) height (ft) (fF)

A-1 70 15 25 60 8 A-11 70 6 23.33 60 6 A-16N 70 15 20.5 60 4 A-18 70 15 20.5 602 4 A-27 70 15 20.5 603 4 C-7 70 2.9 15.17 60 1 C-12 70 6 15.17 601 1 C-18 70 6 15.33 60 1 C-21 70 15 14.83 601 1 C-22 70 15 12 601 1 C-23 70 6 14.83 601 1 C-24 70 6 14.83 601 1 C-30 70 6 25.33 601 9 C-33 70 6 12 601 1 Notes:

1. Control Building cable chase temperatures are not identified in EQSD-IV Table 1. The low temperature (600F) for the cable spreading rooms was utilized.

2. Auxiliary Building cable chase temperatures are not identified in EQSD-IV Table 1. The low temperature (600 F) for the electrical penetration rooms was utilized.

3. The MG Set Room, 1403, is not identified in EQSD-IV Table 1. The low temperature (60 0 F) for the 2026' corridor rooms, 1402 and 1408, was utilized.

GLTIC01 85 for SGL20 is set for 65 0 F per WCRE-01, TPSD.

Post-Fire Safe Shutdown Operator Manual Actions Page B2-1 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1, Rev. 1 Attachment B2 to WIP-E-1 F9900-004-A-1 Sample FDT Data Sheet NUREG-1 805 FDT "11. Estimating Smoke Detector Response Time"

Post-Fire Safe Shutdown Operator Manual Actions Page B2-2 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1. Rev. I CHAPTER 11. ESTIMATING SMOKE DETECTOR RESPONSE TIME tktREQb, 00

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Post-Fire Safe Shutdown Operator Manual Actions Page B2-4 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1, Rev. 1 METHOD OF MILKE Before esthirratirryJ sirroke tltdefeto reop¢orse trife. stti ad'I elfects Karl loca

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Post-Fire Safe Shutdown Operator Manual Actions Page C-1 of C-3 Attachment C WIP-E-1F9900-004-A-1, Rev. 1 Attachment C to WIP-E-1 F9900-004-A-1 Photos of Equipment Manipulated For Operator Manual Action

Post-Fire Safe Shutdown Operator Manual Actions Page C-2 of C-3 Attachment C WIP-E-1F9900-004-A-1, Rev. I t-nfoto U-Z, Abl-MUUUUZ Photo C-3, ABFHCO003 Photo C-4, KAV1429 VA Photo C-5, KAV1365

Post-Fire Safe Shutdown Operator Manual Actions Page C-3 of C-3 Attachment C WIP-EI-F9900-004-A-1. Rev. I Photo C-8, NB0203 Photo C-10, EGHV0054

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