Text

License Amendment Request (LAR) for Deviation from Fire Protection Requirements
	ML13002A146
Person / Time
Site:	Wolf Creek
Issue date:	12/20/2012
From:	Broschak J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ET 12-0033, TAC ME4757
	Download: ML13002A146 (216)
	v • d • e

W F CREE'K WNUCLEAR OPERATING CORPORATION December 20, 2012 John P. Broschak Vice President Engineering ET 12-0033 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 10-0026, dated September 22, 2010, from T. J.

Garrett, WCNOC, to USNRC

2) Letter ET 10-0031, dated November 22, 2010, from T. J.

Garrett, WCNOC to USNRC

3) Letter dated May 24, 2011, from J. R. Hall, USNRC, to M. W.

Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information Regarding License Amendment Request to Revise the Fire Protection Program (TAC NO.

ME4757)"

4) Letter ET 11-0005, dated June 30, 2011, from R. P. Clemens, WCNOC to USNRC

Subject:

Docket No. 50-482: License Amendment Request (LAR) for Deviation from Fire Protection Requirements Gentlemen:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and 10 CFR 50.91, "Notice for public comment; State consultation," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to the Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). This license amendment request (LAR) is seeking approval by the Commission, pursuant to License Condition 2.C.(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR).

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

ET 12-0033 Page 2 of 4 The proposed changes to the approved fire protection prograrn are based on the Reactor Coolant System (RCS) thermal-hydraulic response (Evaluation SA-08-006) for a postulated control room fire performed for changes to the alternative shutdown methodology outlined in letter SLNRC 84-0109, "Fire Protection Review." Drawing E-1F9915, "Design Basis Document for OFN RP-017, Control Room Evacuation," Revision 4, and Evaluation SA-08-006, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation for a Postulated Control Room Fire," Revision 3, demonstrate the adequacy of the revised alternative shutdown procedure, OFN RP-017. The results of the RCS thermal-hydraulic response identified required changes to the fire protection program as follows:

1. Deviation from the 10 CFR 50, Appendix R, Section III.L.1 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining RCS process variables within those predicted for a loss of normal AC power.

2. Deviation from the 10 CFR 50, Appendix R, Section III.L.2 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining pressurizer level on scale.

3. Revision to USAR Appendix 9.5B include incorporation of drawing E-1F9915 and a deviation from Calculation XX-E-013. Deviation from Calculation XX-E-013, Revision 2, "Post-Fire Safe Shutdown (PFSSD) Analysis," Assumption 3-A-4 regarding application of loss of automatic functions, specific to automatic feedwater isolation in the event of a control room fire. Calculation XX-E-013 is incorporated by reference in USAR Appendix 9.5B, "Fire Hazards Analyses."

Attachment I provides the evaluation and justification for the proposed license amendment.

Attachment II provides a markup of License Condition 2.C.(5) reflecting the issuance of an amendment to the license condition. Attachment III provides markups of the USAR including Appendix 9.5B and 9.5E. USAR Appendix 9.5E provides a design comparison to 10 CFR 50 Appendix R. Attachment IV provides markups of the changes to Calculation XX-E-013.

Attachment V provides a drawing of the control room layout. The Enclosure provides a copy of drawing E-1F9915, Revision 4.

Reference 1 provided WCNOC's LAR to make changes to the approved fire protection program as described in the WCGS USAR. Specifically, a revision to USAR Table 9.5E-1 was proposed to include information on RCS process variables not maintained within those predicted for a loss of normal AC power as evaluated in Evaluation SA-08-006, Revision 1. Reference 2 provided supplemental information necessary to enable the Nuclear Regulatory Commission (NRC) staff to make an independent assessment regarding the acceptability of the proposed amendment. Reference 3 provided a request for additional information related to the LAR. In preparing the information to support a response to Reference 3, further review of Evaluation SA-08-006, Revision 1, identified a number of discrepancies with the assumptions utilized.

Based on these discrepancies, Reference 4 withdrew that LAR.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92 "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b),

ET 12-0033 Page 3 of 4 no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The amendment application was reviewed by the WCNOC Plant Safety Review Committee. In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated Kansas State official.

WCNOC requests approval of this proposed amendment by December 31, 2013. Once approved, the amendment will be implemented within 90 days of issuance.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4085, or Mr. Michael J. Westman at (620) 364-8831 ext. 4009.

Sincerely,

ý- d401 M

John P. Broschak JPB/rlt Attachment I - Evaluation of Proposed Change Attachment II - Markup of Renewed Facility Operating License Attachment Ill - Markup of USAR Pages Attachment IV- Markup of Calculation XX-E-013 Attachment Control Room Layout Enclosure Drawing E-1F9915, Revision 4, "Design Basis Document for OFN RP-017, Control Room Evacuation" cc: E. E. Collins (NRC), w/a, w/e T. A. Conley (KDHE), w/a, w/e C. F. Lyon (NRC), w/a, w/e N. F. O'Keefe (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

ET 12-0033 Page 4 of 4 STATE OF KANSAS )

COUNTY OF COFFEY )

John P. Broschak, 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.

Joh , Broschak Vi eoaresident Engineering SUBSCRIBED and sworn to before me this O9 day of I bc, ,2012.

Notary Oublic f~GAYLE SIHEPHEARD Ncla~ry Public - State of Kansas ExcIre'72' Expiration Date '__/__/A,9a

Attachment I to ET 12-0033 Page 1 of 34 Evaluation of Proposed Change

Subject:

License Amendment Request (LAR) for Deviation from Fire Protection Requirements

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION 3.1 Proposed Change to License Condition 2.C.(5) 3.2 Proposed Change to Updated Safety Analysis Report (USAR) Appendix 9.5E, Response to Section III.L.1 3.3 Proposed Change to USAR Appendix 9.5E, Response to Section III.L.2 3.4 Revision to USAR Appendix 9.5B 3.5 Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation 3.6 Conclusions

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Attachment I to ET 12-0033 Page 2 of 34 EVALUATION

1.

SUMMARY

DESCRIPTION The proposed amendment request is requesting Nuclear Regulatory Commission (NRC) approval, pursuant to License Condition 2.C.(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). This evaluation supports a request to amend Renewed Facility Operating License NPF-42 for the Wolf Creek Generating Station (WCGS). The proposed changes to the approved fire protection program are based on the Reactor Coolant System (RCS) thermal-hydraulic response (Evaluation SA-08-006) for a postulated control room fire performed for changes to the alternative shutdown methodology outlined in letter SLNRC 84-0109 (Reference 1), "Fire Protection Review." Drawing E-1F9915 (Reference 2), "Design Basis Document for OFN RP-01 7, Control Room Evacuation," Revision 4, and Evaluation SA-08-006 (Reference 3), "RETRAN-3D Post-Fire Safe Shutdown (PFSSD)

Consequence Evaluation for a Postulated Control Room Fire," Revision 3, demonstrate the adequacy of the revised alternative shutdown procedure, OFN RP-017 (Reference 4). The results of the RCS thermal-hydraulic response identified required changes to the fire protection program as follows:

Deviation from the 10 CFR 50, Appendix R, Section III.L.1 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining RCS process variables within those predicted for a loss of normal AC power.

Deviation from the 10 CFR 50, Appendix R, Section III.L.2 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining pressurizer level on scale.

Revision to USAR Appendix 9.5B to include incorporation of drawing E-1F9915 and a deviation from Calculation XX-E-01 3. Deviation from Calculation XX-E-01 3 (Reference 5),

Revision 2, "Post-Fire Safe Shutdown (PFSSD) Analysis," Assumption 3-A-4 regarding application of loss of automatic functions, specific to automatic feedwater isolation in the event of a control room fire. Calculation XX-E-013 is incorporated by reference in USAR Appendix 9.5B, "Fire Hazards Analyses."

The proposed changes have been determined to adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Therefore, prior Commission approval is required asSection III.L.1 and Section III.L.2 of Appendix R is not directly satisfied.

2. DETAILED DESCRIPTION This amendment application contains a proposed change to the Renewed Facility Operating License and changes to the fire protection program as described in the USAR.

Attachment I to ET 12-0033 Page 3 of 34 2.1 Proposed changes to License Condition 2.C.(5)

License Condition 2.C.(5)(a) currently states:

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No. 191, and Amendment No. 193 subject to provisions b and c below.

License Condition 2.C.(5)(a) is revised to state:

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No. 191, Amendment No. 193, and Amendment No. XXX subject to provisions b and c below.

The proposed change reflects the approved fire protection program based on the issuance of the license amendment approving the proposed change. The amendment number will be reflected in the license condition upon the issuance of the amendment.

2.2 Proposed Change to USAR Appendix 9.5E, Response to Section III.L.1.

The WCGS response to Section III.L.1 in USAR Table 9.5E-1 (Sheet 25), is revised by adding the following statement:

The performance criteria of III.L.1 are satisfied, with the exception of maintaining reactor process variables within those predicted for a loss of normal ac power. This is acceptable, as long as a control room fire will not result in the plant reaching an unrecoverable condition, which could lead to core damage. The criteria for "not reaching an unrecoverable condition" are that 1) natural circulation is maintained, and 2) adequate core cooling is maintained (average hot leg temperature remains at or below normal full power temperature -630 0 F).

2.3 Proposed Change to USAR Appendix 9.5E, Response to Section III.L.2 The WCGS response to Section III.L.2 in USAR Table 9.5E-1 (Sheet 25), is revised by adding the following statement:

In general, the performance goals of III.L.2 are satisfied except that in some cases pressurizer water level is not maintained within level indication. This is acceptable since the evaluation demonstrates that unrecoverable conditions are not reached.

Attachment I to ET 12-0033 Page 4 of 34 2.4 Proposed Change to Calculation XX-E-013 (USAR Appendix 9.5B)

Calculation XX-E-01 3, Assumption 3-A-4 currently states:

For fire in areas requiring alternative shutdown capability (i.e., where control room evacuation may be necessary), a loss of automatic functions is assumed. For example, in the event of a loss of offsite power the emergency diesel generators will normally start automatically on undervoltage. However, in developing the alternative shutdown, capability of this automatic feature to operate is not assumed.

Basis: NRC Generic Letter 86-10, Response to Question 3.8.1; NEI 00-01, Rev. 2, Paragraph 3.3.1.1.4.1 Assumption 3-A-4 is revised as follows:

For a fire in areas requiring alternative shutdown capability (i.e., control room), loss of automatic function of valves and pumps with control circuits that could be affected by a control room fire is assumed, except that an automatic feedwater isolation signal (FWIS) is unaffected by a fire in the control room.

Basis: NRC Generic Letter 86-10, Response to Question 3.8.4; NEI 00-01, Rev. 2, Paragraph 3.3.1.1.4.1; License Amendment XXX (amendment number to be incorporated based on NRC approval of this application)

3. TECHNICAL EVALUATION Letter SLNRC 84-0109 is the original response strategy for shutting down the plant and maintaining a safe hot standby condition from outside the control room in the event of a fire in the control room. This letter is part of the approved fire protection program because the response strategy is described, in detail, in NUREG 0881 Supplement 5, "Safety Evaluation Report related to the operation of the Wolf Creek Generating Station Unit No. 1," (Reference 6), Section 9.5.1.5.

However, there was no technical basis supporting the actions and response times. The strategy was developed based on operator knowledge and experience at the time.

Procedure OFN RP-017 implements the response plan for fire in the control room but differs from letter SLNRC 84-0109 and the response strategy in NUREG 0881 Supplement 5. The technical basis for the response plan in OFN RP-017 is documented in drawing E-1F9915, "Design Basis Document for OFN RP-017, Control Room Evacuation," Revision 4. This drawing, along with various inputs, provides the technical basis for each action step and response time in the procedure and shows that the plant can be safely brought to a hot standby condition using procedure OFN RP-017.

WCNOC proposes to establish drawing E-1F9915 as the new license basis for the procedure OFN RP-017 for shutting down the plant from outside the control room in case of a fire. Drawing E-1F9915 maintains the original philosophical approach for achieving and maintaining safe shutdown as discussed in letter SLNRC 84-0109 by manually manipulating equipment per an approved procedure. The procedure directs operators to take actions, regardless of the status of plant equipment, to avoid or mitigate undesirable events.

Attachment I to ET 12-0033 Page 5 of 34 The approved fire protection program is revised to modify the response strategy described in NUREG 0881 Supplement 5 to the response strategy described in drawing E-1F9915. The response strategy is encompassed in procedure OFN RP-017 with the technical basis provided in drawing E-1F9915.

Additionally, as a result of the development of drawing E-1F9915 and supporting evaluation, it has been identified that some requirements of Section III.L of Appendix R are not met. WCNOC proposes to revise USAR Table 9.5E-1 to document the deviations from the requirements of Appendix R. The proposed changes have been determined to adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Therefore, prior Commission approval is required asSection III.L.1 and Section III.L.2 of Appendix R are not directly satisfied.

Design Basis Function The post-fire safe shutdown design basis for WCGS is the cold shutdown operational mode (Mode 5). In the event that a fire occurs in the plant, which is determined to warrant the plant being brought to a cold, depressurized condition, the plant will be taken immediately to a hot standby condition and then taken to cold shutdown. The time to achieve cold shutdown is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for control room fires. For fires outside the control room, repairs to cold shutdown equipment need to be made within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

10 CFR 50 Appendix R, Section ll.L, "Alternative and dedicated shutdown capability," specifies that alternative or dedicated shutdown capability provided for a specific fire area shall be able to:

(a) achieve and maintain subcritical reactivity conditions in the reactor; (b) maintain reactor coolant inventory; (c) achieve and maintain hot standby conditions for a PWR (d) achieve cold shutdown conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; arid (e) maintain cold shutdown conditions thereafter.

In order to meet the above criteria, the following functions must be available following any fire in the plant:

1. reactivity control function;

2. reactor inventory makeup function; and

3. decay heat removal function.

Associated with the above functions is process monitoring instrumentation and other support systems needed to make the function available.

Background

The WCGS USAR, Appendix 9.5E, provides a comparison of the WCGS Fire Protection Program against the requirements of Section III of Appendix R to 10 CFR 50. Although WCGS obtained its operating license after January 1, 1979, the NRC stated, in NUREG 0881 (Reference 7),

"Safety Evaluation Report related to the operation of Wolf Creek Generating Station, Unit No. 1,"

Attachment I to ET 12-0033 Page 6 of 34 that they will condition the WCGS operating license to require WCGS to meet the technical requirements of Appendix R to 10 CFR 50, or provide equivalent protection. However, the license condition never appeared in the WCGS full power operating license when it was issued on June 4, 1985. Therefore, although Appendix R does not apply, WCGS's commitment to Appendix R is established in Appendix 9.5E as part of the approved fire protection program documented in the USAR.

During an NRC audit of fire protection during the week of July 30, 1984 assumptions applied in the control room fire hazards analysis were questioned. The concern resulted in meetings involving Standardized Nuclear Unit Power Plant System (SNUPPS), WCGS, Callaway Plant, and the NRC in August 1984 to resolve the issues. Meetings were on August 10, 14, 15, and 22. As a result of the meetings, SNUPPS developed letter SLNRC 84-0109 (Reference 1) which documented the SNUPPS "Response Plan for Immediate Evacuation of the Control Room Due to Fire." Letter SLNRC 84-109 addressed spurious actuations and established Phases A through F actions to be taken to mitigate the consequences of a fire in the control room.

After the 2005 NRC triennial fire protection inspection, significant changes to the alternative shutdown methodology were implemented in procedure OFN RP-017. Additionally, drawing E-1F9915, Revision 0, and Evaluation SA-08-006, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD)

Consequence Evaluation for a Postulated Control Room Fire," Revision 0, were developed to demonstrate the adequacy of the revised altemative shutdown procedure. These evaluations predicted that a fire in the control room, which led to control room abandonment and caused a single pressurizer power operated relief valve (PORV) to spuriously open, could cause a steam bubble and subsequent void in the reactor vessel head. USAR Table 9.5E-1 was revised to include the following paragraph:

Analysis demonstrates that the performance goals of III.L.2 are satisfied. The performance criteria of III.L.1 are also satisfied, with the exception of maintaining reactor process variables within those predicted for a loss of normal ac power. This is acceptable, as long as a control room fire will not result in the plant reaching an unrecoverable condition, which could lead to core damage.

During the 2008 NRC triennial fire protection inspection, the team identified an unresolved item related to this change to the fire protection program. The team was concemed that the licensee changed the fire protection program in a manner that could adversely affect the ability to achieve and maintain safe shutdown in the event of a fire without prior NRC approval. Subsequently, the NRC identified this as noncited violation 05000482/2009004-08 (Reference 8).

In response to the NRC finding, WCNOC submitted a license amendment request (Reference 12) to make changes to the approved fire protection program as described in the WCGS USAR.

Specifically, a revision to USAR Table 9.5E-1 was proposed to include information on RCS process variables not maintained within those predicted for a loss of normal AC power as evaluated in Evaluation SA-08-006, Revision 1. WCNOC letter ET 10-0031 (Reference 13) provided supplemental information necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment. On May 24, 2011, a request for additional information (Reference 14) was issued related to the amendment request.

In preparing the information to support a response to request for additional information, further review of Evaluation SA-08-006, Revision 1, identified a number of discrepancies with the assumptions utilized. Based on these discrepancies, WCNOC letter ET 11-0005 withdrew the license amendment request.

Attachment I to ET 12-0033 Page 7 of 34 WCGS Fire Protection Program License Basis The WCGS fire protection program license basis for alternative shutdown can be found in the following documents:

1. WCGS Renewed Facility Operating License NPF-42, Condition 2.C.(5), Fire Protection,

2. NUREG 0881 Supplement No. 5, and

3. WCGS USAR, Section 9.5.1, Appendix 9.5B, and Appendix 9.5E.

WCGS Renewed Facility Operating License NPF-42, Section 2.C.(5) conditions the operating license as follows regarding fire protection:

(5) Fire Protection (Section 9.5.1. SER, Section 9.5.1.8. SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, and as approved in the SER through Supplement 5, Amendment No. 191, and Amendment No. 193 subject to provisions b and c below.

(b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only ifthose changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted The changes described herein adversely affect the ability to achieve and maintain safe shutdown in the event of a fire and, therefore, prior Commission approval is required.

NUREG 0881 (referred to as SER), Section 9.5.1.7, states the following regarding compliance with 10 CFR 50, Appendix R:

"9.5.1.7 Appendix R Statement On October 27. 1980, the Commission approved a rule concerning fire protection. Although this rule and its Appendix R are not directly applicable to Wolf Creek, the requirements set forth in Appendix R are being used as guidelines in licensing plants after January 1, 1979.

On April 27, 1981, the Commission required that Operating Licenses issued after January 1, 1979, contain a condition requiring compliance with commitments made by an applicant and agreed to by the staff after differences between the applicant's program and the guidelines set forth in Appendix A to BTP 9.5-1 and Appendix R to 10 CFR 50 have been identified and evaluated.

The applicant has provided in the FSAR an evaluation of how he meets Appendix R and identified any exceptions. The staff is continuing to review the information. The staff will

Attachment I to ET 12-0033 Page 8 of 34 condition the operating license to require the applicant to meet the technical requirements of Appendix R to 10 CFR 50, or provide equivalent protection."

Although the fire protection conditions in Section 2.C.(5) were not revised to include a specific Appendix R license condition, Section 2.C.(5)(a) references the SER, through Supplement 5 and, therefore, the above SER statement is considered a license condition by reference.

3.1 Proposed Change to License Condition 2.C.(5)

The proposed change reflects the approved fire protection program based on the issuance of the license amendment approving the proposed change. The amendment number will be reflected in the license condition upon the issuance of the amendment.

3.2 Proposed Change to USAR Appendix 9.5E, Response to Section III.L.1 Appendix R, Section IlI.L.1 states the following:

"Alternative or dedicated shutdown capability provided for a specific fire area shall be able to (a) achieve and maintain subcritical reactivity conditions in the reactor; (b) maintain reactor coolant inventory; (c) achieve and maintain hot standby2 conditions for a PWR (hot shutdown 2 for a BWR); (d) achieve cold shutdown conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and (e) maintain cold shutdown conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal AC power, and the fission product boundary integrity shall not be affected; i.e.,

there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary.

2As defined in the Standard Technical Specifications."

One of the requirements listed in Appendix R, Section lII.L.1 is that the process variables shall be maintained within those predicted for a loss of normal AC power. This general requirement may not be met for all transients for two reasons:

1) Some of the transients evaluated have off-site power available and do not represent the transient characteristics of a normal loss of AC power.

2) The PFSSD analysis assumes a loss of off-site power in some scenarios coupled with one spurious operation (failure) and no automatic actuation of safety components.

These two additional conservative assumptions ensure the transient will be more severe than a loss of normal AC power.

Thus, the response of the process variables to these accident conditions cannot be bounded by the loss of normal AC transient results. However, in all scenarios, adequate core cooling is maintained, natural circulation flow through the core is maintained, and the plant reaches safe shutdown conditions.

Attachment I to ET 12-0033 Page 9 of 34 3.3 Proposed Change to USAR Appendix 9.5E, Response to Section III.L.2 Appendix R,Section III.L.2 states the following:

"The performance goals for the shutdown functions shall be:

a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.

b. The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PWRs.

c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

d. The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.

e. The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions."

Evaluation SA-08-006, Revision 3, demonstrates that the performance goals of Appendix R,Section III.L.2, are generally satisfied. Section 3.5 provides the results of Evaluation SA-08-006.

In one evaluated event (Scenario 3A), pressurizer water level is not maintained within level indication as required by Section III.L.2.b. This is acceptable since the evaluation demonstrates natural circulation is maintained and adequate core cooling is maintained. As such, an unrecoverable condition is not reached.

3.4 Revision to USAR Appendix 9.5B USAR Appendix 9.5B is being revised to include incorporation of drawing E-1F9915 and a deviation from Calculation XX-E-013. Incorporation of drawing E-1F9915 into USAR Appendix 9.5B incorporates the revised alternate shutdown methodology into the fire protection program.

Calculation XX-E-01 3, Revision 2, Assumption 3-A-4 states:

"For fire in areas requiring alternative shutdown capability (i.e., where control room evacuation may be necessary), a loss of automatic functions is assumed. For example, in the event of a loss of offsite power the emergency diesel generators will normally start automatically on undervoltage. However, in developing the alternative shutdown, capability of this automatic feature to operate is not assumed.

Basis: NRC Generic Letter 86-10, Response to Question 3.8.1; NEI 00-01, Rev. 2, Paragraph 3.3.1.1.4.1" Contrary to this assumption, Evaluation SA-08-006 assumes that an automatic feedwater isolation signal (FWIS) will occur in response to a reactor trip with low Tavg or abnormal steam generator level. As a result of a non-cited violation documented in the 2011 NRC Triennial Fire

Attachment I to ET 12-0033 Page 10 of 34 Protection Inspection Report 05000482/2011007 (Reference 9), the WCGS fire protection program cannot take sole credit for main steam isolation valve (MSIV) closure using the hand switches in the main control room. Closing the MSIVs stops main steam flow to the feedwater pump turbines and stops the main feedwater pumps. However, with the main feedwater pumps continuing to operate, the steam generators overfill in a matter of minutes, which is insufficient time for operators to take action to stop the pumps. Therefore, WCNOC requests a deviation to credit the automatic MWIS for closure of the feedwater isolation valves to stop main feedwater flow and prevent steam generator overfill. The basis for acceptance of this deviation is discussed below.

A FWIS occurs on one of the following signals:

Reactor Trip with 2/4 Low Tavg (564°F)

2/4 Hi-Hi (78 %) Steam Generator Level on 1/4 Steam Generators

2/4 Lo-Lo (23Y %) Steam Generator Level on 1/4 Steam Generators 0 Safety Injection Signal (SIS)

The control room cabinets that contain controls associated with the FWIS are:

SB038 - Protection Set I

" SB042 - Protection Set II

SB037 - Protection Set III

SB041 - Protection Set IV

SB029A/B/C - Train A Solid State Protection System (SSPS)

" SB030NB - Train A SSPS Test Cabinet

SB032A/B/C - Train B SSPS

" SB033A/B - Train B SSPS Test Cabinet RCS temperature is monitored by the following temperature elements:

" Loop 1 - BBTE0411B (Cold Leg), BBTE04llAl (Hot Leg), BBTE0411A2 (Hot Leg) and BBTE0411A3 (Hot Leg)

" Loop 2 - BBTE0421B (Cold Leg), BBTE0421A1 (Hot Leg), BBTE0421A2 (Hot Leg) and BBTE0421A3 (Hot Leg)

Loop 3 - BBTE0430B (Cold Leg), BBTE0431A1 (Hot Leg), BBTE0431A2 (Hot Leg) and BBTE0431A3 (Hot Leg)

" Loop 4 - BBTE0441B (Cold Leg), BBTE0441A1 (Hot Leg), BBTE0441A2 (Hot Leg) and BBTE0441A3 (Hot Leg)

Signals from these temperature elements are processed in the applicable protection cabinet for that loop (SB038 - Loop 1, SB042 - Loop 2, SB037 - Loop 3, SB041 - Loop 4). The average temperature of each loop is calculated within the protection cabinet and the output is sent to both trains of SSPS cabinets (SB029A/B/C - Train A and SB032A/B/C - Train B). Low Tavg on two out of four loops coincident with a reactor trip generates a FWIS.

A credible fire in the control room could affect two of the four protection cabinets or one of the SSPS sets based on the control room layout (see Attachment V for the control room layout). The remaining two protection cabinets and remaining SSPS set would be unaffected by the fire.

Therefore, a MWIS would be generated in the event of a reactor trip with Low Tag on 2/4 loops and the feedwater isolation valves close.

Attachment I to ET 12-0033 Page 11 of 34 Steam generator (SG) level is monitored by the following level instruments:

SG 'A' - AELT0517, AELT0518, AELT0519, AELT0551

SG 'B' - AELT0527, AELT0528, AELT0529, AELT0552

SG 'C' - AELT0537, AELT0538, AELT0539, AELT0553

SG 'D'- AELT0547, AELT0548, AELT0549, AELT0554 Signals from AELT0551, AELT0529, AELT0539 and AELT0554 are processed in Protection Set I cabinet SB038.

Signals from AELT0519, AELT0552, AELT0553 and AELT0549 are processed in Protection Set II cabinet SB042.

Signals from AELT0518, AELT0528, AELT0538 and AELT0548 are processed in Protection Set III cabinet SB037.

Signals from AELT0517, AELT0527, AELT0537 and AELT0547 are processed in Protection Set IV cabinet SB041.

Each protection cabinet sends an output signal to both trains of SSPS cabinets (SB029A/B/C -

Train A and SB032A/B/C - Train B). Loss of 1 train of protection cabinets or 1 train of SSPS cabinets would not prevent a FWIS on Hi-Hi or Lo-Lo SG level. Based on the control room layout, these cabinets have physical separation that would prevent a credible fire from affecting both trains. Therefore, there is reasonable assurance that a credible fire in the control room will not affect both trains of SG level FWIS.

The physical separation between redundant divisions of MWIS circuits in the control room meets the requirements of IEEE 384-1974. The NRC in Regulatory Guide 1.75, "Physical Independence of Electrical Systems," dated September 1978, has endorsed this standard. The physical separation provides reasonable assurance that a single spurious operation or signal due to a fire will not affect both divisions of MWIS and that one division of FWIS will remain available to isolate feedwater upon receipt of one of the four feedwater isolation signals.

Control Room Cabinet Fire Testing Fire tests of representative samples of control room cabinets were conducted in the mid-1980s and the results are reported in NUREG/CR-4527 (Reference 16), "An Experimental Investigation of Internally Ignited Fires in Nuclear Power Plant Control Cabinets: Part 1: Cabinet Effects Tests."

The results of this test program show that severe fires in vertical control cabinets will not spread to adjacent cabinets where !EEE-383 qualified and unqualified cable is used and where the cabinets are separated only by the metal enclosure of each cabinet forming a double wall metal barrier. In these tests, the cabinets were placed side-by-side leaving only a 1-inch air gap between cabinets.

The following observation was made in NUREG/CR-4527 regarding test Preliminary Cabinet Test (PCT) #2:

"PCT #2 demonstrated that for a vertical cabinet with open doors and with an in situ fuel loading of unqualified cable that appears similar to real fuel loadings in nuclear power plants, the fire will develop and spread rapidly throughout the burning cabinet. However,

Attachment I to ET 12-0033 Page 12 of 34 even a fire as large as this did not have a significant thermal effect (i.e. temperature rise that could result in melting of cables or components) on the adjacent cabinets in the configuration tested."

During PCT #2, thermocouple readings inside the test cabinet reached as high as 1,7421F, whereas the adjacent cabinet wall temperature only reached 5361F. The air temperature inside the adjacent cabinet reached 1800 F. IEEE-383 qualified cable has a damage threshold of approximately 700 0 F. Therefore, the temperatures experienced in the adjacent cabinet would not have been sufficient to damage the cables in that cabinet.

It should be noted that PCT #2 was performed with the cabinet doors open, which results in a higher heat release rate (HRR) than with the doors closed. This represents the most severe condition for the test. At WCGS, the cabinet doors are not open during normal operation and are alarmed to alert operators of them being opened. Also, WCGS uses IEEE-383 qualified cable, which resulted in a much lower fire severity when compared to the tests that used unqualified cable. Test PCT #3 studied the effects of a control cabinet fire that uses IEEE-383 qualified cable. The following observation was made regarding this test:

"Preliminary Cabinet Test #3 again showed that a cabinet fire in a vertical cabinet with qualified cable has little potential to propagate and spread throughout a single vertical cabinet. ... with the in situ fuel and configurations tested, a fire in a vertical cabinet with qualified cable is not likely to propagate or result in damage to cable components or equipment outside the cabinet as a result of the thermal environment."

During PCT #3, thermocouple readings were much lower than in test PCT #2. Inside the test cabinet, the air temerature only reached 423 0 F and the adjacent cabinet wall temperature only reached about 212 0 F. The air temperature inside the adjacent cabinet reached 1400 F.

Therefore, the temperatures experienced in the adjacent cabinet were not sufficient to damage the cables in that cabinet.

The test results in NUREG/CR-4527 provide valuable insight for the control room fire scenario discussed in this evaluation. The test results clearly show that under the test configuration studied, a severe fire in one cabinet will not propagate to adjacent cabinets as long as there is at least a double wall metal barrier and 1-inch air gap between the cabinets. It is reasonable to conclude that additional spatial separation further reduces the potential for thermal propagation between cabinets.

The ignition source used in most of the tests was a 2.5 gallon polyethylene bucket containing a 16 oz box of kimwipes and 1 quart of acetone. Some of the kimwipes were crumpled and placed in the bucket and some of the acetone was dumped into the bottom of the bucket to represent a spill. The total heat content of the ignition source was about 68,500 BTUs. This ignition source is extreme compared to the conditions present at WCGS. Administrative controls are in place to prevent the presence of this fuel load inside control room cabinets at WCGS. The only ignition sources inside these cabinets are the IEEE-383 qualified cables that terminate in the cabinets and other cabinet mounted equipment.

The testing also showed that ignition and sustained combustion of qualified cable was difficult even with the ignition source used. A series of 11 smaller scale scoping tests (ST) were preformed to evaluate the ability of the selected ignition source fuels to ignite and propagate a fire in a cable bundle and to select credible in situ fuel fuel packages. These scoping tests also

Attachment I to ET 12-0033 Page 13 of 34 provide valuable insight of the potential fire hazard of qualified and unqualified cable. In test ST

2, only 1 pint of acetone was used in the ignition source package and the fire was not adequate to ignite and propagate a fire in a vertical bundle of qualified cable. In test ST #3, the full quart of acetone was included in the ignition source package and the vertical qualified cable bundle had to be loosened to allow additional air flow and flames through the cables. In this test, the cables ignited and flames propagated up the bundle. As was demonstrated in this test, it was necessary to increase the ignition source fuel and modify the configuration of the cables to achieve the desired test results. At WCGS, cables within control room cabinets are tightly bundled and run in raceway where possible. Therefore, the testing is conservative compared to the WCGS configuration.

Based on the testing reported in NUREG/CR-4527, a credible fire in the control room will not spread out of the cabinet of origin and will not adversely affect cables and components in adjacent cabinets as long as there is a double metal barrier and one inch air gap between cabinets.

A fire starting outside a cabinet was not considered because there are no significant ignition sources or combustibles located outside the cabinets. The back portion of the control room where the critical cabinets are located needs to remain accessible during operation. This along with administrative controls prevents the accumulation of transient combustibles in the area.

Based on a review of the control room layout, a credible fire will not affect both Train A FWIS and Train B FWIS. Therefore, there is reasonable assurance that a FWIS will occur resulting in closure of the feedwater isolation valves.

Licensing Basis for Feedwater Isolation Section 9.5.1.5 of NUREG 0881 Supplement 5 (Reference 6), provides NRC acceptance of the alternative shutdown strategy for a control room fire. The strategy was presented in letter SLNRC 84-0109 dated August 23, 1984 (Reference 1). In that letter, SNUPPS outlined the strategy for bringing the reactor to a safe and stable hot standby condition from outside the control room. Key observations from that letter related to feedwater are listed below:

1. The alternative shutdown strategy in SLNRC 84-0109 took no actions to isolate main feedwater.

2. MSIVs are closed in Phase D, which is a 30 minute action.

3. Isolation of the MSIVs was the only action taken in SLNRC 84-0109 that would have isolated main feedwater.

4. SG overfill did not appear to be an immediate concern in SLNRC 84-0109.

The NRC, in NUREG 0881 Supplement 5, accepted the alternative shutdown strategy with no specific actions taken to isolate main feedwater by the closure of the feedwater isolation valves.

In addition, isolation of MSIVs was accepted as a 30 minute action. WCNOC procedure OFN RP-017 currently isolates the main steam and main feedwater isolation valves in less than 3 minutes.

Attachment I to ET 12-0033 Page 14 of 34 As discussed above, feedwater isolation is not part of the WCGS license basis for alternative shutdown because it was not included as an action in SLNRC 84-0109. Furthermore, the NRC accepted the safe shutdown procedure presented in SLNRC 84-0109 as indicated in NUREG 0881, Supplement 5.

3.5 Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation Evaluation SA-08-006, Revision 3, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD)

Consequence Evaluation for a Postulated Control Room Fire," (Reference 3) documents the basis of the WCGS RCS thermal-hydraulic response to different scenarios potentially caused by a fire in the control room. Twenty-four control room fire scenarios were chosen to address a spurious actuation that could result in significant RCS mass inventory loss, significant RCS pressure reduction, and pressurizer overfill. These scenarios were developed by evaluating various potential scenarios on the simulator, iterating on assumed failures, and selecting the cases that would result in a maximum RCS mass inventory loss and pressure reduction following an uncontrolled cool down of the primary system.

All scenarios assume a single spurious operation failure in conjunction with and without a loss of off-site power and with and without an auxiliary feedwater actuation signal (AFAS). The AFAS was modeled since it could adversely impact PFSSD due to the potential for uncontrolled cool down. No automatic actions were assumed unless it adversely impacted the transient except for automatic feedwater isolation.

The 24 bounding scenarios evaluated, shown in Table 1, can be grouped into three categories and are summarized as follows:

1. Spurious behavior of pressurizer PORV failed open;

2. Spurious behavior of SG atmospheric relief valves (ARVs) failed open; and

3. Spurious uncontrolled letdown.

Table I - Summary of Transient Scenarios Automatic Off-Site Safety Scenario Spurious Operation AFW Pump Power Injection Failure Auto Start Aabe Sign Available Signal Available 1 Failed Open Pressurizer PORV 1A Failed Open Pressurizer X PORV 1B Failed Open Pressurizer X PORV lC Failed Open Pressurizer X X PORV

Attachment I to ET 12-0033 Page 15 of 34 Table I - Summary of Transient Scenarios (cont.)

Automatic Spurious Operation AFW Pump Off-Site Safety Scenario Failure Auto Start Power Injection Available Signal Available 2 Failed Open Pressurizer X PORV 2A Failed Open Pressurizer X X PORV 2B Failed Open Pressurizer X X PORV 2C Failed Open Pressurizer X X X PORV 3 Failed Open SG ARV 3A Failed Open SG ARV X 3B Failed Open SG ARV X 3C Failed Open SG ARV X X 4 Failed Open SG ARV X 4A Failed Open SG ARV X X 4B Failed Open SG ARV X X 4C Failed Open SG ARV X X X 5 Letdown Open 5A Letdown Open X 6 Letdown Open X 6A Letdown Open, No X Pressurizer Heaters 6B Letdown Open, No X Pressurizer Heaters, Pressurizer Spray On 6C Letdown Open X X 6D Letdown Open, No X X Pressurizer Heaters 6E Letdown Open, No X X Pressurizer Heaters, Pressurizer Spray On

Attachment I to ET 12-0033 Page 16 of 34 The RETRAN-3D Input Model The results presented in Evaluation SA-08-006 were developed using a four-loop best-estimate RETRAN-3D model of the plant used in the RETRAN-02 mode. The only exception to the RETRAN-02 mode was that the Chexal-Lellouche drift flux model option was used to better represent depleted mass distributions on the steam generator secondary and to simulate vapor collecting in the upper regions of the RCS should boiling occur. By using a model to simulate vapor and liquid phase separation (unequal velocities), the evaluation allows the vapor to collect in the upper tube primary region, and RCS vessel, which enhance the possibility of loop flow stagnation.

The NRC approved the use of RETRAN-02 in the Safety Evaluation Report dated September 30, 1993 (Reference 17), for the WCNOC Topical Report NSAG-006 "Transient Analysis Methodology for the Wolf Creek Generating Station." The NRC has accepted the RETRAN-3D computer code for use in analyzing Chapter 15 accidents and transients subject to some conditions and limitations. This acceptance is documented in a letter from Stuart Richards, NRC, to Gary Vine, EPRI, dated January 25, 2001, entitled "Safety Evaluation Report (SER) on EPRI Topical Report NP-7450(P), Revision 4, "RETRAN-3D - A Program for Transient Thermal-Hydraulic Analysis of Complex Fluid Flow Systems" (TAC No. MA4311)," (Reference 10).

Specifically, Condition 40 of the NRC Safety Evaluation Report states:

40. Organizations with NRC-approved RETRAN-02 methodologies can use the RETRAN-3D code in the RETRAN-02 mode, without additional NRC approval, provided that none of the new RETRAN-3D models listed, in the definition are used. Organizations with NRC-approved RETRAN-02 methodologies must obtain NRC approval prior to applying any of the new RETRAN-3D models listed above for UFSAR Chapter 15 licensing basis applications. Organizations without NRC approved RETRAN-02 methodologies must obtain NRC approval for such methodologies or a specific application before applying the RETRAN-02 code or the RETRAN-3D code for UFSAR Chapter 15 licensing basis applications. Generic Letter 83-11 provides additional guidance in this area. Licensees who specifically reference RETRAN-02 in their technical specifications will have to request a Technical Specification change to use RETRAN-3D.

Section 8.0 of the NRC Safety Evaluation Report indicates that use of the Chexal-Lellouche drift flux model will result in the need to assure its use is in conformance with Condition 16. Condition 16 indicates that the results of the analysis using the model must be carefully reviewed. WCNOC has reviewed the results of the model. Additionally, as noted in Condition 40, Evaluation SA 006 is not a USAR Chapter 15 licensing basis analysis.

Evaluation SA-08-006. Revision 3 Results The key results of this evaluation are shown in Table 2. Although not an Appendix R requirement, it is noted in Table 2 whether boiling in the RCS occurs. In Scenarios 1, 1A and 1C minimal boiling occurred in the upper core region for a short period. The only transient scenario that does not meet the Appendix R,Section III.L.2 performance goals is Scenario 3A in which, for a brief period, the pressurizer water level is not maintained within level indication. Scenarios 1, 1A, 1C, and 3A are discussed in further detail below.

Attachment I to ET 12-0033 Page 17 of 34 Table 2 - Results of the Transient Scenarios Cold Core Pressurizer Natural Shutdown Remains Level Circulation RCS Boiling Scenario Achieved Covered Maintained Maintained Prevented 1 Yes Yes Yes Yes No 1A Yes Yes Yes Yes No 1B Yes Yes Yes Yes Yes iC Yes Yes Yes Yes No 2 Yes Yes Yes Yes Yes 2A Yes Yes Yes Yes Yes 2C Yes Yes Yes Yes Yes 2D Yes Yes Yes Yes Yes 3 Yes Yes Yes Yes Yes 3A Yes Yes No Yes Yes 3B Yes Yes Yes Yes Yes 3C Yes Yes Yes Yes Yes 4 Yes Yes Yes Yes Yes 4A Yes Yes Yes Yes Yes 4B Yes Yes Yes Yes Yes 4C Yes Yes Yes Yes Yes 5 Yes Yes Yes Yes Yes 5A Yes Yes Yes Yes Yes 6 Yes Yes Yes Yes Yes 6A Yes Yes Yes Yes Yes 6B Yes Yes Yes Yes Yes 6C Yes Yes Yes Yes Yes 6D Yes Yes Yes Yes Yes 6E Yes Yes Yes Yes Yes Scenario I Discussion Scenario 1 assumes a loss of offsite power with one pressurizer PORV stuck open. A reactor trip occurs at time zero when operators press the reactor trip pushbuttons. The MSIVs are closed by manual operation within 180 seconds after reactor trip. Automatic feedwater isolation occurs on reactor trip with low Tag (564°F). A rapid RCS depressurization occurs due to the reactor trip and the failed open PORV. With the PORV open, a rapid decrease in pressurizer level occurs followed by RCS coolant drawn into the pressurizer creating an increase in pressurizer level.

When the PORV is closed at 180 seconds by operator action the RCS begins to repressurize and

Attachment I to ET 12-0033 Page 18 of 34 the pressurizer level decreases. The following figures from Evaluation SA-08-006 show the pressurizer level and pressure during the Scenario 1 transient.

Scenario 1, Figure 2: Pressurizer Pressure 2

2 0~

0 2

a-0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Scenario 1, Figure 3: Pressurizer Level 100 90-80 -

Close 70- PORV &

MSIV 60

. 50-40 ARVs and CCPs 30-Throttle 20-10- Initiate CCP AFW Off, RCP Trip, MSIV Open 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

The rapid depressurization of the RCS results in minimal upper core boiling between 160 seconds and 770 seconds. The maximum void fraction achieved in the upper core is less than 6.6%. All of the voids are collapsed due to cooling and elevation head prior to reaching the top of the SG tubes so natural circulation is maintained.

Attachment I to ET 12-0033 Page 19 of 34 The following figure from Evaluation SA-08-006 shows the upper core void fraction during the Scenario 1 transient.

Scenario 1, Figure 8: Upper Core Void Fraction 1.U 0.9

-Upper Core Volume 0.8 0.7 C0.6 0_

"g.

0.5 0.4 0.3 0.2 0.1 0.0 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

The following figures from Evaluation SA-08-006 demonstrate that, during the Scenario 1 transient, the RCS loop flows remain in natural circulation and RCS temperature stabilizes.

Scenario 1, Figure 5: Hot Leg Loop Flow 12000 Loop A 10000 Loop B

- Loop 8000 C i Loop D

0 6000

,T 4000 2000 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Attachment I to ET 12-0033 Page 20 of 34 Scenario 1, Figure 4: Core Inlet and Exit Temperature At T=0 PORV Fails Open, -Core Inlet 620- AFW Off, RCP Trip, MSIV Open -Core Outlet PORV, MSIV Closes 600 -

580 560 E

12 540 Starts 520 500 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

After 3000 seconds the RCS pressure, temperature, and pressurizer level have stabilized indicating a safe shutdown condition.

Scenario 1A Discussion Scenario 1A is similar to Scenario 1 with the exception of the AFW pumps auto start for an unplanned cooldown. With the loss of power, the reactor trip occurs at time zero and the reactor coolant pumps (RCPs) coast down. Automatic feedwater isolation occurs on reactor trip with low Tav (564 0 F). The MSIVs are closed by manual operation within 180 seconds after reactor trip. A rapid RCS depressurization occurs due to the reactor trip and the failed open PORV. With the PORV open, a rapid decrease in pressurizer level occurs followed by RCS coolant drawn into the pressurizer creating an increase in pressurizer level. When the PORV is closed at 180 seconds by operator action the RCS begins to repressurize and the pressurizer level decreases.

Attachment I to ET 12-0033 Page 21 of 34 The following figures from Evaluation SA-08-006 show the pressurizer level and pressure during the Scenario 1A transient.

Scenario 1A, Figure 2: Pressurizer Pressure 3000 2500

= 2000 2 1500 1000 500 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Scenario IA, Figure 3: Pressurizer Level I

a.

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

The rapid depressurization of the RCS results in minimal upper core boiling between 180 seconds and 450 seconds. The maximum void fraction achieved in the upper core is less than 2.35%. All of the voids are collapsed prior to reaching the top of the SG tubes so natural circulation is maintained.

Attachment I to ET 12-0033 Page 22 of 34 The following figure from Evaluation SA-08-006 shows the upper core void fraction during the Scenario 1A transient.

Scenario 1A, Figure 8: Upper Core Void Fraction 1.0 0.9

- Upper Core Volume 0.8 0.7 C

0.6 S0.5 0.4 0.3 0.2 0.1 0.0 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

The following figures from Evaluation SA-08-006 demonstrate that, during the Scenario 1A transient, the RCS loop flows remain in natural circulation and RCS temperature stabilizes.

Scenario 1A, Figure 5: Hot Leg Loop Flow 12000 10000 8000 U. 6000 05 I

4000 2000 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Attachment I to ET 12-0033 Page 23 of 34 Scenario 1A, Figure 4: Core Inlet and Exit Temperature At T=0 PORV Opens, 620 AFW On, LOOP

-Core Inlet 600 PORV Closes -Core Outh

/

5Throttle CCP and ARVs 560 -

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

After 3000 seconds the RCS pressure, temperature, and pressurizer level have stabilized indicating a safe shutdown condition.

Scenario IC Discussion Scenario 1C is similar to Scenario 1A with the exception of the AFW pumps auto start for an unplanned cooldown and safety injection is available if required. With the loss of power, the reactor trip occurs at time zero and the RCPs coast down. The MSIVs are manually closed within 180 seconds of reactor trip. Automatic feedwater isolation occurs on reactor trip with low TV0 (5640 F). A rapid RCS depressurization occurs due to the reactor trip and the failed open PORV.

This is followed by a safety injection signal which initiates the centrifugal charging pumps (CCPs) increasing pressurizer level as shown in Scenario 1C, Figure 3.

Attachment I to ET 12-0033 Page 24 of 34 The following figures from Evaluation SA-08-006 show the pressurizer level and pressure during the Scenario IC transient.

Scenario 1C, Figure 2: Pressurizer Pressure 3000 2500 2000 10 2 1500 0j 0.

500 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Scenario 1C, Figure 3: Pressurizer Level 100 90 80 70 60

-J e 50 40 2

0.

30 20 10 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Low RCS pressure after 4800 seconds results in minimal upper core boiling for the period after that time.

Attachment I to ET 12-0033 Page 25 of 34 The maximum void fraction achieved in the upper core is less than 11.2% as shown in the following figure from Evaluation SA-08-006. All of the voids are collapsed prior to reaching the top of the SG tubes.

Scenario 1C, Figure 8: Upper Core Void Fraction 1.0 0.9

-Upper Core Volume 0.8 0.7 0.6 05 0.

,a 0.4 0.3 0.2 0.1 0.0 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

The following figures from Evaluation SA-08-006 demonstrate that, during the Scenario 1C transient, the RCS loop flows remain in natural circulation and RCS temperature stabilizes.

Scenario 1C, Figure 5: Hot Leg Loop Flow 12000 10000 8000 U-U.

-J 6000 0

"1 4000 2000 0

0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Attachment I to ET 12-0033 Page 26 of 34 Scenario 1C, Figure 4: Core Inlet and Exit Temperature 620 600 S580 2 560 E

540 520 50o 1200 2400 3600 4800 6000 7200 Transient Time (wec)

After 6000 seconds the RCS pressure, temperature, and pressurizer level have stabilized indicating a safe shutdown condition.

Scenario 3A Discussion Scenario 3A assumes a loss of offsite power with the SG 'A' ARV stuck open and closes at 3600 seconds. The AFW pumps auto start. A reactor trip occurs at time zero and automatic feedwater isolation occur on reactor trip with low T,,g (5640 F). The MSIVs are manually closed within 180 seconds of reactor trip. The stuck open ARV with AFW flow to the SGs result in a RCS cooldown.

The RCS pressure, temperature, and pressurizer water level initially decrease due to the reactor trip followed by a small rise after the MSIVs close increasing SG pressure and cooling capability.

The uncontrolled AFW flow and stuck open SG 'A' ARV causes excess SG cooling and these RCS parameters continue to decline. Through the first 2000 seconds, SG 'A' pressure is decreasing and is the primary reason the RCS cools. At 840 seconds pressurizer level goes off scale low and returns on scale at 1780 seconds. To verify no voiding occurred in the RCS hot leg, the water level in the pressurizer surge line was examined. The water level in the surge line reached a minimum height of 67% volume for a short period of time and increases with the initiation of CCP flow. Natural circulation is maintained through this time period and the core remains in a controlled safe shutdown condition.

Attachment I to ET 12-0033 Page 27 of 34 The following figures from Evaluation SA-08-006 show the pressurizer level and pressure during the Scenario 3A transient.

Scenario 3A, Figure 2: Pressurizer Pressure 0

1200 2400 3600 4800 6000 7200 Transient Time (sec)

Scenario 3A, Figure 3: Pressurizer Level 100 90 80 70 60

-J e 50 40 30 20 10 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Attachment I to ET 12-0033 Page 28 of 34 The following figures from Evaluation SA-08-006 demonstrate that, during the Scenario 3A transient, the RCS loop flows remain in natural circulation and RCS temperature stabilizes.

Scenario 3A, Figure 5: Hot Leg Loop Flow 12000

- Loop A 10000 -

-Loop B

-Loop 8000- C

-Loop D

U- 6000 -

06 Xe 4000 2000 -

0 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

Scenario 3A, Figure 4: Core Inlet and Exit Temperature

-Core Inlet 620 - -Core Outlet 600-AFW Control 580 F-560-E I--

540-520 -

At T=O RCPs Off, Charging Off, ARV on A SG Open, AFW On 500 0 1200 2400 3600 4800 6000 7200 Transient Time (sec)

After 4800 seconds the RCS temperature and pressurizer level have stabilized indicating a safe shutdown condition.

Attachment I to ET 12-0033 Page 29 of 34 Summary Based on the control room fire scenarios investigated in Evaluation SA-08-006, Revision 3, coupled with the procedural guidance of OFN RP-017 (Reference 4) and OFN RP-017A, "Hot Standby to Cold Shutdown From Outside the Control Room due to a Fire" (Reference 11), the plant will not reach unrecoverable conditions, which could lead to core damage. The pressurizer level remains on scale for all scenarios except Scenario 3A, natural circulation flow is maintained, and average hot leg temperature remains below 6280 F (approximately 100% power steady-state temperature). This demonstrates that safe hot standby and inventory levels can be achieved and maintained using the timing limitations defined in Evaluation SA-08-006. In all cases the reactor core remains cooled and no core damage is indicated, no pressure vessel limits are exceeded, and the reactor reaches a new stable steady-state condition representing safe shutdown.

The results of these transient evaluations may not be bounded by the normal loss of AC power transient because of an additional spurious operation (failure) and no automatic actuation of safety components assumptions. These two additional conservative assumptions ensure the transient will be more severe than a loss of normal AC power. In addition, some of the transients have off-site power available and will have much different results than an AC power loss transient. Thus, they cannot be directly compared.

In only two scenarios, small amounts of voiding occur for a short period of time with a loss of off-site power and a stuck open PORV. Natural circulation and adequate core cooling is maintained throughout the duration of the transient.

3.6 Conclusions It is acceptable to re-baseline the license basis for shutdown of the plant from outside the control room in the case of a fire in the control room from letter SLNRC 84-0109 referenced in NUREG 0881 Supplement 5 to drawing E-1F9915. The present license basis is a letter that has no documented technical basis for the sequence of operator actions. Drawing E-1F9915 is a comprehensive and documented technical basis for the sequence of operator actions in procedure OFN RF-017.

The thermal-hydraulic evaluation results in Evaluation SA-08-006 demonstrate that the control room shutdown capability meets the Appendix R, III.L.1 criteria with one exception. The RCS process variables are not maintained within those predicted for a loss of normal ac power.

Specifically, some voiding is observed in the upper core region in three (Scenarios 1, 1A, and IC) of the 24 scenarios modeled. However, this is acceptable since the evaluation shows that the plant does not reach unrecoverable conditions.

The thermal-hydraulic evaluation also demonstrates that the performance goals of Appendix R,Section III.L.2, are met with one exception. In one analyzed event (Scenario 3A), pressurizer water level falls below the indicated level for a short period of time. This is acceptable because the evaluation also shows that the core remains covered and the plant does not reach unrecoverable conditions.

It is acceptable to credit an automatic FWIS in the event of a fire in the control room. The redundancy and diversity of FWIS initiators in the control room, the physical location of redundant protection cabinets in the control room as well as fire test data associated with control cabinet

Attachment I to ET 12-0033 Page 30 of 34 fires provides reasonable assurance that a single credible fire in the control room will not adversely affect both trains of components necessary to actuate an automatic FWIS.

Based on the above discussion, the proposed changes to the approved fire protection program discussed herein are acceptable as there is reasonable assurance that safe shutdown can be achieved.

4. REGULATORY EVALUATION 4.1 Applicable Reaulatorv Requirements/Criteria 10 CFR 50, Section 48, Fire Protection, paragraph (a)(1) states, in part: "Each holder of an operating license issued under this part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part."

Paragraph (b) states, in part: "Appendix R to this part establishes fire protection features required to satisfy Criterion 3 of appendix A to this part with respect to certain generic issues for nuclear power plants licensed to operate before January 1, 1979."

10 CFR 50, Appendix R, Section III.L.1, states: "Alternative or dedicated shutdown capability provided for a specific fire area shall be able to (a) achieve and maintain subcritical reactivity conditions in the reactor; (b) maintain reactor coolant inventory; (c) achieve and maintain hot standby2 conditions for a PWR (hot shutdown2 for a BWR); (d) achieve cold shutdown conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and (e) maintain cold shutdown conditions thereafter. During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal a.c. power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture of any primary coolant boundary, of rupture of the containment boundary."

10 CFR 50, Appendix R, Section III.L.2, states: "The performance goals for the shutdown functions shall be:

a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.

b. The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PWRs.

c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

d. The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.

e. The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions."

Attachment I to ET 12-0033 Page 31 of 34 10 CFR 50, Appendix A, Criterion 3-Fire protection. Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

4.2 Significant Hazards Consideration The proposed amendment request is requesting Nuclear Regulatory Commission (NRC) approval, pursuant to License Condition 2.C.(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). The proposed changes to the approved fire protection program are based on the Reactor Coolant System (RCS) thermal-hydraulic response (Evaluation SA-08-006) for a postulated control room fire performed for changes to the alternative shutdown methodology outlined in letter SLNRC 84-0109, "Fire Protection Review." Drawing E-1F9915, "Design Basis Document for OFN RP-017, Control Room Evacuation," Revision 4, and Evaluation SA-08-006, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation for a Postulated Control Room Fire," Revision 3, demonstrate the adequacy of the revised alternative shutdown procedure, OFN RP-01 7, "Control Room Evacuation." The results of the RCS thermal-hydraulic response identified required changes to the fire protection program as follows:

" Deviation from the 10 CFR 50, Appendix R, Section III.L.1 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining RCS process variables within those predicted for a loss of normal AC power.

Deviation from the 10 CFR 50, Appendix R, Section 111.L.2 comparison response, as described in Appendix 9.5E of the WCGS USAR, specific to maintaining pressurizer level on scale.

" Revision to USAR Appendix 9.5B to include incorporation of drawing E-1F9915 and a deviation from Calculation XX-E-013. Deviation from Calculation XX-E-013, "Post-Fire Safe Shutdown (PFSSD) Analysis," Revision 2, Assumption 3-A-4 regarding application of loss of automatic functions, specific to automatic feedwater isolation in the event of a control room fire. Calculation XX-E-013 is incorporated by reference in USAR Appendix 9.5B, "Fire Hazards Analyses."

The proposed changes have been determined to adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Therefore, prior Commission approval is required asSection III.L.1 and Section III.L.2 of Appendix R is not directly satisfied.

WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Attachment I to ET 12-0033 Page 32 of 34

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The design function of structures, systems and components (SSCs) are not impacted by the proposed deviations from Appendix R, Sections III.L.1 and IIl.L.2, and Calculation XX-E-013.

The proposed changes to the approved fire protection program are based on the RCS thermal-hydraulic response (Evaluation SA-08-006) for a postulated control room fire performed for changes to the alternative shutdown methodology outlined in letter SLNRC 84-0109, "Fire Protection Review." Drawing E-1F9915, "Design Basis Document for OFN RP-017, Control Room Evacuation," Revision 4, and Evaluation SA-08-006, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation for a Postulated Control Room Fire,"

Revision 3, demonstrate the adequacy of the revised alternative shutdown procedure, OFN RF-017. The proposed changes do not alter or prevent the ability of SSCs from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. Therefore, the probability of any accident previously evaluated is not increased. Equipment required to mitigate an accident remains capable of performing the assumed function.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes will not alter the requirement or function for systems required during accident conditions. The design function of structures, systems and components are not impacted by the proposed change. The thermal-hydraulic evaluation of the RCS determined natural circulation is maintained and adequate core cooling is maintained. The fission product boundary integrity is not affected and safe shutdown capability is maintained.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. The revised alternative shutdown methodology provides the ability to achieve and maintain safe shutdown in the event of a fire. The thermal-hydraulic evaluation of the RCS determined natural circulation is maintained and adequate core cooling is maintained.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Attachment I to ET 12-0033 Page 33 of 34 Based on the above, WCNOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION WCNOC has evaluated the proposed changes and determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. REFERENCES

1. SNUPPS letter SLNRC 84-0109, "Fire Protection Review," from N. A. Petrick, SNUPPS, to H. R. Denton, USNRC, August 23,1984.

2. Drawing E-1F9915, Revision 4, "Design Basis Document for Procedure OFN RP-017, Control Room Evacuation."

3. Evaluation SA-08-006, "RETRAN-3D Post-Fire Safe Shutdown (PFSSD) Consequence Evaluation for a Postulated Control Room Fire," Revision 3, October 17, 2012.

4. Procedure OFN RP-017, Revision 40, "Control Room Evacuation," January 30, 2012.

5. Calculation XX-E-013, Revision 2, "Post Fire Safe Shutdown Analysis," April 11, 2010.

6. NUREG 0881, "Safety Evaluation Report related to the operation of Wolf Creek Generating Station, Unit No. 1," Supplement No. 5, March 1985.

7. NUREG 0881, "Safety Evaluation Report related to the operation of Wolf Creek Generating Station, Unit No. 1," April 1982.

8. NRC letter, "Wolf Creek Generation Station - NRC Integrated Inspection Report 05000482/2009004," November 10, 2009. ADAMS Accession No. ML093140803.

9. NRC letter, "Wolf Creek Generating Station - NRC Triennial Fire Protection Inspection Report (05000482/2011007)," December 27, 2011. ADAMS Accession No. ML11361A427.

Attachment I to ET 12-0033 Page 34 of 34

10. NRC letter from Stuart Richards, NRC, to Gary Vine, EPRI, "Safety Evaluation Report on EPRI Topical Report NP-7450(P), Revision 4, "RETRAN-3D - A Program for Transient Thermal-Hydraulic Analysis of Complex Fluid Flow Systems" (TAC No. MA431 1)," January 25, 2001.

11. Procedure OFN RP-017A, Revision 5, "Hot Standby to Cold Shutdown From Outside the Control Room due to a Fire," June 6, 2012.

12. WCNOC letter ET 10-0026, "License Amendment Request (LAR) for Deviation from Fire Protection Requirements - Reactor Coolant System Subcooling During Alternative Shutdown," September 22, 2010. ADAMS Accession No. ML102720417.

.13. WCNOC letter ET 10-0031, "Response to Supplemental Information Request for License Amendment Request Deviation from Fire Protection Requirements - Reactor Coolant System Subcooling During Alternative Shutdown (TAC NO. ME4757)," November 22, 2010.

ADAMS Accession No. ML103340290.

14. NRC letter from J. R. Hall, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information Regarding License Amendment Request to Revise the Fire Protection Program (TAC NO. ME4757)," May 24, 2011. ADAMS Accession No. ML111380215.

15. WCNOC letter ET 11-0005, "Withdrawal of License Amendment Request to Revise the Fire Protection Program (TAC NO. ME4757)," June 30, 2011. ADAMS Accession No. ML11188A074.

16. NUREG/CR-4527 (Reference 16), "An Experimental Investigation of Internally Ignited Fires in Nuclear Power Plant Control Cabinets: Part 1: Cabinet Effects Tests," April 1987.

17. NRC letter from W. D. Reckley, USNRC, to N. S. Cams, WCNOC, "Wolf Creek Nuclear Operating Corporation - Transient Analysis Methodology for the Wolf Creek Generating Station (TAC NO. M79740)," September 30, 1993.

Attachment II to ET 12-0033 Page 1 of 2 Markup of Renewed Facility Operating License

Attachment If to ET 12-0033 Page 2 of 2 5

(5) Fire Protection (Section 9.5.1. SER, Section 9.5.J.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No. 191, and Amendment No. subject to provisions b and c below.

and Ame (b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted.

(6) Qualification of Personnel (Section 13.1.2. SSER #5, Section 18, SSER

_t)

Deleted per Amendment No. 141.

(7) NUREG-0737 Supplement I Conditions (Section 22, SER)

Deleted per Amendment No. 141.

(8) Post-Fuel-Loading Initial Test Program (Section 14, SER Section 14, SSER #5)

Deleted per Amendment No. 141.

(9) Inservice Inspection Program (Sections 5.2.4 and 6.6. SER)

Deleted per Amendment No. 141.

(10) Emergency Planning Deleted per Amendment No. 141.

(11) Steam Generator Tube Rupture (Section 15.4.4. SSER #5)

Deleted per Amendment No. 141.

(12) LOCA Reanalysis (Section 15.3.7. SSER #5)

Deleted per Amendment No. 141.

Renewed License No. NPF-42 Amendment No. 193

Attachment III to ET 12-0033 Page 1 of 5 Markup of USAR Pages

Attachment III to ET 12-0033 Page 2 of 5 WOLF CREEK APPENDIX 9.5B FIRE HAZARDS ANALYSES The USAR FHA has been superseded by the following documents:

E-1F9905, Fire Hazard Analysis.

" E-1F9900, Post-Fire Safe Shutdown Manual Actions.

E-1F9910, Post-Fire Safe Shutdown Fire Area Analysis.

" XX-E-013, Post-Fire Safe Shutdown (PFSSD) Analysis.

M-663-00017A, Fire Protection Evaluations for Unique or Unbounded Fire Barrier Configurations.

The above documents are incorporated by Reference within the USAR.

9.5B-0 Rev. 19

Attachment III to ET 12-0033 Page 3 of 5 No changes this page WOLF CREEK For information only TABLE 9.5E-1 (Sheet 25) 10CFR50 ADpendix R WCGS covered by any complete shift personnel complement. These duties include command control of the brigade, transporting fire suppression and support equipment to the fire scenes, applying the extinguishant to the fire, communication with the control room, and coordin-ation with outside fire departments.

g. Potential radiological and toxic hazards in fire zones.

h. Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire con-tainment or smoke clearing operations.

i. Operations requiring con-trol room and shift engineer coordination or authorization.

j. Instructions for plant operators and general plant personnel during fire.

III. L. Alternative and Dedicated Shutdown Capability

1. Alternative or dedicated An auxiliary shutdown shutdown capability provided panel, described in for a specific fire area shall Section 7.4, in conjunction be able to (a) achieve and with certain local maintain subcritical reac- controls, provides a means tivity conditions in the of achieving and maintaining reactor, (b) maintain hot standby in the event reactor coolant inventory that the main control room (c) achieve and maintain is uninhabitable.

hot standby"' conditions Rev. 23 I

Attachment III to ET 12-0033 Page 4 of 5 WOLF CREEK TABLE 9.5E-1 (Sheet 26) 10CFR50 An=endix R WCGS for PWR (hot shutdown"' for The auxiliary shutdown a BWR); (d) achieve cold panel contains the con-shutdown conditions within trols and indication 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and (e) maintain necessary to maintain cold shutdown conditions reactor coolant system thereafter. During the inventory, remove decay postfire shutdown, the heat, and provide the reactor coolant system required boration for process variables shall hot standby. Adequate be maintained within operations shift staffing those predicted for loss is provided to achieve and of normal ac power and maintain post-fire safe shut-the fission product down "Hot Standby Conditions" boundary integrity shall in the event of a fire.

not be affected i.e., Cold shutdown can be there shall be no fuel achieved and maintained clad damage, rupture of from outside the control any primary coolant room by additional manual boundary, or rupture operator action at local of the containment control sites.

boundary.

The auxiliary shutdown

2. The performance goals for panel is included in the shutdown functions shall the fire hazards anal-be: ysis, Appendix 9.5B.

a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.

The performance criteria of III.L.I are satisfied, with the exception of maintaining reactor process variables within those predicted for a loss of normal ac power. This is acceptable, as long as a control room fire will not result in the plant reaching an unrecoverable condition, which could lead to core damage. The criteria for "not reaching an unrecoverable condition" are that 1) natural circulation is maintained,*

and 2) adequate core cooling is maintained (average hot leg temperature remains at or below normal full power temperature - 6300F).

v --

7 - As defined in the Standard Technical Specifications.

Rev. 23 1

Attachment III to ET 12-0033 Page 5 of 5 WOLF CREEK TABLE 9.5E-1 (Sheet 27) 10CFR5O Avpendix R WG

b. The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressur-izers for PWRs.

c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

d. The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and, control the above functions.

e. The supporting functions shall be capable of providing the process cooling, lubri-cation, etc., necessary to permit the operation of the.

equipment used for safe shutdown functions.

3. The shutdown capability for specific fire areas may be unique for each such area or it may be one unique combination in general, the performance goals of III.L.2 are satisfied except that in some cases pressurizer water level is not indicated within level indication. This is acceptable since the evaluation demonstrates that unrecoverable conditions are not reached.

Rev. 0

Attachment IV to ET 12-0033 Page 1 of 2 Markup of Calculation XX-E-013

Attachment IV to 9T 12-0033 Page 2 of 2 FORM APF 05D-001-01, REV. 07 CALCULATION NO. XX-E-013 CALCULATION SHEET REVISION NO. 2 Page 15 Area of change Basis: NRC Generic Letter 86-10, Response to Question 7.2; NEI 00-01, Rev. 2, Paragraph 3.1.1.6.

3-A-3 Design basis fires are not assumed to occur concurrently with non-fire related failures in safety systems, plant accidents, or the most severe natural phenomena.

Basis: NRC Generic Letter 86-10, Response to Question 7.2; NUREG 0800, Section 9.5-1, Rev. 3, paragraph C.1 .b.

3-A-4 For fire in areas requiring altern.ative hu.tdWn capability (i.e., whore control FGroom

.vacuation m.ay be nessar-), a less of atomatic functions. is assumed. For example, in the event of a lose Of offeite poWer the em~ergency diesel generatorst fil~normally stant automaticauly on undeoroltage. HGoweFe, in developing the alternative shutdown, capability of this autom-atic- st-art feature to opera-te Is nOW as69uMad.

Basis:- NRC Generic ILctteF 86 10, Response to Question 3.8.4!, NEI 00-01, Rev. 2, Paragraph-For a fire in areas requiring alternative shutdown capability (i.e., control room), loss of automatic function of valves and pumps with control circuits that could be affected by a control room fire is assumed, except that an automatic feedwater isolation signal (FWIS) is unaffected by a fire in the control room.

Basis: NRC Generic Letter 86-10, Response to Question 3.8.4; NEI 00-01, Rev. 2, Paragraph 3.3.1.1.4.1; License Amendment XXX (LAR number will be assigned after approval of LAR)"

3-A-5 For fire areas not requiring an alternative shutdown capability, automatic operation of components and logic circuits is credited in the analysis only where the control circuits associated with the automatic operation are known to be unaffected by the postulated fire (i.e., lll.G.2 separation requirements are satisfied).

Basis: 10 CFR 50, Appendix R, Specific Requirements Sections lll.G.1 and lll.G.2; NEI 00-01, Rev. 2, Paragraphs 3.1.1.10 and 3.3.1.1.4.1.

3-A-6 Off-site power may or may not be available. The maximum duration of any loss of offsite power event is assumed to be 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Basis: 10 CFR 50, Appendix R, Section lll.L.3; NUREG 0800, Section 9.5-1, Rev. 3, paragraph C.1.b.

3-A-7 Loss of offsite power has been specifically evaluated for every fire area to demonstrate where a LOOP may occur as a result of a fire. For alternate shutdown, a LOOP is considered as a simultaneous event. (Appendix 2 identifies fire areas where a fire may cause a LOOP)

Basis: 10 CFR 50, Appendix R, Section ll1.1.3; NUREG 0800 Position C5.c.(3); NEI 00-01, Rev. 2 paragraph 3.1.1.7.

3-A-8 Failure of onsite power supplies is not assumed unless it is caused as a direct consequence of a fire.

Basis: 10 CFR 50, Appendix R, Section 111. L.3; NUREG 0800 Position C5.c.(4); NEI 00-01, Rev. 2, Paragraph 3.1.1.7.

Attachment V to ET 12-0033 Page 1 of 2 Control Room Layout

Enclosure to ET 12-0033 Drawing E-1 F9915, Revision 4, "Design Basis Document for Procedure OFN RP-017, Control Room Evacuation" (167 pages)

COVER SHEET DRAFT MARKUP ASSOCIATED WITH LICENSE AMENDMENT REQUEST LETTER ET 12-0033 O REVISED INCORPORATED CHANGE 13906 CHG. DOC. PKG. NO.

ISSUED THISDING.

SUPERSEDEDBY REV. THISDWGSUPERSEDES REV.

REVISION NOTES:

W4OLF CREEK ELE vRNI NUCR OPERATING ORPORAN APPROVAL DESIGN BASIS DOCUMENT FOR OFN RP-017, CONTROL ROOM EVACUATION SCALE DRAWING NUMBER SHEET I REV NONE E-1 F9915 1 4

Design Basis Document for Procedure OFN RP-017 Page 2 of 102 E i F991 5, Rev. 4 TABLE OF CONTENTS Pane 1.0 Purpose .............................................................................................................................................. 3 2.0 Scope and Assum ptions .............................................................................................................. 3 2.1 Scope .............................................................................................................................................. 3 2.2 Assum ptions ................................................................................................................................... 3 3.0 Methodology ....................................................................................................................................... 3 4.0 References .......................................................................................................................................... 4 4.1 W olf Creek Docum ents ............................................................................................................. 4 4.2 Nuclear Regulatory Com m ission Docum ents ........................................................................... 6 4.3 Other Docum ents ............................................................................................................................ 6 5.0 Background ........................................................................................................................................ 6 6.0 Sum m ary of Tim ing Basis ............................................................................................................ 6 6.1 Reactivity Control ............................................................................................................................ 7 6.2 Reactor Coolant Makeup/Inventory Control ............................................................................ 7 6.3 Decay Heat Rem oval ...................................................................................................................... 8 6.4 Process Monitoring ......................................................................................................................... 9 6.5 Support ........................................................................................................................................... 9 7.0 Section-by-Section Review ........................................................................................................ 11 7.1 O FN RP-017, Section 1.0 -Purpose ....................................................................................... 11 7.2 O FN RP-017, Section 2.0 - Sym ptom s or Entry Conditions ................................................... 12 7.3 OFN RP-017, Section 3.0 - References and Commitments ................................................... 12 7.4 Step-by-Step Review ................................................................................................................ 18 Appendix 1 - OFN RP-01 7 Credited Component Evaluation Appendix 2 - Control Room Fire Consequence Evaluation for Motor Operated Valves

Design Basis Document for Procedure OFN RP-017 Page 3 of 102 E 1F9915, Re.-

1.0 Purpose The purpose of this document is to provide a technical basis for procedure OFN RP-017, Control Room Evacuation (due to fire) and define the timing basis for each action step within OFN RP-01 7.

2.0 Scope and Assumptions 2.1 Scope This document applies to procedure OFN RP-017.

2.2 Assumptions The following assumptions are applied when developing the Wolf Creek strategy for shutting down and maintaining hot standby using procedure OFN RP-01 7.

2.2.1 Only fire-induced failures are postulated to occur and all equipment is in normal operating state at the time of the fire.

2.2.2 Response Not Obtained (RNO) actions are included as operator aids and exceeds the procedural guidance required by regulation. It is not expected that the RNO actions will be necessary unless the primary action is affected by the fire.

2.2.3 Prior to transfer of control to the Auxiliary Shutdown System only a single spurious actuation is assumed to occur at a time, except in the case of two redundant valves in a high/low pressure interface line. All potential spurious actuations are mitigated/prevented using OFN RP-017 but timing is based on the spurious actuations occurring one at a time, or two at a time in the case of high/low pressure interface lines.

2.2.4 The Wolf Creek Fire Protection licensing basis, as described in USAR, Section 9.5.1, requires that a loss of off-site power be assumed in conjunction with a control room fire. However, a loss of offsite power may not be the most conservative assumption for every fire scenario. Therefore, the thermal hydraulic calculations were performed assuming off-site power is available and off-site power is not available to determine the most conservative outcome. The results of the thermal hydraulic calculation are presented in evaluation SA-08-006.

2.2.5 Automatic functions capable of mitigating spurious actuations are assumed to be defeated by damage to cables located in the area associated with the automatic function.

2.2.6 The reactor is tripped prior to evacuation of the control room. This is the only action assumed to work prior to evacuation. Tripping the reactor is considered to be t = 0 seconds for the purpose of timing subsequent steps.

2.2.7 Transfer of control to the alternative or dedicated shutdown system is assumed to occur when all isolation and transfer switches have been manipulated per procedure OFN RP-017. These switches are either located at the Auxiliary Shutdown Panel or at the local equipment.

3.0 Methodology The methodology for completing this document is described in this section.

Each section and step within OFN RP-017 was reviewed and a technical basis for the section or step was documented.

Section 1.0 describes the purpose of E-1 F9915. Section 2.0 identifies the scope. Section 4.0 lists the references used to compile E-IF9915.

Section 5.0 provides background information on OFN RP-017.

Design Basis Document for Procedure OFN RP-017 Page 4 of 102 E11F9115, Rev. 4 Section 6.0 is a summary of each PFSSD function and the major equipment associated with the function.

In addition, Section 6.0 summarizes the timing requirement to ensure the function is satisfied per the times justified in Section 7.0.

Section 7.0 provides a technical review of each section in OFN RP-017. First, the front-end sections are discussed and a technical basis provided. These front-end sections include the Purpose, Symptoms or Entry Conditions, and References and Commitments.

Next, each Action/Expected Response and Response Not Obtained step within OFN RP-017 is tabulated in Table 7.1. The columns and the information provided in each column are described below.

" Step Number - The step number identified in OFN RP-01 7, revision 31.

" Step Description - The Step wording taken verbatim from the procedure.

" PFSSD Function - This column describes the PFSSD function that is satisfied by performing the Step. Functions are as follows: R - Reactivity Control; M - Reactor Coolant Makeup and Inventory Control; D - Decay Heat Removal; P - Process Monitoring; S - Support. If the step does not satisfy a specific function, then N/A is placed in the column.

" Basis - This column provides useful information about the step and why it is included in the procedure.

" Required Time to Complete - This column describes the maximum time that the operator has to complete the step to ensure the function supported by the step is satisfied. Completion of a step after the time indicated does not necessarily mean unrecoverable conditions would be reached but it would be beyond that which has been analyzed. Further analysis would be needed to determine the impact of not meeting a time limit identified in this document.

" Timing Basis - This column describes the basis for the maximum allowed operator response time given in the previous column. The basis is derived from a number of calculations and evaluations as described in the column.

Control Room Fire Impact - This column describes whether a fire in the control room could cause the component to spuriously operate after the Step and any identified pre-requisite Steps are complete. If yes, then further discussion is provided for why it is acceptable.

Prerequisite Steps - This column identifies the Step(s) that are required to be completed prior to completing the Step. Prerequisites are steps that must be completed before the current step to prevent potential damage to equipment or prevent spurious operation of the equipment after the step is completed and the Operator moves on. A step that restores power to a component is not considered a prerequisite. These pre-requisites are listed to provide reasonable assurance that future procedure changes will not improperly re-order the steps.

4.0 References 4.1 Wolf Creek Documents 4.1.1 Procedure OFN RP-017, Revision 40 - Control Room Evacuation 4.1.2 Wolf Creek Operating License NPF-42 4.1.3 Wolf Creek Safety Evaluation Report including Supplements 1 through 5 4.1.4 Wolf Creek Technical Requirements Manual (TRM), Revision 38 4.1.5 SNUPPS Letter SLNRC 84-0109 - Fire Protection Review 4.1.6 Memo from NRC to KG&E dated August 31, 1984 - Minutes of August 22, 1984 Meeting with

Design Basis Document for Procedure OFN RP-017 Page 5 of 102 E 1F9911 , Rev. 4 Kansas Gas and Electric and Union Electric Company 4.1.7 Calculation XX-E-013, Post-Fire Safe Shutdown Analysis 4.1.8 Safety Analysis Evaluation SA-08-006, Rev. 2 - Retran-3D Post-Fire Safe Shutdown (PFSSD)

Consequence Evaluation for a Postulated Control Room Fire 4.1.9 Calculation Change Notice AN-02-10-000 EDG Room Temperature at Various Outside Air Temperatures for the NRC Triennial Fire Protection Inspection 4.1.10 Calculation EF ESW System Flow Requirements 4.1.11 Drawing M-018-000155 - Operation of Diesel Engine without Cooling Water 4.1.12 Drawing J-14001 - Control Room Equipment Arrangement 4.1.13 Drawing E-13EF06A - Schematic Diagram ESW to Ultimate Heat Sink Isolation Valves 4.1.14 Drawing E-025-00007, Sheet 185 - EFHV0038 Design Configuration Document 4.1.15 Document E-1ONK-Class 1E 125 VDC System Description 4.1.16 Specification M-018 - Standby Diesel Generator 4.1.17 PIR 2005-3314/CR2007-003037 - Issues involving NRC Information Notice 92-18 4.1.18 CR 00012368 - Timing Basis for Re-Establishing Room Cooling 4.1.19 CR 00016481 - Guidance for Control Room Re-Entry After Fire 4.1.20 CR 00019239 -Time to Close Valve BNHV8812A 4.1.21 CR 00019242 - Train B Emergency Diesel Generator Potential Failure to Start 4.1.22 CR 00020612 - Amphenol Connectors for MSIVs cannot be Removed by Hand 4.1.23 CR 00023410 - Issues with the Train B Emergency Diesel Generator Voltage Regulator 4.1.24 CR 00030350 - Post-Fire Safe Shutdown Concern with Train B Diesel Generator Field Flashing 4.1.25 CR 00030376 - Revise E-1 F9915 to Document Time to Establish Diesel Engine Cooling 4.1.26 CR 2008-004708 - Determine Time to Establish Diesel Engine Cooling 4.1.27 CR 00041746 - Spurious Operation of Valve EFHV0060 4.1.28 Calculation KJ-M-01 7, Rev. 0 - Emergency Diesel Standby Generator (KKJ01 B) Runtime Without ESW Flow 4.1.29 CR 00041746 - Potential for EFHV0060 to Open Due to Control Room Fire 4.1.30 CR 00044460 - Add OFN RP-01 7 Component Evaluation to E-1 F9915 4.1.31 CR 00046642 - RCP Seal Return Valves 4.1.32 CR 00046702 - Auxiliary Shutdown Panel Controls for B Motor Driven Auxiliary Feedwater Pump 4.1.33 CR 00046707 - Review Reactor Trip Switch Circuits for Alternative Shutdown

Design Basis Document for Procedure OFN RP-017 Page 6 of 102 E-1 F991 5, Rev. 4 4.2 Nuclear Regulatory Commission Documents 4.2.1 10 CFR 50.48 - Fire Protection 4.2.2 10 CFR 50, Appendix R - Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 4.2.3 NRC Generic Letter 86 Implementation of Fire Protection Requirements 4.2.4 NRC Information Notice 2005 Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant Pumps 4.2.5 Regulatory Guide 1.189, Rev. 2 - Fire Protection for Nuclear Power Plants 4.3 Other Documents 4.3.1 Westinghouse WCAP-16396-NP, Westinghouse Owners Group Reactor Coolant Pump Seal Performance for Appendix R Assessments.

4.3.2 Westinghouse Technical Bulletin TB-04-22, Rev. 1, Reactor Coolant Pump Seal Performance -

Appendix R Compliance and Loss of All Seal Cooling.

4.3.3 NEI 00-01, Rev. 2- Guidance for Post-Fire Safe Shutdown Circuit Analysis 4.3.4 Westinghouse Letter LTR-RAM-1-10-053 dated October 15, 2010.

Subject:

White Paper Westinghouse Reactor Coolant Pump Seal Behavior For Fire Scenarios, Revision 2.

5.0 Background The Control Room evacuation and plant shutdown procedure is documented in OFN RP-017 (power operation to hot standby) and OFN RP-017A (hot standby to cold shutdown). The original basis for procedure OFN RP-01 7 is SLNRC 84-0109, which documents a phased approach to shutting down the plant and maintaining it in a safe hot standby condition if control room evacuation is required following a fire. This phased approach was approved by the NRC in Supplement 5 of the Wolf Creek Safety Evaluation Report.

Although SLNRC 84-0109 formed the original licensing basis for hot shutdown from outside the control room at SNUPPS facilities, its basis is not clearly defined nor understood. Some of the step sequences and actions are questionable by today's operational and regulatory standards. Over the years, changes have been made to OFN RP-017, which were not in literal compliance with the letter. The changes were subsequently determined to not have an adverse impact on the health and safety of the public. However, because of the confusing nature of the letter, it was decided that a design basis document that clearly describes the basis for OFN RP-01 7 is needed.

License Amendment XXX approved superseding letter SLNRC 84-0109 with document E-1 F9915 as the basis for alternative shutdown in the event of a fire in the control room. Therefore, letter SLNRC 84-0109 is considered historical and is no longer part of the approved fire protection program.

6.0 Summary of Timing Basis This Section includes a summary of the major equipment credited in OFN RP-01 7 for satisfying each PFSSD function (Reactivity Control, Reactor Coolant Makeup and Inventory Control, Decay Heat Removal, Process Monitoring and Support). In addition, operator response timing, to ensure the function is satisfied prior to reaching unrecoverable conditions, is discussed.

Design Basis Document for Procedure OFN RP-017 Page 7 of 102 S -1FONl15, Rev. 4 6.1 Reactivity Control Reactivity control is achieved by tripping the reactor prior to leaving the control room. Tripping the reactor is considered to be t = 0 seconds for the OFN RP-01 7 timeline. (Assumption 2.2.6)

The main steam isolation valves (MSIVs) and steam generator (SG) blowdown valves are isolated to prevent return to criticality due to uncontrolled cooldown. The MSIVs are assumed to remain open until action is taken outside the control room within 3 minutes to close them. Prior to evacuating the control room, operators attempt to close the MSIVs using the all-close hand switches, but this action is assumed to fail. In these cases, the steam dumps are assumed to operate properly to control temperature to 557 0 F, then the steam dumps are isolated within 7 minutes by de-energizing power to the valves, at which time the ARVs are used for temperature control. All components located downstream of the MSIVs are assumed to be unaffected by the fire.

Plant cooldown is controlled using SGs B and D atmospheric relief valves (ARVs) while SGs A and C ARVs are closed. Based on Calculation SA-08-006, a single SG ARV can remain open for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months with no adverse impact on safe shutdown. Otherwise, all SG ARVs are assumed to function normally at time 0, controlling pressure less than 1184.7 psia. Steam generators B &D ARVs are assumed to close at 7 min then control as necessary at 561 degrees F after the operator takes manual control of the B & D ARVs from the auxiliary shutdown panel (ASP). Steam generators A & C ARVs are assumed to close at 7 minutes, then stay closed after the operator at the ASP closes them per procedure.

The main turbine trips in response to a reactor trip through an interlock from the reactor trip breakers that is unaffected by a fire in the control room. Therefore, steam loss through the turbine is prevented.

The Train B Chemical and Volume Control System (CVCS) is used to provide borated water to the RCS to maintain negative reactivity conditions. This is accomplished using the Train B centrifugal charging pump (CCP) taking suction from the borated refueling water storage tank (RWST) and injecting to the RCS through the boron injection tank (BIT). Calculation SA-08-006 assumes the Train B CVCS is lined up and injecting through the BIT within 28 minutes.

6.2 Reactor Coolant Makeup/inventory Control Reactor coolant makeup and inventory control is achieved by first isolating all potential RCS leakage and inventory reduction paths including pressurizer power operated relief valves (PORVs), normal letdown, excess letdown, reactor vessel head vents, reactor coolant pump seals, MSIVs, steam generator blowdown, steam generator ARVs, and residual heat removal (RHR) suction from the RCS. Leakage through the RHR system is not credible since the RHR pump suction valves are normally closed and de-energized. The reactor coolant pumps (RCPs) are stopped to prevent loss of inventory through the RCP seals.

Based on Calculation SA-08-006, pressurizer PORVs are assumed isolated within 3 minutes and normal letdown is assumed isolated within 7 minutes. Charging flow to the reactor coolant pump seals is assumed to be isolated within 10 minutes. The reactor coolant pumps are assumed to be stopped within 7 minutes. Steam generator ARVs and MSIVs are isolated as discussed in Section 6.1.

Letdown flow is assumed to be isolated within 7 minutes. In all scenarios where letdown is unaffected, initial flow is 120 gpm until isolated. The 120 gpm flow rate is based on normal letdown of 75 gpm plus an additional 45 gpm that could be flowing for Chemistry concerns (this rarely occurs). In the scenarios where letdown valves fail open, letdown flow goes to 195 gpm for 7 minutes, which is the maximum letdown flow. The automatic letdown isolation signal on low pressurizer water level (17%) is assumed to fail.

Pressurizer heater backup group B is cycled to maintain pressurizer pressure within 2000 to 2300 psig.

In the loss of off-site power scenarios, Calculation SA-08-006 assumes pressurizer heaters fail to operate at time zero. At 11.5 minutes, backup group B is controlled at the ASP. In the non loss of off-site power scenarios, all three heater groups operate normally but power to backup group B is lost by procedure

Design Basis Document for Procedure OFN RP-017 Page 8 of 102 E 1F99115, Rev. 4 within 7 minutes. Power is restored within 11.5 minutes and control on backup group B is available from the ASP.

Calculation SA-08-006 assumes the steam generator blowdown valves function normally except in the scenarios where the blowdown valves are assumed to remain open. In these scenarios, the blowdown valves remain open for the duration of the modeled run (1-hour).

Calculation SA-08-006 assumes the pressurizer and auxiliary pressurizer spray valves operate normally except in those scenarios where the pressurizer spray is assumed to fail. In those scenarios, the pressurizer spray valves are assumed to open at time zero and pressurizer spray stops at 7 minutes when the RCPs are stopped. Auxiliary spray is assumed to operate at time zero and stops in 7 minutes when PK5117 is opened in Step D1.

The Train B CVCS is used for makeup and inventory control by taking suction from the RWST and injecting through the BIT. Calculation SA-08-006 assumes the Train B CVCS is lined up and injecting through the boron injection tank (BIT) within 28 minutes.

A potential concern with inventory control is that a control room fire could cause the number 1 seal return valves (BBHV8141A, B, C and D) to close, which could cause excessive RCS leakage. OFN RP-017 isolates RCP seal cooling, contributing to this event. OFN RP-017 also trips the RCPs, which minimizes the impact of this event.

A white paper prepared by Westinghouse and distributed as letter number LTR-RAM-1-1 0-053 (Reference 4.3.4) summarizes RCP seal behavior for fire scenarios. This white paper is a compilation of several WCAPs and Technical Bulletins on the subject.

Table 1 in the letter is a scenario matrix that identifies the number 1 and number 2 RCP seal behavior and resultant leakage given RCPs running or not running and seal cooling available or not available. For the scenario postulated here (Number 1 seal return line isolated, RCPs not running and no seal cooling),

the resultant leakage from Table 1 is 21 gpm per seal or 84 gpm total. This leakage is well within the makeup capability of the charging pump, which has a design flow rate of 150 gpm at 2800 psi and a runout flow of 550 gpm at 606 psi. Therefore, this condition does not pose a concern for PFSSD at Wolf Creek.

6.3 Decay Heat Removal Hot standby decay heat removal is achieved using Train B motor driven auxiliary feedwater pump (MDAFP), taking suction from the condensate storage tank (CST), to supply feedwater to steam generator D and the turbine driven auxiliary feedwater pump (TDAFP), taking suction from the condensate storage tank (CST), to supply feedwater to steam generator B.

Calculation SA-08-006 assumes the Train B MDAFP is lined up and supplying steam generator D within 15 minutes and the TDAFP is lined up and supplying steam generator B within 35 minutes. Steam generators B and D atmospheric relief valves are used to control reactor coolant system (RCS) temperature. Steam generators A and C atmospheric relief valves are isolated. See Section 6.1 for dScus-sion about -.team generator -RVs.

The reactor is tripped at t = Os when operators actuate the reactor trip push buttons prior to evacuating the control room. The reactor trip causes a low Tavg signal within 5 seconds and initiates a feedwater isolation signal, which stops main feedwater flow and prevents steam generator overfill from main feedwater.

To prevent steam generator overfill in cases where the fire causes a spurious auxiliary feedwater actuation signal (AFAS), the Train A MDAFP is stopped by operator action within 15 minutes. The TDAFP is taken to minimum output within 15 minutes and remains there until valves in the AFW discharge line are closed, which takes 35 minutes. At that point, the TDAFP is started to supply SG B.

Design Basis Document for Procedure OFN RP-017 Page 9 of 102 6-1 *-191 5, Rev. 4 Main steam isolation valves are required to be closed for decay heat removal to control cooldown. See Section 6.1 for discussion about MSIVs.

Cold shutdown decay heat removal is not included in OFN RP-017.

6.4 Process Monitoring Process monitoring ensures RCS variables are within specified limits. The ASP contains all the required process monitoring instruments to verify reactivity conditions, pressurizer level, pressurizer pressure, RCS temperature and steam generator level. Source range indicator SENI0061X indicates reactivity level. Pressurizer level is determined by BBLI0460B. Pressurizer pressure is determined using reactor vessel pressure instrument BBPI0406X. RCS temperature is determined using RCS loop 2 cold leg temperature indicator BBTI0423X and loop 4 hot leg temperature indicator BBTI0443A. Steam generator level is determined using steam generators B and D narrow range level indicators AELI0502A and AELI0504A, respectively. These process monitors are unaffected by a fire in the control room.

6.5 Support The post fire safe shutdown support function provides the necessary cooling, ventilation and electrical power required by the reactivity control, reactor makeup, decay heat removal and process monitoring functions. The support function supports all the other post fire safe shutdown functions and includes component cooling water (CCW), essential service water (ESW), room cooling and ventilation, control room isolation and electrical power distribution.

Component cooling water is required for OFN RP-017 to supply cooling to the Train B charging pump oil cooler and the seal water heat exchanger. Both of these components support centrifugal charging pump (CCP) operability. Therefore, CCW is required to be operable prior to the need for charging. Based on Calculation SA-08-006, charging needs to be lined up and injecting within 28 minutes.

Essential service water is required to provide cooling to the CCW heat exchanger, emergency diesel engine coolers and various room coolers. In addition, ESW is a backup source of auxiliary feedwater.

Emergency diesel engine cooling is required to maintain the engine jacket water temperature below the trip setpoint of 195°F. The engine is started in Step C6 when the offsite power feeder breakers are opened, which provides an automatic start signal to the engine. Step C8.e closes the Train B emergency diesel generator (EDG) output breaker and step C9 starts the ESW pump. The combined generator loading of the non-shed loads and the ESW pump is 3,615.9 kW per calculation KJ-M-01 7, which is 58.3% of the EDG rating of 6,201 kW. At this point, service water (SW) crosstie valve EFHV0026 is not closed and it is assumed that the ESW flow is diverted to the SW system. Therefore, no EDG cooling benefit is assumed after the start of the ESW pump. Step C12 closes EFHV0026, at which point EDG cooling can be credited.

Table 1 in Calculation KJ-M-017 identifies the allowable time to establish EDG cooling given various values of unloaded times from 1 minute to 5 minutes in 15 second increments. The table shows that, as the time to complete steps C6 through C8 increases, the time to complete Steps C9 through C12 decreases. For example, if step C8 is completed in 2.5 minutes after step C6, operators have 2.51 minutes to complete Steps C9 through C12 and close EFHV0026. However, if the operator takes 3.5 minutes to complete Step C8 after Step C6 is completed, then they only have 2.22 minutes to complete Steps C9 through C12 and close EFHV0026. Table 1 from Calculation KJ-M-01 7 follows.

Design Basis Document for Procedure OFN RP-017 Page 10 of 102 6 F991 5,Re.4 Time Allowable Time Allowable Unloaded Time Loaded Unloaded Time Loaded (Min) (Min) (Min) (Min) 1 2.80 3.25 2.28 1.25 2.75 3.5 2.22 1.5 2.69 3.75 2.12 1.75 2.63 4 1.98 2 2.57 4.25 1.85 2.25 2.51 4.5 1.71 2.5 2.45 4.75 1.58 2.75 2.39 5 1.44 3 2.33 1 1 Room coolers and ventilation fans are used to maintain a suitable environment for the equipment within the room to ensure long term operation of the equipment. Room coolers credited in the event of a control room fire are as follows:

1. Train B Class 1E Electrical Equipment Room A/C Unit (SGK05B)

2. Train B Electrical Penetration Room Cooler (SGL1 5B)

3. Train B Component Cooling Water Pump Room Cooler (SGL 113B)

4. Train B Auxiliary Feedwater Pump Room Cooler (SGF02B)

5. Train B Centrifugal Charging Pump Room Cooler (SGL12B)

6. Train B Containment Coolers (SGN01B and SGN01D)

7. Train B ESW Pump Room Supply Fan (CGDO1B) and Dampers (GDTZ1 1A and GDTZ1 1C)

Procedure SYS GK-200 allows up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to pass after loss of one Train of Class 1E Electrical Equipment Room A/C before compensatory measures are established to restore cooling to the affected Train. For conservatism, this design basis document uses 60 minutes as the requirement to restore Class 1E Electrical Equipment Room A/C.

The timing basis for establishing electrical penetration room cooling is documented in CR 012638. Based on the evaluation in CR 012638, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months should be used as the maximum time to restore cooling to the electrical penetration rooms. This time is based on the Wolf Creek Technical Requirements Manual (TRM), TR 3.7.22-1 which states that operators have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore room temperatures to within allowable limits given in Table TR 3.7.22-1. (Note that the TRM revision in effect when the CR was evaluated (Revision 35) required equipment to be declared inoperable if temperatures were not restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The current revision of the TRM (38) does not require equipment to be declared inoperable). For conservatism, 1-hour is used as the timing basis in E-1 F9915. The allowable temperature limit for the electrical penetration rooms is 101 degrees F per Table TR 3.7.22-1. Based on operator timing, the electrical penetration room cooler is started within 13 minutes. Therefore, the time to restore electrical penetration room cooling is well within the 1-hour limit established in E-1 F9915.

The pump room coolers (SGL1 1B, SGF02B and SGL12B) automatically start when the pump starts.

Procedure OFN RP-017 lines up power and ESW flow to the pump room coolers prior to starting the pumps. Therefore, pump room cooling will be provided as soon as each pump starts.

The containment coolers maintain containment temperature within acceptable limits but are not directly required for safe shutdown after a fire in the control room. There are no post-fire safe shutdown components in containment that will adversely impact the ability to achieve safe shutdown if the coolers are not started. Therefore, the timing for this step is not critical and, therefore, no time limit has been established.

The timing basis for establishing ESW pump room ventilation is documented in CR 012638. Based on the evaluation in CR 012638, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months should be used as the maximum time to restore cooling to the ESW pump room. This time is based on the Wolf Creek Technical Requirements Manual (TRM), TR 3.7.22-1 which states that operators have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore room temperatures to within allowable limits given in

Design Basis Document for Procedure OFN RP-017 Page 11 of 102 EAI FQ191 5, Rev:. 4 Table TR 3.7.22-1. (Note that the TRM revision in effect when the CR was evaluated (Revision 35) required equipment to be declared inoperable if temperatures were not restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The current revision of the TRM (38) does not require equipment to be declared inoperable). For conservatism, 1-hour is used as the timing basis in E-1 F9915. The allowable temperature limit for the ESW pump rooms is 119 degrees F per Table TR 3.7.22-1. Based on operator timing, the ESW pump room supply fan is started approximately 12 to 15 minutes after the ESW pump is started. In addition, Step A16 directs an available operator to check ESW pump room temperature. Based on operator timing, Step A16 is reached in less than 20 minutes. At this point, the Site Watch, who has no fire brigade or OFN RP-017 duties, could be dispatched to the ESW pumphouse to check room temperatures and make adjustments as necessary per the Step Al 6 RNO column. Therefore, the time to restore room cooling in the ESW pump room is well within the 1-hour limit established in E-1F9915.

7.0 Section-by-Section Review 7.1 OFN RP-017, Section 1.0 - Purpose 7.1.1 OFN RP-017, Section 1.1 1.1 To provide operatoractions for evacuating the ControlRoom due to fire, establishingplant control from the Auxiliary Shutdown Panel (ASP), and reactorshutdown to Hot Standby conditions.

Basis - 10 CFR 50, Appendix R, Section III.L.3 requires procedures to be in effect to implement the alternative and dedicated shutdown capability for any fire area utilizing the provisions in Appendix R,Section III.G.3. Wolf Creek took no exception to this requirement in the Appendix R comparison documented in the USAR, Table 9.5E. Letter SLNRC 84-0109 (August 23, 1984), Section 2.0 Response Plan Summary states, in part, "Procedures will be developed to implement this plan at Callaway and Wolf Creek." The Wolf Creek SER, Supplement 5, Page 9-12 states, in part, "(1) The applicant will revise the procedures for a fire in the control room in accordance with the SNUPPS letter of August 23, 1984 ... "

Therefore, Wolf Creek is committed to maintain in effect procedure OFN RP-01 7 to achieve hot standby conditions. Cold shutdown is achieved from outside the control room using OFN RP-017A.

7.1.2 OFN RP-017, Section 1.2 1.2 This procedureshould only be used when the ControlRoom is uninhabitableand damage to controls or ControlRoom equipment has occurred or is imminent.

Basis - This statement emphasizes that control room evacuation should only take place when control from the control room is lost or will be lost. Shutting down from outside the control room is not desired and evacuation should only be done when the plant cannot be controlled from inside the control room.

7.1.3 OFN RP-017, Section 1.3 1.3 Since the Control Room is uninhabitable,this procedure includes actions to:

Prevent subsequent fire/physical damage to Control Room circuitsfrom adversely affecting systems needed to maintain Hot Standby

Transfer critical Train B controls to the ASP

Maintain the plant in Hot Standby from the ASP Basis - This step identifies the objectives for OFN RP-01 7. It clearly states that the procedure is only intended to maintain hot standby from outside the control room using Train B components. Cold shutdown is achieved using procedure OFN RP-017A.

Design Basis Document for Procedure OFN RP-017 Page 12 of 102 FE-1F9915, Roe'Y.4 7.2 OFN RP-017, Section 2.0 - Symptoms or Entry Conditions Section 2.0 provides conditions in which operators may deem entering OFN RP-01 7 to be necessary. These entry conditions are not licensing commitments but rather guidance for operators to use when determining the need to enter OFN RP-01 7. The decision is a judgment call made by operating staff with the final decision made by the Shift Manager. Step 1 in the procedure provides additional conditions to be considered prior to evacuating the control room. There are no NRC criteria for establishing the point at which operators evacuate the control room. Therefore, there is no licensing basis for when control room evacuation takes place.

7.3 OFN RP-017, Section 3.0 - References and Commitments 7.3.1 OFN RP-017, Section 3.1 - References

a. Nuclear Safety EngineeringSurveillance Report No. 1991-005 Basis - This surveillance report, designated SSR 91-005, was performed by Wolf Creek Nuclear Safety department and was issued on 4/26/1991. The purpose of the surveillance was to determine the adequacy of 10CFR50.59 screenings on Operations procedures.

OFN 00-017, Control Room Evacuation, Revision 13 was chosen for review. The review concluded that the 50.59 screenings were appropriate but made 12 recommendations for improvement of the procedure. Most of the recommendations were incorporated into revision 14 of OFN 00-017 and some were not with justification. The changes made to OFN 00-017 as a result of this surveillance that are still in effect today in OFN RP-01 7 are listed below:

1. NK4101 is no longer opened to remove control power from Train A bus NB01 breakers.

The observer stated that by opening the switch, the Train A AFW pump would not be able to be controlled from the ASP. Operations removed the step due to there being no requirement to open the switch. Train A equipment is not required for OFN RP-01 7.

However, it may be practical to open NK4101 to support Step C15 (Stopping the Train A Containment Spray Pump).

2. Fuse #46 in panel RP209 is pulled to fail close the MSIV bypass valves. The observer noted that opening the breaker would remove power from other equipment and felt that this is not a good idea. He also noted that Callaway pulls fuses to close the MSIV bypass valves. Step B1 2 pulls fuse #46 in RP209.

3. NK4411 is used to isolate steam generator blowdown. This differs from SLNRC 84-0109, which says to use the switches in the Radwaste Control Room. Use of NK4411 will achieve the desired result faster than sending an operator to the Radwaste Control Room. See Step C27.

4. As a result of recommendation 12, an attachment was added to give operators instruction to protect Train A equipment after all other critical steps are completed.

Attachment F provides guidance based on this recommendation.

b. USAR 7.4.6, Safe Shutdown From Outside The Control Room Basis - USAR Section 7.4.6 describes the capability of Wolf Creek to shutdown from outside the control room using the Auxiliary Shutdown Panel (ASP), switchgear and motor control centers. The mitigating actions for a fire in the control room use Train B ASP and equipment. Train B was selected because instrumentation and controls for the turbine driven auxiliary feedwater pump are located on the Train B ASP.

c. USAR Appendix 9.5B, Fire HazardsAnalyses Basis - The Fire Hazards Analysis is now located in document E-1 F9905, which is incorporated into the USAR, Appendix 9.5B by reference.

Design Basis Document for Procedure OFN RP-017 Page 13 of 102 E 1F9915, Rev. 4

d. PIR 1997-2819, EDG Master Transfer Switch In Auto With Fire In The Control Room Basis - PIR 1997-2819 identified a concern where OFN RP-017 did not previously require placing master transfer Switch KJHS0109 in Local/Manual position. The initiator stated that if the switch were left in Auto position, a control room fire could affect the circuits and shut down the diesel generator. After review of the circuits, OFN RP-01 7 was revised to require operators to place KJHS0109 in Local/Manual. Step C.8.b proceduralized this action. Also see PIR 2006-000860 discussion below.

e. PIR 1997-2453, Enter OFN RP-013 At 2 mR/hr Submersion Dose Rate Basis - PIR 1997-2453 identified a concern where OFN RP-017 previously required evacuation of the control room if radiation reached certain levels. As a result, OFN RP-017 was revised to allow Health Physics and Shift Supervisor discretion on whether to evacuate. PIR 1997-3376 was also written to evaluate the need to evacuate the control room at all for radiation levels. OFN RP-01 7 was revised to remove the specific radiation levels and allow the Shift Supervisor to enter OFN RP-01 3 at his discretion.

f. OP 1988-0190, Replacing BG HV-8105 with local valves within the NCP room Basis - This is an inter-office correspondence that requested a procedure change to OFN 00-017 (now OFN RP-017) to reduce the time to complete certain actions. The procedure required an operator to first open BGFCV0121 locally in the positive displacement pump (PDP) room (now the normal charging pump (NCP) room) on the 1974 elevation then the same operator had to ascend to the north pipe penetration room on the 2000 elevation to locally close BGHV8105. The memo requested that instead of closing BGHV8105, valves BG8402B and BGV001 7 be manually closed or verified closed. These valves are located in the NCP room along with BGFCV0121. The change was made as requested and OFN RP-01 7 uses BG8402B and BGV001 7.

g. PIR 1999-109, Removing control power priorto rotating ESF bus #2 isolate switch Basis - This PIR identified 3 issues where OFN RP-01 7, Revision 11 was not consistent with the original response strategy for control room fires documented in SLNRC 84-0109 (Superseded by E-1 F9915). These issues are discussed below:

Issue 1 - Note 10 in SLNRC 84-0109 states that FCHV0312 and ABHV0005 will not be opened until it is verified that ALHV0036 is open. There are two loop steam supply valves to the turbine driven auxiliary feedwater pump (TDAFP) (ABHV0005 (loop 2) and ABHV0006 (loop 3)). SLNRC 84-0109 only credited ABHV0005 to provide a steam supply to the TDAFP. OFN RP-017, Rev. 11 Step A9 required the operator at the ASP to open steam supply valve ABHV0006 using ABHIS0006B prior to verifying that suction valve ALHV0036 is open. However, OFN RP-01 7, Rev. 11 Steps A6 and A8 had the same operator at the ASP close the turbine trip and throttle valve (FCHV0312) using FCHIS0312B and the turbine governor valve (FCHV0313) using FCHS0313 and FCHIK0313. Step A7 required the operator at the ASP to isolate ABHV0005 using ABHIS0005B. The requirement in SLNRC 84-0109 has been met in that FCHV0312 and ABHV0005 are maintained closed until ALHV0036 is opened. However, ABHV0006 was added to the procedure at some later time. Since FCHV0312 is maintained closed, the TDAFP will not operate even with ABHV0006 open.

Issue 2 - This issue involves performing steps in the procedure in a different sequence than what was approved in SLNRC 84-0109. Note 2 in SLNRC 84-0109 states that DC power should be tripped after Action 9 [assure MCC and load center breakers are closed]

Design Basis Document for Procedure OFN RP-017 Page 14 of 102 E 1F994 5,Rev. 4 in room 3302 so that breakers can be electrically tripped by hand to the desired position.

OFN RP-01 7, Rev 11 had operators' open the control power breakers to the NB02 bus and then rotate switch NBHS0014 to the isolate position. By opening the control power breaker before rotating NBHS001 4, relay 195 will not energize and the control room will not be isolated.

Revision 18 of OFN RP-01 7 deleted NBHS001 4 from the procedure. The hand switch would not have completely isolated the control room from the control circuit on the affected components. Also, a control room fire could have opened the control power fuse due to a hot short, thereby isolating control power prior to operation of the hand switch.

The current revision of OFN RP-01 7 requires operators to remove control power from the NB02 bus and not use NBHS0014. Isolating control power will prevent spurious operation of any of the breakers associated with NB02. The possibility still exists for the NB02 breakers to close prior to isolating control power. Therefore, to ensure the NB02 bus loads are shed, each pump breaker, except for the ESW pump, is verified open prior to opening the NB02 feeder breakers to simulate a LOSP and start EDG-B. Verifying each of these breakers is open also ensures the diesel will not fail to start due to overload.

On the basis of the above discussion, the concern raised in Issue 2 of this PIR is no longer valid. The use of NBHS0014 would never have fully isolated the control room and, therefore, its use was never required. Isolation of control power to NB02 ensures spurious operation of the breakers will not occur. All revisions of OFN RP-01 7 (OFN 00-017) required isolation of control power to NB02 in Phase A. The intent of SLNRC 84-0109 is met since isolation of control power effectively prevents spurious operation due to cable failures in the control room.

Issue 3 - The third issue involves the closure of the MSIVs using a portable air supply versus an electrical source, as delineated in SLNRC 84-0109. The MSIVs are closed prior to leaving the control room using ABHS0079 or ABHS0080. However, their closure cannot be guaranteed due to possible fire damage. Therefore, OFN RP-01 7 has steps to close the valves if they failed to close in response to the fast close signal.

SLNRC 84-0109, Note 6 states that the MSIVs will be closed with a portable 125 VDC source. Wires to the valves will then be cut to leave the valves in the closed position. Prior to revision 27, OFN RP-01 7 used a portable air source to close the MSIVs. This change was made in MA 93-0181 with insufficient documentation for the change. The PIR evaluation provides adequate justification for the change and RCMS 1985-118 documents the change in commitment. Since the use of air versus power to close the MSIVs is a more reliable and safe method, it met the intent of SLNRC 84-0109 and was therefore acceptable.

The MSIVs were replaced in refuel outage 16 (DCPs 09952 and 11608) with solenoid actuated system medium operated valves. These valves do not require an accumulator or external air supply so the portable air source and associated air hoses and fittings are not required. The new MSIVs are held open by six normally energized solenoid valves, three associated with Train A and three associated with Train B. Either train of solenoid valves can operate the associated valve, independent of the opposite train solenoids which provides for diversity and electrical independence. De-energizing either train of solenoids will cause the MSIVs to close. Amphenal connectors, 3 per MSIV per train, have been provided near each MSIV to provide a way for operators to disconnect power to the solenoids and close the MSIVs. This method for closing the MSIVs is utilized in the current version of OFN RP-017.

h. PIR 1999-107, Concerns with meeting required time frame

Design Basis Document for Procedure OFN RP-017 Page 15 of 102 E-iF991 , Rev:. 4 Basis - This PIR was written to document whether changes made in revision 12 of OFN RP-01 7 meet the commitments made in SLNRC 84-0109. The PIR concluded that commitments were met and no changes were required.

PIR 1999-3648 Procedurenot matchingplant labels Basis - This PIR addressed labeling inconsistencies between OFN RP-01 7 and the plant labels. The procedure was revised to match plant labeling.

j, PIR 2002-1956, Failure to properly track and implement actions specified within Regulatory CorrespondenceSLNRC 84-0109 as referenced in USAR Appendix 9.5B.

Basis -This PIR identifies concerns with OFN RP-01 7, Rev. 16 not meeting commitments in SLNRC 84-0109. The evaluation shows a step-by-step comparison of OFN RP-01 7, Rev. 16 with SLNRC 84-0109 and provides justification for any deviations. The PIR evaluation found that the deviations would not have prevented the safe shutdown of the plant. The deviations were historical with no documented evaluation in some cases. In many cases, the deviations were a result of alternative methods to produce the desired result. The alternative methods were determined to be faster and/or safer than that specified by SLNRC 84-0109. Note that the contents of USAR Appendix 9.5B is now contained in E-1F9905.

k. PIR 2003-3479, Revisions to proceduresneed fire protection review Basis - This PIR identified problems associated with emergency lighting for equipment required to implement OFN RP-01 7. Changes have been made to the procedure over the years with no consideration given to emergency lighting requirements. As components were added or deleted from the procedure, consideration was not always given to emergency lighting requirements. As a result of the PIR, a number of emergency lighting changes were made to ensure each OFN RP-01 7 action has sufficient lighting in accordance with Wolf Creek commitments.

Westinghouse Tech Bulletin TB-04-22, Reactor Coolant Pump Seal Performance- App R Compliance and Loss of All Seal Cooling and WCAP 10541, Reactor Coolant Pump Seal Performance FollowingA Loss of All AC Power, NRC IN 2005-14, FP Findings on Loss of Seal Cooling to Westinghouse RCPs.

Basis - These documents describe industry positions on reactor coolant pump seal cooling. Because of the uncertainty of where the NRC may go in the future with RCP seal cooling issues, Wolf Creek decided to deviate from SLNRC 84-0109 and not restore seal cooling in response to a control room fire. Rather, Wolf Creek will use a natural circulation cooldown and provide RCS makeup and boration through the Boron Injection Tank (BIT) flow path, rather than the seal injection flow path, Revision 22 of OFN RP-017 made this change. The use of natural circulation to cooldown will not adversely impact the ability to achieve and maintain safe shutdown.

m/n. PIR 2005-3314 (laterconverted to PIR 2007-003037in PILOT), Failureto Address NRC Information Notice 92-18.

Basis - This PIR was written to address URI 2005008-06, which was given to Wolf Creek during the Fall, 2005, NRC Triennial Fire Protection Inspection. Wolf Creek has responded to this issue by modifying the control circuit on 36 motor operated valves so a hot short from a fire in the control room will not bypass the valve protective features and prevent operation of the valve.

Design Basis Document for Procedure OFN RP-017 Page 16 of 102 E 1,F0645, Rev-.

NRC IN92-18 identified a concern where a control room fire could cause the spurious operation of motor operated valves due to hot shorts that bypass the valve protective features. The hot short, if sustained, could cause valve damage in a manner that prevents the valve from being manually operated to its desired position. Therefore, the ability to achieve safe shutdown after a control room fire could be compromised.

Wolf Creek initially responded to the IN by crediting the modifications that were done prior to startup in which the NRC required the installation of a number of isolation switches.

However, these modifications did not address the concerns raised in IN 92-18. In April 1999 the NRC conducted an inspection at Callaway and questioned.their response to IN 92-18, which was the same response given by Wolf Creek. As a result, Wolf Creek initiated PIR 1999-1245 to take another look at the issue. The PIR was closed in March 2001 with no actions taken due to the ongoing industry discussions with the NRC on the issue of hot shorts, as well as a moratorium placed on circuit inspections by the NRC. The PIR closure statement said that a new PIR will be generated when the industry initiative to address the issue is completed.

The NEI and EPRI conducted testing in 2001 to gain a better understanding of the issue of hot shorts causing spurious actuations. The testing found that under certain fire conditions, spurious actuations could occur due to hot shorts. In January 2005 the NRC resumed inspections of fire-induced safe shutdown circuits. However, the IN 92-18 issue remained unresolved at Wolf Creek and, until PIR 2005-3314 was written, a new PIR was not written as stated in PIR 1999-1245.

o. PIR 2007-003003, PotentialLoss of Field Flashingon Train B Emergency Diesel Generator Basis - This PIR (originally PIR 2005-3333) was written to identify a condition where field flashing could be lost on the Train B EDG due to a fire in the control room. Since Train B is the protected train in the event of a control room fire, this could have an adverse impact on the ability to achieve safe shutdown. Change Package 12097 was prepared and implemented to modify the control circuit and add a control room isolation switch (KJHS01 10) and redundant fuses on the circuit to ensure the availability of field flashing.

p. PIR 2006-000860, PotentialLoss of Train B Emergency Diesel Generatorduring Control Room Fire Basis - This PIR was written after it was discovered that a control room fire could cause a hot short in the EDG shutdown circuit that could stop the EDG during the event. Since Train B is the protected train in the event of a control room fire, this could have an adverse impact on the ability to achieve safe shutdown. The control room portion of the circuit was only partially isolated by hand switch KJHS0109, which left it vulnerable to a control room fire. Change Package 12097 was prepared and implemented to modify the circuit to provide full isolation from the control room.

q. PIR 1998-3012, VCT Outlet Valve Did Not Have Redundant Control Power Fusing. LER 98-004-00, Verifying BG LCV 112C Closed Basis - This PIR identifies a concern where OFN RP-01 7 directed operators to close BGLCV01 12C using local hand switch BGHS01 12C. However, because the control power circuitry does not contain redundant fusing, control power could be lost, resulting in failure of the valve to close.

Prior to revision 27, OFN RP-01 7 had operators try the hand switch then open the breaker once sufficient time has passed for the valve to close. Another operator then followed up and verified the valve was closed and manually closed it if it was not closed.

Design Basis Document for Procedure OFN RP-017 Page 17 of 102

&I1F-0-15, Rev. 4 DCP 12131 was implemented to add a redundant fuse to the circuit so that operation of BGHS01 12C will close the valve. Therefore, the actions to open the breaker and manually close the valve have been removed from OFN RP-017.

r. E-IF9915, Design Basis Document for OFN RP-01 7, Control Room Evacuation This document describes the basis for OFN RP-01 7.

s. Engineering Disposition,PFSSD Issue With Voltage Regulator (CR 00023410)

Basis - This CR identifies a concern where a fire in the control room could have affected the Train B EDG voltage regulator and could have energized the unit parallel relay, placing the EDG in droop mode of operation. The control circuitry was found to not have sufficient isolation capability to ensure the Train B EDG will be available in the event of a control room fire. A temporary modification (TMO 10-004-NE) was implemented and OFN RP-017 was revised to address the issue. A permanent modification will be implemented at a later date.

The temporary modification installed jumper in panel NE0106 to bypass the control room circuitry for the null meter and the Auto/Manual voltage regulator selector switch. This ensures a control room fire will not damage the voltage regulator.

The procedure change added Step C7 to remove the break glass cover from the emergency start pushbutton (KJ HS-101 D) to energize the ESA and ESB relays to de-energize the UPR relay. This action will also energize relay 90 VEP which disables the control room auto/manual raise/lower voltage control switches and ensures a control room fire will not cause a hot short that sends a raise or lower signal to the voltage regulator.

t. Calculation SA-08-06, Rev. 2, Retran 3D Post-FireSafe Shutdown (PFSSD)Consequence Evaluation for a Postulated Control Room Fire.

Basis - This calculation demonstrates the thermal-hydraulic performance of the plant during a postulated control room fire that causes spurious operation of equipment. The results of the calculation are used to determine the maximum allowed time to mitigate a spurious operation. These times are utilized throughout Table 7.1.

7.3.2 OFN RP-017, Section 3.2- Commitments

a. Letter SLNRC 84-0109, Fire Protection Review RCMS #1985-118 [Entire Procedure]

Basis - SLNRC 84-0109 provides the original licensing basis for response to a control room fire and shutdown from outside the control room. The letter assigned 6 phases to the time critical actions within the letter. Procedure OFN RP-01 7 no longer uses phases. The timing is now based on thermal hydraulic calculations, which provide more realistic time response criteria to the potential spurious operations that could occur in the event of a fire in the control room. Therefore, all mention of phases has been removed from the procedure. The new timing requirements are described in Table 7.1.

Letter SLNRC 84-0109 should remain in this section because of other commitments within the letter. These commitments are described throughout this document where applicable.

b. SLNRC 84-0109 change to commitment RCMS #1988-201 Basis - See 3.1 .f above.

Design Basis Document for Procedure OFN RP-017 Page 18 of 102 S-1F0915, Rev. 4

c. PIR 2005-3209, and LER 2005-006, Unanalyzed Condition Related To Loss Of RCP Seal Cooling DuringA PostulatedAppendix R Fire Event. (Removes steps from procedure for RCP seal restoration)

Basis - An Apparent Violation (AV) issued by the NRC during the 2005 Triennial Fire Protection Inspection identified a concern where Revision 21 of OFN RP-01 7 may not have been able to restore seal cooling prior to seal damage occurring. The current procedure does not restore seal cooling in response to a control room fire. Rather, the RCPs are stopped, the seal injection flow path is isolated, RCP thermal barrier is isolated from the CCW system, RCS makeup and boration is accomplished through the BIT flow path and natural circulation cooldown is used. The thermal hydraulic calculations show that stable hot standby conditions are achieved using OFN RP-017.

7.4 Step-by-Step Review Table 7.1 provides a detailed evaluation for each Step in OFN RP-017 per the Methodology in Section 3.0.

Design Basis Document for Procedure OFN RP-017 Page 19 of 102 E 1F9916, Roy.-4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) (Note )(rain) Complete (Note 2) Steps Wolf Creek USAR, Appendix 9.5E, Response to Section III.L states, inpart: "...Adequate Operations shift staffing is provided to achieve and maintain post-fire safe shutdown..."

10CFR50, Appendix R, Section III.L.4 states, inpart, The fire brigade is "...The number of operating shift personnel, exclusive dedicated to fighting of fire brigade members, required to operate such the control room fire. equipment and systems shall be on site at all times.

They are not NOTE responsible for N/A The Wolf Creek Technical Requirements Manual N/A N/A N/A N/A performing any of the (TRM), TR 5.2.1.b states inpart: "Asite Fire Brigade operator actions of at least 5 members shall be onsite at all times ...

described inthis The Fire Brigade shall not include the Shift Manager procedure. (SM), and the two other members of the minimum shift crew necessary for safe shutdown of the Unit and any personnel required for other essential function during an emergency."

Note that four operators, besides the SM, are required to complete OFN RP-017.

Design Basis Document foar Procedure OFN RP-017 Page 20 of 102 E 1F9916, Roy.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP (Note 1)(mn Complete (Note 2) Steps (min)

Check Control Roam The decision to evacuate is made by the Shift Evacuation Due To Fire Manager based on environmental conditions and/or SREQUIRED the ability to control the plant from the control room

Annunciators and (CR). There is no regulatory basis for when the CR status panels - NOT should be evacuated.

READABLE FROM The Wolf Creek SER, Supplement 5, page 9-10 states "AT THE CONTROLS" N/A inpart: "The new procedures assume that evacuation N/A N/A N/A N/A of the control room takes place when the fire starts..."

Spurious equipment It is not realistic to assume the control room operators actuations - will evacuate as soon as a fire starts. Only the control OBSERVED room staff can make the decision to evacuate based Loss Roomofcontrols Control- on conditions. Therefore, OFN RP-017 can useprovides guidelines that the Shift Manager for deciding IMMINENT when to evacuate.

Generic letter 86-10, response to question 3.8.4 states, in part: "...Note that the only manual action in the control room prior to evacuation usually given credit for is the reactor trip. For any additional control room actions deemed necessary prior to evacuation, a Trip The Reactor demonstration of the capability of performing such actions would have to be provided..." The reactor is 2 0 SB HS-1 R In a memo from the NRC to KG&E dated August 31, 0 assumed tripped at No N/A a SB HS-42 1984, which documents the minutes of an August 22, 1984 meeting with KG&E and UEC, the NRC provided clarifications of staff positions discussed during the meeting. One of those positions is as follows:

Credit can be taken only for a manual scram before leaving the control room.

Design Basis Document for Procedure OFN RP-017 Page 21 of 102 E 1F9916, Rev-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS mTo e (ote Prereq (omi)ple Tomlt TIMING BASIS (Note Impact? 2) Steps Stp (Note 1)

Based on this staff position, the NRC acknowledged that the reactor will trip when the switches are depressed prior to evacuating the control room.

Hand switches SB HS-1 and SB HS-42 are located on separate panels. SB HS-1 is located on RL003 while SB HS-42 is located on RL006. There is a 2 foot air gap between the panels as well as metal outer covers that will restrict the spread of fire between panels.

Automatic smoke detection is present ineach panel, which will provide early warning of a fire. Inaddition, the control room is constantly attended. A fire inone panel is unlikely to spread to the other due to the physical separation present.

Drawing E-1 3SB1 2A shows a schematic diagram of the reactor trip switch wiring. Each switch has two normally open contacts per train. Two out of four contact closures on one out of two trains actuates the reactor trip function at panel SB1 02A or SB1 02B, located outside the control room. Two contacts on each switch are on separation group 1 and two contacts are on separation group 4. Physical separation between each group is maintained in accordance with IEEE 384 to ensure a fire that affects one group will not affect the other.

The positioning of the reactor trip switches on separate panels and the arrangement of the switch contacts and wiring provides reasonable assurance that one of the switches will successfully trip the reactor.

L ________________ L_______________________ I. _____________ L ___________

Design Basis Document for Procedure OFN RP-017 Page 22 of 102 E 1F9911, Rev*.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

Generic letter 86-10, response to question 3.8.4 states, inpart: "...Note that the only manual action in the control room prior to evacuation usually given credit for is the reactor trip. For any additional control room actions deemed necessary prior to evacuation, a demonstration of the capability of performing such Yes. The actions would have to be provided. Additionally, SA-08-006 MSIVs assurance would have to be provided that such assumes this step could actions could not be negated by subsequent spurious will be completed spuriously Close MSIVs actuation signals resulting from the postulated fire." approximately 5 open or

AB HS-79 Hand switches AB HS-79 and AB HS-80 are located seconds after the remain 3 R,M,D on RL006, which also has one of the two reactor trip 5 sec reactor trip switches open after N/A AND hand switches (SB HS-42). Therefore, due to the are depressed. the

AB HS-80 close proximity between the reactor trip hand switch See Section 6.1 for switches and the MSIV close hand switches, it is reasonable to discussion on the have been conclude that actuating both hand switches is possible timing basis for actuated.

prior to exiting the control room. MSIV closure. See Step Credit is not given for actual MSIV closure since D15.

spurious actuation could occur as a result of the control room fire. Therefore, Step D15 provides instructions to close them ifnot already closed. For a single failure not involving the MSIVs, SA-08-006 assumes the MSIVs close inStep 3.

Shift Manager proce d The Shift Manager (SM) proceeds directly to the ASP N/A N/A N/A N/A 4 to ASP and direct N/A to direct performance of OFN RP-017.

personnel.

Design Basis Document for Procedure OFN RP-017 Page 23 of 102 E lF9916, Rev-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 2) Steps (NoteComplete(Note 1)(min)

The Gaitronics system is the preferred method to announce the fire and call out the fire brigade. The Gaitronics control panel is located inthe back panel area of the control room on the far South wall, remote Announce the from the main control room area. Afire inthe main evacuation of the control room area, inthe absence of a loss of offsite 4.a Control Room due to N/A power, will not affect the ability of the Gaitronics N/A N/A N/A N/A fire and entry into OFN system to announce the fire and call out the fire RP-017 using Plant brigade due to the physical separation of the control Gaitronics handset panel (QF076) and power cables. However, a loss of offsite power to NG01, NG02, PG19 and PG20 will prevent operation of the system. Therefore, an RNO is provided to ensure timely callout of the fire brigade and notification of control room evacuation.

IFGaitronics is not working, THEN perform the following:

1)vActonusinge Announce This RNO provides instructions to ensure all available 4.a RNO public address system. N/A means are used to call out the fire brigade and commence OFN RP-017 actions ifthe Gaitronics N/A N/A N/A N/A

2) IFannouncement system is unavailable.

cannot be made, THEN dispatch runners to notify OFN RP-017 personnel.

4.b Repeat announcement. N/A The Operator repeats the announcement to ensure it N/A N/A N/A N/A is heard.

Design Basis Document for Procedure OFN RP-017 Page 24 of 102 E I FOS!6, Rey. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min) 4.c Check Fire Brigade - N/A The Operator ensures the fire brigade has been called N/A N/A N/A N/A CALLED OUT out successfully and, ifnot, performs the RNO actions.

Perform the following:

1) Make the following announcement using the Public Address System

" Fire Fire.

"Fire Fire inControl Room. Fire Brigade members assemble at turnout lockers" This RNO provides alternative methods to notify the 4.c RNO 2) Repeat Public N/A fire brigade and provides instructions to ensure the N/A N/A N/A N/A Address System off-site fire department is called out ifthe fire brigade isdelayed or cannot be contacted.

Announcement.

3) ILFFire Brigade cannot be contacted, THEN dispatch runners to alert FB members.

4) Request assistance from Coffey County Fire Department.

Telephone number 911

Design Basis Document for Procedure OFN RP-017 Page 25 of 102 E !F9916, Roy.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1)(mn Complete (Note 2) Steps (min)

Classify the event using 4.d EPP 06-005, N/A The SMs duty at this point is to classify the event and N/A N/A N/A N/A EMERGENCY initiate the emergency plan.

CLASSIFICATION.

4.e Supervise performance N/A After the emergency plan has been initiated, the SM N/A N/A N/A N/A of this procedure. supervises performance of OFN RP-01 7.

SRO proceed to ASP The Senior Reactor Operator (SRO) is responsible for 5 via CAS and direct N/A performing the actions of Attachment A inOFN RP- N/A N/A N/A N/A personnel. 017.

Obtain the following equipment from Control Room emergency locker for personnel entering the RCA:

Low-Range PIC 0

- 500 mR This step ensures those exiting the CR through CAS

High-Range PIC obtain the proper radiation monitoring and safety gear.

5.a 0-5 R N/A The SRO is required to operate 480 VAC breakers on N/A N/A N/A N/A

" Record Dose his/her way to the ASP so it will be necessary to don a Dosimeter (RDD) fire resistant suit and leather gloves.

" Fire resistant Suit (SRO)

Leather gloves (SRO)

Hard hat

Design Basis Document for Procedure OFN RP-017 Page 26 of 102 E !F9916, Roy.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP IN OFN RP-017 Req'd Time CR Fire To TIMING BASIS Impact? Prereq BASIS Complete (Note 2) Steps (min)

CAS is evacuated to prevent security personnel from N/A N/A N/A N/A being overcome by smoke.

The SRO proceeds to the ASP through CAS and enters room 1512, where NG03C is located.

On NG03C, place the Therefore it is feasible for the SRO to perform these following breakers to OFF: actions before proceeding to the ASP.

These breakers are placed inthe OFF position to See Section 6.3 for

" NG03CEF4 for AL discussion of timing ensure power is disconnected to the associated Train HV-36, Supply basis for aligning From Cond Stor A valves. This will prevent the valves from spuriously operating prior to and after the valve is manually auxiliary feedwater.

Tk Water operated inanother step.

5.c

NG03CHF3 for EG D,S N/A No N/A HV-15, CCW If,prior to performing this step, the valve spuriously See Section 6.5 for Return From operates to the undesired position, the valve can still discussion of timing Nuclear Aux be manually operated. Valve damage will not occur basis for aligning Components due to circuit modifications completed per change component cooling packages 12130 (EG HV-61) and 12170 (AL HV-36 water.

" NG03CKF3 for EG and EG HV-15) inresponse to NRC IN92-18 (PIR HV-61, CCW 2007-003037).

CTMT ISO VLV For additional information on these specific valves see Steps B7, B10 and D5.

L ________ L _____________________________________ __________ L______________ ________ _______

Design Basis Document for Procedure OFN RP-017 Page 27 of 102 E 1F9916, Roy-.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP.017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 1) Complete (an (Note 2) Steps (min)

Operators will generally communicate via radio.

Therefore, the SRO obtains a radio from the Pick up radio from emergency locker.

5od emergency locker outside ASP and select N/A The radio system is unaffected by a fire inthe control N/A N/A N/A N/A Channel 1. room. Therefore, the radio system is a reliable means of communication. Channel 1 is used because it is the Operations channel.

Perform actions of The SRO is responsible for performing the actions of 5.e ATTACHMENT A,SRO N/A Attachment A inOFN RP-01 7. N/A N/A N/A N/A ACTIONS On-Shift Personnel 6 Perform Designated N/A N/A N/A N/A N/A N/A Actions:

Operator performing Turbine Building actions, proceed to 6.a PAO1/PAO2 and N/A N/A N/A N/A N/A N/A perform actions of ATTACHMENT B, TURBINE BUILDING ACTIONS Reactor Operator, proceed to NK switchgear rooms and 6.b perform actions of N/A N/A N/A N/A N/A N/A ATTACHMENT C, REACTOR OPERATOR ACTIONS

Design Basis Document for Procedure OFN RP-017 Page 28 of 102 E IF9915, RAI. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1)

(min)

Operator performing Aux Building actions, proceed to emergency 6.c locker 2026' level and N/A N/A N/A N/A N/A N/A perform actions of ATTACHMENT D, AUXILIARY BUILDING ACTIONS Offsite Communicator, proceed to Aux The Wolf Creek emergency plan requires an offsite N/A N/A N/A N/A 6.d Shutdown Panel until N/A communicator.

released by Shift Manager CR 00019239 identified an issue involving the time to close valve BN HV-8812A. The valve requires approximately 600 turns of the handwheel to close.

Operations Standing Order #1 limits the handwheel Operator closing BN speed to 60 revolutions per minute. Therefore, the HV-8812A, RWST TO minimum time to close is 10 minutes, but due to the RHR PUMP A location of the handwheel and potential fatigue of the SUCTION ISOLATION operator, it will likely take longer. Therefore, itwas 6.e VALVE proceed to ESF R,M decided to add an extra operator to this procedure to N/A N/A N/A N/A Switchgear Room B perform this action. This operator will also be and perform actions of responsible for opening the breaker to the valve. Due ATTACHMENT E, BN to the length of time necessary to close the valve, this HV-8812A CLOSURE. operator should not be given any other OFN RP-01 7 duties prior to getting BN HV-8812A closed.

Design Basis Document for Procedure OFN RP-017 Page 29 of 102 EIF-9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'dToTime CR Fire STEP DESCRIPTION Function (Note 1) BASIS Complete TIMING BASIS Impact?

(Note 2) Prereq Steps (mrin)

These hand switches are used to isolate certain components from the control room. The switches, when placed inISO. CTRL. ROOM position, energize lockout relays (LORs) and change the position on a number of contacts located inthe control circuit for these components. This ensures a fire inthe control room will not affect the isolated components after the hand switch is actuated. This step Place Following establishes control Switches In ISOLATE: The LORs are powered from DC batteries (NK). The of the isolated batteries are sized to supply power to all emergency components from

" RP HIS-1 CTRL loads for 200 minutes following loss of ac power per the auxiliary ROOM ISO E-10NK. Loss of offsite power will not affect the shutdown panel LORs.

SWITCH - (ASP). The timing ISOLATE RP HIS-1 performs the following functions: basis depends on Al " RP HIS-2 CTRL R,M, D,

Isolates valve FC HV-312 (TDAFP Trip and N/A when the isolated No N/A ROOM ISO P,S Throttle Valve) from the control room. components are SWITCH - required to be

Isolates main steam to TDAFP supply valves AB ISOLATE operable, which is

RP HIS-3 CTRL HV-5 and AB HV-6 from the control room.

" Isolates AB PV-2 indication from the control discussed inthe ROOM ISO steps that follow.

room. AB PV-2 position indication at the ASP is SWITCH - Therefore, there is independent of the control room. RP HIS-1 ISOLATE no timing basis for isolation is not required. ARV position indication is not credited for PFSSD. ARV position is this step.

determined by controlling the ARV using the controller at the ASP and monitoring RCS temperature.

Isolates FC FV-313 (TDAFP Speed Governing Valve) position indication from the control room.

I _____________________________________________________________

I. ________________ I _______________________ _____________ I.___________

Design Basis Document for Procedure OFN RP-017 Page 30 of 102 E-IF9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1) Note 1)(rain)

RP HIS-2 performs the following functions:

Isolates BG HV-8152 (Letdown Isolation Valve) from the control room.

Isolates the trip portion of NB0208 handswitch PG HIS-21. However, NB0208 could trip and the control power fuses could blow before RP HIS-2 is operated. This would prevent operation of pressurizer backup heater group B from the ASP.

Ifthis occurs, operators will need to manually close NB0208 to energize PG22. NB0208 is dosed inStep C10.

Isolates valves AL HV-30, AL HV-33 and AL HV-34 from the control room and adds a redundant fuse inthe circuit.

Isolates AB PV-4 indication from the control room. AB PV-4 position indication at the ASP is independent of the control room. RP HIS-2 isolation is not required. ARV position indication is not credited for PFSSD. ARV position is determined by controlling the ARV using the controller at the ASP and monitoring RCS temperature.

" Isolates MDAFP B from the control room and adds redundant fuses inthe circuit. However, this method of controlling the Train B motor driven auxiliary feedwater pump is not credited in OFN RP-017. Rather, the B MDAFP is started by dosing breaker NB0205 inStep C14.

-A .1. _________________________________________________________________

U .1 U J ____________

Design Basis Document for Procedure OFN RP-017 Page 31 of 102 E-ir-9945,-4ke.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note1)(rain) Complete (Note 2) Steps (Note 1)

RP HIS-3 performs the following functions:

Isolates PG2201 control circuit from the control room. PG2201 supplies power to pressurizer heater backup group B. Isolation of the PG2201 control circuit using RP HIS-3 allows operation of the heater group using BB HIS-52B at RP118B.

The heaters are used inStep A.7 RNO to maintain pressurizer pressure. Isolation of the heaters prevents spurious operation and ensures availability when needed. PG2201 is powered from NB0208 which is closed in Step C10.

Design Basis Document for Procedure OFN RP-017 Page 32 of 102 E 1F9916, Roy.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 1)(min) (Note 2) Steps (Note 1)_Complete SA-08-006 assumes this step will be completed within 7 minutes ifa single failure occurs Close SIG A And C The control circuit for these valves is not isolated from that does not ARVs: the control room by operation of AB HS-1 and AB HS-involve an ARV

3. Therefore, AB PV-1 and AB PV-3 could remain circuit. Therefore, it

a. AB HS-1 SG A open. Steps D18 and D19 direct operators to isolate STEAM DUMP CTRL is assumed that Yes. A air and nitrogen to the valves then bleed air from the XFR - LOCAL regulator to fail the valves closed. Ifthis method fails, ARVs 1 and 3 will control be closed in7 room fire operators are directed to close AB-V018 and AB-

b. AB HS-3 SG C minutes inthis step could V029. Isolating air and nitrogen provides a faster STEAM DUMP CTRL and that the control prevent A2 method of dosing the valves.

XFR-LOCAL R, M,D 7 room fire will not closure or N/A Control power to AB PIC-1 B originates from NNO1 16, impact the ability to cause the

c. AB PIC-I B SG A which is powered from the NK01 1 batteries. close the ARVs re-opening Therefore, power will be available to perform this from the ASP. SA- of ABPV1 STEAM DUMP TO ATMS CTRL- CLOSED action.08-006 also shows and Control power to AB PIC-3B originates from NN0303 that a single failed ABPV3.

d. AB PIC-3B SG C which is powered from the NK013 batteries. open ARV can go STEAM DUMP TO Therefore, power will be available to perform this unmitigated for at ATMS CTRL- CLOSED action. least 1-hour. See Section 6.1 for discussion of timing basis for controlling the steam generator ARVs.

-I. ____________ L ____________________________________________________________ J _________________ I _______________________ .1_____________ 1 ___________

Design Basis Document for Procedure OFN RP-017 Page 33 of 102 E !F9915, Ro" TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1) (min)

Check RCS Cold Leg The steam generator ARVs, ifunaffected by a fire, Temperatures: control temperature to 561 OF.Temperature A3 STABLE AT OR D instrument BB TI-423X is used to monitor cold leg N/A N/A N/A N/A TRENDING TO 561 OF temperature on loop 2. The circuits for this temperature indicator are independent of the control e BB TI-423X room.

Design Basis Document for Procedure OFN RP-017 Page 34 of 102 E !F9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1) (mrin)

Perform the following:

a. IFtemperature greater than 561 OF, THEN dump steam using S/G B and S/G D ARV's:

ARVs AB PV-2 and AB PV-4 are isolated from the

1) ABHS-2SGB control room by placing AB HS-2 and AB HS-4 in STEAM DUMP LOCAL position. Auxiliary feedwater is assured to SA-08-006 CTRL XFR -

LOCAL steam generators B and Dusing the Train B MDAFP assumes and the TDAFP. The Train B MDAFP is started in atmospheric steam

2) ABHS-4SGD Step C14. The TDAFP is started inStep A14. dump control on STEAM DUMP steam generators B Control power for AB PIC-2B originates from NN0203 CTRL XFR - and Dis A3 RNO which is powered from NK02. Therefore, power will LOCAL D remain available from the NK012 batteries. 7 established at the No N/A ASP within 7 Redundant power is available from NG02A.which is

3) AB PIC-2B - minutes. See energized inStep Cl 1.

THROTTLED Section 6.1 for Control power for AB PIC-3B originates from NN0404 discussion about OPEN which is powered from NK04. Therefore, power will steam generator

4) AB PIC-4B - remain available from the NK014 batteries. ARVs.

THROTTLED Redundant power is available from NG02A which is OPEN energized in Step C11.

b. IFtemperature less than 561 OF AND temperature decreasing, THEN stop dumping steam. L _____ I ______________________ I ______ I ________ _____ t ____

Design Basis Document for Procedure OFN RP-017 Page 35 of 102 E-IF9915, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note1)(rmin) Complete (Note 2) Steps (Note 1)

The control circuit for this valve is isolated from the control room by operating RP HIS-2 inStep Al. The 15 minutes See Section 6.3 for Check CST to MD control circuit has been modified to address NRC IN to start the timing basis for A4 AFP B- OPEN 92-18 (PIR 2005-3314). pump and establishing AL HIS-34B - MDAFP B is lined up to supply feedwater to steam inject into auxiliary feedwater OPEN generator D. Step C13 restores power to AL HV-34 steam using Train B MCC cubicle NG04CNF1. The valve may not open generator D MDAFP.

until Step C13 is completed.

Verify AFW Valve Lineup For MD AFP B: Operation of AL HS-5 to the LOCAL position allows control of valve ALHV0005 from the ASP.

a. SG DAUX FW XFR CTRL VLV Power to valve AL HV-5 is from NG04CCF2. The 15 minutes See Section 6.3 for valve is normally full open and can be throttled to to start the timing basis for A5 o AL HS o control flow into the steam generator. Loss of power pump and establishing No N/A LOCAL will fail the valve as is and will prevent control of the inject into auxiliary feedwater valve from the ASP until power is restored to NG04C. steam using Train B

b. SG D MD AFP AFW Power is restored instep C13. This will have no generator D MDAFP.

REG VLV CTRL adverse impact since the Train B MDAFP is not started until Step C14.

o AL HK-5B-OPEN Notify Reactor The Reactor Operator, in Step C14, ensures Steps A4 15 minutes See Section 6.3 for Operator That Motor and A5 are complete before starting the Train B motor to start the timing basis for A6 Driven AFW Pump B D driven auxiliary feedwater pump. Valve lineups in pump and establishing N/A N/A Valve Lineup Steps Steps A4 and A5 establish a suction source from the inject into auxiliary feedwater A4 Through A5 Are CST and a discharge path to SG D and need to be steam using Train B Complete complete before Step C14 is complete. generator D MDAFP.

Design Basis Document for Procedure OFN RP-017 Page 36 of 102 E 1F9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP(FuNton BASISComplete (Note 2) Steps t 1) (mrin)

Maintain Stable Plant Conditions:

Hot standby is maintained using procedure OFN RP-

a. PZR pressure - 017 by ensuring parameters are within the ranges BETWEEN 2000 PSIG listed. Diagnostic instrumentation is available as AND 2300 PSIG described below.

0 BB PI-406X a. The only pressurizer pressure indicator at the ASP is on the Train A side (BB PI-455B), which is not

b. PZR level - protected from a control room fire. RCS pressure BETWEEN 25% AND indicator BB PI-406X is located on the Train B ASP 70% and is unaffected by a control room fire. Therefore, BB PI-406X is used inthis step to verify RCS

BB LI-460B pressure.

A7 R,M,D, N/A N/A No N/A P b. Pressurizer level is indicated by BB LI-460B on the

c. S/G Wide Range Train B ASP and is unaffected by a control room fire.

Levels BETWEEN 60%

AND 62% c. OFN RP-017 uses steam generators B and Dfor shutdown from outside the control room. Wide range

AE LI-502A level indicators AE LI-502A (SG B)and AE LI-504A

AE LI-504A (SG D)are located on the Train B ASP and are unaffected by a control room fire.

d. RCS cold leg d. RCS cold leg temperature is monitored at the Train temperatures - B ASP using temperature indicator BB TI-423X (Loop BETWEEN 551°F AND 2 cold leg). This TI is unaffected by a fire inthe 561°F control room.

BB TI-423X I

-~ ________ .1~_______________________________________ L __________ L L ________ _______

Design Basis Document for Procedure OFN RP-017 Page 37 of 102 E 1F9915, Rev-.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 1)(min) (Note 2) Steps (Note 1)_Complete

a. Per SA-08-006, pressurizer heater backup group B is assumed to be controlled within

a. Cycle PZR HTRS 11.5 minutes.

B/U GP B as necessary to restore PZR b. SA-08-006 pressure shows that the most

a. Ifpressurizer pressure is below 2000 psig, the challenging

BB HIS-52B backup group B pressurizer heaters are cycled to scenario for restore pressure. Step C10 restores power to the pressurizer level is

b. WHEN BIT is heaters and will need to be complete before this step a. 11.5 a single steam aligned, THEN direct can be completed. generator ARV a. N/A A7 RNO R, M No Operator performing opening coincident

b. 10 CFR 50, Appendix R requires pressurizer level b. D4 Turbine Building b. 28 with an immediate to remain on-scale. To maintain pressurizer level on actions to control level automatic AFAS(T) scale, an operator needs to throttle the BIT outlet locally: and a loss of offsite valve to control flow. The valve is throttled inStep power. Pressurizer B13.

Throttle BIT outlet level does not drop valve off scale low as long as the CCP is o EM HV-8801B started and BIT injection is lined up in 28 minutes. See Sections 6.1 and 6.2 for discussion about charging.

-L ________ 1 _______________________________________ __________ _______________ 1 ________ L _______

Design Basis Document for Procedure OFN RP-017 Page 38 of 102 E 1 F99156, R"y TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 1) Complete (Note 2) Steps (mrin)

IfAL HV-6 opens, the TDAFP would supply AFW to steam generator Dinaddition to MDAFP B. Flow controller AL FC-5 will limit flow to the steam generator to 300 gpm and will throttle AL HV-5 accordingly. Circuits for this function are not run inthe control room and, therefore, are unaffected by the fire.

However, the controller will not function until power is restored to NG04C inStep C13. Inthis case, Yes. AL operators may have to manually close AL HV-6. The HV-6, AL TDAFP is designed to supply all four steam Closing valves HV-7, AL CAUTION generators so flow diversion to SG Dwill not impact ALHV-6, 7, 8 and HV-8 and PFSSD. 12 is not time o AL HV-6, AL HV-7, AL HV-12 critical as discussed AL HV-8 and AL HV-12 IfAL HV-7 opens, water would be directed to SG Avia are not inthe Basis.

are not isolated from MDAFP B. The MDAFP B is sized to supply both SG isolated N/A Therefore, the control room and D Aand SG D,so sufficient flow would be directed to N/A from the N/A operators can may spuriously actuate. SG D for safe shutdown. With flow being directed to control SG Aand with the SG A ARV not being used, the SG mitigate spurious It may be necessary to room.

operation of these manually isolate these could fill solid. However, with the SG filled solid, This will valves when all valves. PFSSD is still assured. not time critical actions IfAL HV-8 opens, the same result would occur as with adversely are complete.

AL HV-7 opening, except the water would come from impact the TDAFP. The TDAFP is designed to supply all four PFSSD.

steam generators. Therefore, ifvalve AL HV-8 spuriously opens, PFSSD is still assured.

IfAL HV-1 2 opens, water would be directed to SG C via the TDAFP. However, with flow being directed to SG C and with the SG C ARV not being used, the SG could fill solid, which is not desirable. However, with the SG filled solid, PFSSD is still assured. The

Design Basis Document for Procedure OFN RP-017 Page 39 of 102 E 1F9916, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

TDAFP is designed to supply all four steam generators. Therefore, ifvalve AL HV-1 2 spuriously opens, PFSSD is still assured.

As stated earlier, AL HV-33 is isolated from the control Check ESW To TD room using RP HIS-2. Step C13 energizes valve AFW Pump cubicle NG04CCF4, so the valve may not close until This action is not Isolation Valve - Step C13 is completed. time critical. As A8 CLOSED D A failed open valve will not impact PFSSD. The N/A stated ifthe valve intheopens Basis, No Al A

preferred source of auxiliary feedwater is the CST. PFSSD is still o AL HIS-33B However, ESW is the safety-related source. This assured.

CLOSED action is for commercial concerns to ensure raw untreated ESW water does not enter the SGs.

Contact Operator 35 minutes Performing The SRO ensures a suction supply from the CST is to start the See Section 6.3 for A9 Attachment B To D available before starting the TDAFP. Step B7 opens pump and timing basis for the No N/A Verify AL HV-36 Open the valve after ensuring control power is de-energized inject into ti af oN inStep 5.c. steam

. AL HV OPEN generator B

Design Basis Document for Procedure OFN RP-017 Page 40 of 102 E 1IF99115, Rev-.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION j(Note Function SNFto 1)

BASIS BS To Complete (m)in)

TIMING BASIS Impact?

(Note 2)

Prereq Steps Perform the following:

a. Close AFW Pump Turbine Mechanical Trip/Throttle Valve.

FC HIS-312B

b. Close Loop 2 and Ifthe TDAFP is Loop 3 Steam to AFP running with no Turb. IfAL HV-36 is not open, this RNO directs the operator suction source, to ensure the steam supply to the TDAFP is isolated damage to the A9 RNO " AB HIS-5B to protect the TDAFP. pump could occur.

D N/A No Al

AB HIS-6B Ifthe pump has no Valves AB HV-5, AB HV-6 and FC HIS-312B are suction this RNO isolated from the control room inStep Al. needs to be

c. WHEN CST Supply To TD AFW Pump is completed before open, THEN perform damage occurs.

Steps A10 through A14.

d. Observe note prior to Step A15 and continue with step A15.

Design Basis Document for Procedure OFN RP-017 Page 41 of 102 E-ir-9915, Re.. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1)

(min)

Place TD AFP FC HS-313 transfers control of the TDAFP speed Governor Control to governing valve to the ASP. After the switch is local: manipulated, controller FC HIK-313B can be used to 35 minutes control the TDAFP. to start the See Section 6.3 for A10 0 LCAL D LOCA Control power originates Cotro poer from NN0203, rignats fom N023, which is hic isinject pump into and timing basis for the TDAFP. No N/A powered from NK02. Therefore, power will remain steam 0 Adjust FC HIK- available from the NK012 batteries. Redundant power generator B 313B to Minimum is available from NG02A, which is energized inStep Output Clil.

Verify AFW Valve Lineup For TD AFP:

AL HS-10 transfers control of AL HV-10 to the ASP,

a. SG B AUX FW XFR where AL HK-1OB can be used to control valve CTRL VLV LOCAL position. This valve controls TDAFP flow to SG B, 35 minutes All

ALHS-l0- which is one of the credited AFW flowpaths. to startand pump the See Section 6.3 for LOCAL D Controlpower originates from NN0404 which is inject into timing basis for the No N/A powered from NK04. Therefore, power will remain steam TDAFP.

b. SG B TD AFP AFVV available from the NK014 batteries. Redundant power generator B REG VLV CTRL OPEN is available from NG02A which is energized inStep Cli.

ALHK-10B-OPEN Ensure Loop B Steam 35 minutes Isolation To AFP Valve AB HV-5 is opened to ensure adequate steam 35 minute supply to the TDAFP. RP HIS-1 isolates the valve to start the See Section 6.3 for A12 Turbine Is - OPEN D from the control room and inserts a redundant fuse in pump and timing basis for the No Al A -the circuit. Therefore, the hand switch can be relied into sinject DAFP.

AB HIS-B- Tsteam on to function.

OPEN otofntn.generator B

Design Basis Document for Procedure OFN RP-017 Page 42 of 102 E 1F-9915, Roe.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Valve AB HV-6 is closed because steam generator C is not credited for a control room fire. Continued Ensure Loop C Steam steaming of this steam generator with no feedwater Isolation To AFP flow could result inthe steam generator going dry.

Turbine Is- CLOSED Valve AB HV-5 is opened inStep A12 to provide the A13 D required steam flow to the Turbine Driven Auxiliary N/A N/A No Al

AB HIS-6B - Feedwater Pump. RP HIS-1 isolates the valve from CLOSED the control circuit. Theroom and inserts alternate a redundant power supply to the fuse valveindoes the not run through the control room. Therefore, the hand switch can be relied on to function.

Ensure AFP Turbine Mechaical35 minutes Mechanical Trip/Throttle Valve tto start tr the See Section 6.3 for h

A14 Open D Valve is isolated from the control room and redundant pump and tim bai n for fuses are added using RP HIS-1 inStep Al. inject into timing basis for the No Al, A9 steam TDAFP.

FC HIS-312B -

OPEN generator B Contact Operator Calculation SA Performing Auxiliary feedwater valves AL-V032, AL-V056, AL- 006 shows that the Attachment E, BN H11- V061 and AL-V071 are closed to prevent overfilling steam generators A15 8812A AND AUX D the steam generators. This step has the operator 35 could FEEDWATER VALVE, verify the valves are closed before starting the valvesoverfill are notifthe No N/A CLOSURE To Ensure TDAFP. closed within 35 AFW Valves Areminutes.

closed. __________________________

Design Basis Document for Procedure OFN RP-017 Page 43 of 102 E 1F9916, Re*.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1)(min) Complete (Note 2) Steps (Note 1)

Perform the following:

a. WHEN AFW Calculation SA Va.ves aeA , 006 shows that the N THEN perform A15 Ifthe AFW valves are not closed, The RNO directs the steam generators operator to continue to Step A16 until the valves are 35 could overfill ifthe No N/A

b. Observe notes closed, valves are not prior to step A16 closed within 35 and continue with minutes.

step A16 Establish Turbine Driven AFW Pump Control:

a. Adjust AFW Turbine The TDAFP is credited for supplying AFW to SG B. 35 minutes Speed Governor CTRL FC HIK-313B is used to control TDAFP speed from to start the See Section 6.3 for A16 Output to 60% theASP. Step AI0 transfers control of FC FV-313 to pump and timing basis forthe No Al1, A9, the ASP. Step E4 closes TDAFP to SGs A,C and D inject into TDAFP. A10, E4 o FC HIK-313B valves AL-V056, AL-V071 and AL-V061, respectively, steam to prevent overfill of these steam generators. generator B

b. Adjust AFW pump speed as necessary to establish desired AFW flow

Design Basis Document for Procedure OFN RP-017 Page 44 of 102 E I F9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (min)

Align Alternate AFW Pump Water Source:

a. Check CST below minimum level:

CST level on ASP -

Yes. CST LESS THAN 14%

level 0 indicator AP LI-4B The CST contains This step aligns the ESW system to the AFW pumps AP L-4B sufficient inventory inthe event the CST reaches low level. RP HIS-2 is not OR for PFSSD. This isolates both AL HV-30 and AL HV-33 from the control isolated step is entered only A17

Local CST level - room and adds redundant fuses to the control circuit from the D N/A when the CST Al LESS THAN 6' 5" for each valve. control reaches low level.

room.

There is no timing

b. Open ESW To MD Step C13 needs to be complete to restore power to AL Local level basis associated AFW Pump B Isolation HV-30 and AL HV-33 MCC cubicles. instrument with this step.

Valve may need to be

AL HIS-30B - used.

OPEN

c. Open ESW To TD AFP

AL HIS-33B -S +/- _______________________________________ I __________ I _______________I ________ I _______

Design Basis Document for Procedure OFN RP-017 Page 45 of 102 E 1F991 6, Rev. 4!

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 1)(mn Complete (Note 2) Steps (min)

a. Perform the The RNO is entered when the CST is above minimum following: level. This is a continuous action step which means

1) WHEN CST level the operator at the ASP will continue to monitor CST decreases to less than level and initiate swapover to ESW when required.

Al7 RNO minimum level, THEN D PerTS 3.7.6, the CST is required to contain 281,000 N/A N/A No N/A do Steps Al 5.b and gallons of water, which is sufficient to provide water to the steam generators for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months at hot standby

2) Observe notes prior followed by plant cooldown to RHR entry conditions.

to Step A16 and Therefore, itis not expected that ESW will be needed Scontinue with Step A16. until several hours into the event.

This step was added inOTSC 10-0093 as a result of condition report 31408. Step C16 has operators fully open the B ESW pump room supply damper and start The timing basis Direct Available depends on the Operator to Check B the supply fan. There are no operator actions taken time for the room to for the recirculation damper. This lineup may not be ESW Pumphouse heat up or cool adequate during all times of the year. Inthe winter Temperature down to a point months, drawing in100% outside air with a closed Prior to room where the ESW A18 a. Check room recirculation damper could cause the room reaching temperature greater S pump and N/A N/A temperature to drop below freezing. In the summer undesirable than 650 F associated months, with the recirculation damper open, the room temperature components will not

b. Check room could heat up to an undesired temperature. The operate. See temperature less than temperature range of 65 to 90 degrees F ensures the Section 6.5 for 900 F room temperature remains within the required range.

discussion about These are interim actions until a permanent resolution room cooling.

is determined. Condition Report Action 30350-02-06 is trackinq the resolution of this issue.

Design Basis Document for Procedure OFN RP-017 Page 46 of 102 E5-1F8916, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'dToTime CR Fire Prereq STEP DESCRIPTION Function BASIS TIMING BASIS Impact? Steps Complete (Note 2)

(Note 1) (min)

a. Perform the following:

1) Open breaker This RNO performs the necessary steps to ensure the NG06EEF4 to stop B Train B ESW pump room temperature remains within ESW Pumphouse the required range. These steps are performed Supply Fan locally. Opening NG06EEF4 will de-energize the supply fan and allow the room to heat up ifthe

2) WHEN temperature temperature drops below 650F. When the The timing basis reaches 1000F, THEN temperature reaches 1000F, the operator will re-start depends on the close breaker the fan. time for the room to NG06EEF4 to start B heat up or cool ESW Pumphouse When the room temperature reaches 110 0F, the down to a point Supply Fan Prior to room operator will open breaker NG06EBF208 to fail the where the ESW A18 RNO reaching

b. Perform the S recirculation damper closed, allowing 100% outside air pump and N/A N/A undesirable following: into the room to cool the room. When the temperature associated temperature drops to 650F, the operator will close breaker components will not

1) WHEN temperature NG06EBF208 to re-energize the recirculation damper operate. See reaches 110 0F, THEN to allow it to open. If the recirc damper does not open Section 6.5 for open breaker 8 on due to the fire inthe control room, then the operator discussion about NG06EBF2 to fail can perform the RNO for Step A16.a to increase the room cooling.

Recirc Damper dosed. room temperature.

2) )WHEN temperature reaches These are interim actions until a permanent resolution 65°F, THEN close is determined. Condition Report Action 30350-02-06 breaker 8 on is tracking the resolution of this issue.

NG06EBF2 to enerlgize Recirc Damper.

I .1 4 J

Design Basis Document for Procedure OFN RP-017 Page 47 of 102 E 1F9915, Re..4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1)

(min)

Direct Available Operators To Perform This step is used whenever extra operators are Actions Of available to minimize damage to Train A equipment. N/A ATACTO NSTO FAttachment F is not required by regulation, so its steps PROTET TRN Aare not evaluated inthis DBD.

PROTECT TRAIN A EQUIPMENT The purpose of OFN RP-01 7 is to maintain hot Check plant standby conditions until the fire is under control and A20 cooldown - NOT N/A operations can be resumed from the control room. If N/A N/A N/A N/A DESIRED the event duration does not allow the plant to be maintained in hot standby, then OFN RP-017A is entered, per the RNO.

Go to OFN RP-017A, HOT STANDBY TO A20 RNO COLD SHUTDOWN N/A If necessary, OFN RP-017A is entered to brng the N/A N/A N/A N/A FROM OUTSIDE THE plant to safe cold shutdown.

CONTROL ROOM NRC Draft Regulatory Guide DG-1214 dated April 2009, which is a proposed revision to RG 1.189, Section 5.5.2 has guidance for re-entering and re; A21 Check Fire Has Been N/A establishing control from the Control Room. Steps A- N/A N/A N/A N/A Extinguished. 18 through A-22 were added to OFN RP-017 to identify this guidance. CR 00016481 identified the need to add guidance for re-entry into the Control Room.

A21 RNO Do NOT continue until N/A Continuation inthe procedure is not allowed until the N/A N/A N/A N/A fire is extinguished. fire is extinguished.

Design Basis Document for Procedure OFN RP-017 Page 48 of 102 E 1IF991, Re .4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Reqi'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1)(min) Complete (Note 2) Steps (Note 1)

A22 Check Control Room N/A See Step A19 Basis N/A N/A N/A N/A Habitable Do NOT continue until Habitability must be established prior to allowing N/A N/A N/A N/A A22 RNO Control Room is N/A unprotected operators back into the control room.

habitable.

Assess Control Room A23 Damage. N/A See Step A19 Basis N/A N/A N/A N/A Perform Corrective Actions To Restore A24 Necessary Safety, N/A See Step Al 9 Basis N/A N/A N/A N/A Control And Information Systems To Functional.

Contact TSC To Develop Procedures To Transfer Control From Aux Shutdown Panel To The Main Control A25 Room And To Restore N/A See Step A19 Basis N/A N/A N/A N/A From Any Local Actions Taken Based On Review Of Actions Taken InThe Procedures Performed.

Proceed As Directed A26 By Station N/A N/A N/A N/A N/A N/A Management.

Design Basis Document for Procedure OFN RP-017 Page 49 of 102 E !F9916, Ro'-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps

(Note 1) (min)

The RCPs are tripped to prevent damage to the seals upon loss of all seal cooling. Natural circulation is Locally Trip RCPs used to circulate coolant and to cooldown. Yes. The

PA01 07 for RCP A The breakers are tripped by rotating the local hand breakers

- TRIPPED switch to the STOP position. For this to work, control Based on SA could

" PA0108 for RCP B power needs to be available to each of the breaker 006, the RCPs are spuriously B1 -TRIPPED M control circuits. Control power is removed inSteps B4 7 assumed to be close until N/A

PA0205 for RCP C and B5 after this step is completed. tripped within 7 Steps 84

- TRIPPED minutes. and B5

" PA0204 for RCP D A fire inthe control room could cause a loss of control are

-TRIPPED power and prevent opening the breakers with the local complete.

hand switch. The fire would have to be located in either panel RL021, SB030A or SB033A for this to occur.

Proceed TurbineAndTo 2033 Tobt3 After the RCPs are tripped, the operator proceeds to 82 Copy Of This N/A the emergency equipment locker and obtains a copy N/A N/A N/A N/A Procedure. of OFN RP-017.

Design Basis Document for Procedure OFN RP-017 Page 50 of 102 E-r-F991, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Perform the following:

a. Obtain the following from emergency locker:

Radio

Flashlight A radio is required to ensure communication with the

b. Obtain pocket ion SRO at the ASP. Channel 1 is used by Operations for chambers and an RDD communication. Aflashlight will supplement fixed B3 from the emergency N/A Appendix R emergency lighting inthe event of a loss N/A N/A N/A N/A locker for personnel of off-site power.

entering the RCA Dosimetry is required for personnel entering the RCA.

Low-Range PIC 0-500 mR

" High-Range PIC 0-5R

RDD

c. Select Channel 1 on radio On PK41 OPEN Isolating DC control power to PA01 ensures cable breaker for DC damage will not cause the spurious closure of PA01 07 See Section 6.2 B4 control power to M or PA01 08, causing the RCPs to start. Isolating N/A discussion about No N/A PA01 control power before step 81 is complete will prevent opening the breakers using the local hand switch. stopping the RCPs.

PK4103 - OFF Therefore, Step 84 shall be performed after Step BI.

Design Basis Document for Procedure OFN RP-017 Page 51 of 102 E 1F991 6, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

On PK62 Open Isolating DC control power to PA02 ensures cable breaker for DC damage will not cause the spurious closure of PA0204 See Section 6.2 B5 control power to M or PA0205, causing the RCPs to start. Isolating N/A discussion about No N/A PA02 control power before step B1is complete will prevent stopping the RCPs.

opening the breakers using the local hand switch.

PK6204 - OFF Therefore, Step B5 shall be performed after Step 31.

Ensure RCP Breakers Are Tripped:

PA0107 for RCP A -TRIPPED See Section 6.2 B6 0 PA0108 for RCP B-TPPDafter M This step ensures control powerthe hasRCP beenbreremoved. main tripped N/A discussiontheabout stopping ROPs. No N/A B- TRIPPED sopn h Cs

PA0205 for RCP C - TRIPPED

" PA0206 for RCP D -TRIPPED Check AL HV-36 CST to Turbine Driven AFP Suction Isolation 35 minutes Valve Open: Valve AL HV-36 is required to be open to ensure suction to the TDAFP from the CST. DCP 12170 to start the See Section 6.3 for 87 a. Verify with SRO at D modified the control circuit to ensure a control room pump and timing basis for the No 5.c ASP that Step 5.c is fire will not damage the valve and prevent manual inject into TDAFP.

complete. opening. steam generator B

b. Ensure AL HV OPEN

Design Basis Document for Procedure OFN RP-017 Page 52 of 102 E ir-9916, Re-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min) 35 minutes The operator completing step B7 RNO will not to start the See Section 6.3 for B7 RNO a. Do not continue until D manually open AL HV-36 until it is verified that the pump and timing basis for the No 5.c step 5.c is complete. breaker is off. With the breaker on, a spurious signal inject into TDAFP.

can close the valve after it has been opened. steam generator B Descend Elevation To 1974' Via Ladders This step provides the operator with the most efficient B8 In AFW Valve Room N/A path to get to the Auxiliary Building. Dosimetry for N/A N/A N/A N/A And Enter The RCA. entering the RCA isobtained inStep B3.

In NCP Room, Close CCP To Regen Hx Valves

a. Close Charging Header HCV-1 82 Inlet Isolation Valve This step is required to prevent uncontrolled charging.

See Section 6.2 for B9

BG-8402B - M Closing the valves ensures charging to the RCS 14 timing basis for CLOSED through the Regen Hx is isolated. isolating normal charging.

b. Close Charging Header BG HCV-182 Bypass Valve

BG-V017 -

CLOSED

Design Basis Document for Procedure OFN RP-017 Page 53 of 102 E 1F9916, Rev-.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (mrin)

These valves are closed to prevent a steam bubble from migrating to the CCW piping when the CCW pumps are started. The valves are also closed to prevent cold CCW from being injected to the RCP thermal barrier when the CCW pump is started, which could cause damage to the RCP seals. The CCW In North Mechanical pumps are not started until these valves are closed.

As long as the valves are dosed before starting the Pent Room, Isolate CCW From RCP CCW pumps, then there is no possibility of water Thermal Barriers hammer or seal damage.

a. Verify with SRO that a. Step 5.c opens the breaker associated with EG Step 5.c is complete. HV-61. After the breaker is open, control power is lost and the valve cannot spuriously actuate. Ifthe Prior to the breaker is confirmed open and the valve is closed, See Section 6.5 for b. 5.c B10 b. Ensure EG HV need for S then it is inthe desired position and will remain there discussion about No CLOSED supported throughout the event. Ifthe valve is verified closed support systems. d. D8 systems.

c. Verify with Aux Bldg prior to ensuring Step 5.c is complete and the operator moves on to the next step, the valve could spuriously that Aft D,Step D8 is operate. Also see the discussion for Step 5.c.

complete.

d. Ensure EG HV-133 - c. Step D8 opens the breaker associated with EG HV-CLOSED 133. After the breaker is open, control power is lost and the valve cannot spuriously actuate. Ifthe breaker is confirmed open and the valve is closed, then it is inthe desired position and will remain there throughout the event. Ifthe valve is verified closed prior to ensuring Step D8 is complete and the operator moves on, the valve could spuriously operate. Also see the discussion for Step D8. I I -- I

Design Basis Document for Procedure OFN RP-017 Page 54 of 102 E-!F-915, Rev-.-4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

a. Do not continue until Step 5.c is complete. b. 5.c The RNO ensures the operator does not continue until N/A N/A No B10 RNO

c. Do not continue until power is disconnected. d. D8 Aft D,Step D8 is complete.

In Aux Bldg Filter Alley, Locally Close Valves To Isolate RCP Manual valves BG-V101 and BG-V105 isolate the seal Seals: injection lines and ensure spurious valve actuation will

a. SealInlet Water Injection notberestore Filters Isolations. to closedseal injection.

before These charging valves are is restored required to prevent 28 minutes to start the See Section 6.2 for BBG-V01 RCP seal damage and loss of RCS inventory. The charging PFSSD strategy for a control room fire is to not restore pump and charging.

BG-V105 seal cooling inorder to prevent a seal LOCA ifseal inject to the cooling is not restored promptly. Only one of these RCS.

b. Inform Reactor valves is open at a time but both are included because Operator that Steps either one could be open at the time of the fire.

B10 and Bll are complete.

Design Basis Document for Procedure OFN RP-017 Page 55 of 102 E !F9916, Rv-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note (min)

SA-08-006 shows all four MSIVs can stay open for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as long as there are no At RP209 Across other failures. This From North The action to pull this fuse was part of the original bounds the Mechanical licensing basis strategy for control room fire. The scenario where the B12 Penetration Room R, M,D strategy was approved by the NRC inSupplement 5 of 60 bypass valves are No N/A Fail MSIV Bypass the SER. Pulling the fuse removes control power from open because the Valves Closed. the MSIV bypass valve circuit and fails the valves bypass lines are 2-closed. See Section 7.3.1 for more information. inch diameter

Fuse #46 - OFF whereas the main steam lines are 28-inch diameter. See Section 6.1 for discussion about MSIVs.

Verify BIT Isolation Step D4 opens the breaker for valve EM HV-8801B, 28 minutes Valves open: ensuring the valve will not change position after it has to start the been throttled, charging

a. Verify with person pump and performing Aux Bldg Step D5 opens the breaker for valve EM HV-8801A, control actions that Attachment ensuring the valve will not spuriously open after it has charging See Section 6.2 for B13 D, D5 Steps D4 through are complete. M Mtmn been closed. flow. timing basis ai for o NooD D4 Valve EM HV-8801 B is throttled manually to prevent The timing charging.

b. Inthe North Piping overfilling the pressurizer. Ifthe valve were to fully basis to Penetration Room, open with no letdown, the pressurizer would go solid close EM locally Close 'A"BIT and water would be lost to the PRT and eventually the HV-8801A is OUTLET VALVE. floor of the reactor building. Therefore, the valve is being I manually throttled to control pressurizer level, determined 1

Design Basis Document for Procedure OFN RP-017 Page 56 of 102 E 1F9916, Roy.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

EM HV-8801A by CR CLOSED Valve EM HV-8801A is closed to prevent overfilling 045442 the pressurizer. This step was added as a 04.

c. Inthe North Piping compensatory measure per CR 00045442, which Penetration Room identified the potential to overfill the pressurizer ifthis locally throttle open BIT valve were to spuriously open as a result of a safety outlet isolation valve. injection signal. Closing valve EM HV-8801A or ensuring it is closed will prevent the pressurizer from

EM HV-8801 B going water solid.

THROTTLED OPEN

d. Notify the SRO that BIT is lined up for injection.

e. Throttle EM HV-8801B as directed by the SRO to control PZR level.

28 minutes to start the

a. Do not continue until cagn e eto . o B13 RNO D4 through D5 are M The RNO ensures the operator does not continue until charging See Section 6.2 for B1reMRO 4 hrug D owr s isonete t bthvave.pump and timing basis for No D4 complete. power is disconnected to both valves, control charging.

charging

_______ ___________flow.

Contact SRO At ASP B14 For Further Direction N/A N/A N/A N/A N/A N/A

Design Basis Document for Procedure OFN RP-017 Page 57 of 102 E !F9916, R."

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Evacuate Control Room:

a. Exit Control Room using north door

b. Ensure Control The operator exits through the north door and Room outer doors -AT retrieves his/her hard hat and proceeds to the NK LEAST ONE CLOSED: switchgear room.

Cl N/A N/A N/A N/A N/A

Normal outer door Ensuring one of the control room doors is closed prevents the fire from spreading beyond the control OR room.

Missile door

c. Proceed to NK switchgear rooms.

Design Basis Document for Procedure OFN RP-017 Page 58 of 102 E-IF9915, Rev-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function SNcti BASIS BS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1) (min)

Turn Off The One pressurizer PORV is assumed to fail open. Both Based on SA Following NK PORVs are failed closed by opening NK5108 and 006, the pressurizer Breakers: NK4421 to prevent loss of RCS inventory. PORVs need to be closed within 3

" NK5108 for BB NK5109 and NK4414 supply power to portions of minutes following PCV-455A PZR RL021/RL022. Panel RL021/RL022 supplies power to reactor trip. This PORV Control a number of loads including the reactor head solenoid assumes a single Power Breaker - vent valves. Placing these switches inthe OFF PORV opens and OFF position will fail the solenoid valves closed, thereby no other spurious

NK5109 for Reactor preventing loss of inventory through the reactor head actuations.

Head Vent Valves - vents. Loss of power to the remaining loads supplied Therefore, NK5108, OFF by these breakers will have no adverse impact on safe NK5109, NK4414 shutdown. Switches NK4414 and NK5109 are also and NK4421 need

NK5119 for MSFIS opened to de-energize other potential Separation to be opened within Cab SA075A - OFF Group 1 and 4 125VDC power sources that could 3 minutes.

C2 " NK4401 Breaker M,D cause the pressurizer PORVs to open inthe event of 3 No N/A Control Power for multiple proper polarity hot shorts within The time required NB02 - OFF RL021/RL022. to open NK5119 is being analyzed by

" NK4413 MCB NK5119 supplies power to Train A MSFIS cabinet CR 045442-02-04.

Control Panels SA075A. Isolation of power to SA075A will close the RLO19 and RL020 main steam and main feedwater isolation valves. This The time required

" NK4414 for Reactor action was added as a compensatory measure for CR to open the Head Vent Valves - 00045442, which identified the potential to overfill the remaining switches OFF steam generators iffeedwater flow is not stopped ina inthis step is timely manner. greater than 3

" NK4416 SS minutes so opening Protection Systerr Control power for NB02 needs to be isolated before them within 3 Out 2 Cabinet the NB02 breakers are manipulated inStep C5. minutes will ensure SB032D (Stm Therefore, it makes sense to open the breaker inthis PFSSD.

Dumps) - OFF steo.

Design Basis Document for Procedure OFN RP-017 Page 59 of 102 E IFOSI6, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP (Note 1)(min) Complete (Note 2) Steps (Note 1)

NK4413 supplies power to the following PFSSD components: 1) Train 8 diesel generator room NK4421 for BB exhaust damper actuator GM HZ-19; 2) Solenoid PCV456 actuators for radwaste building CCW supply/retum PORV Control header supply valves EG HV-70A and EG HV-70B; Power Breaker - and, 3) Train B CCW temperature control valve EG POw TV-30. Loss of power to GM HZ-19 will fail the damper open, which is the desired position. Loss of power to EG HV-70A/B will fail the valves closed, which is the desired PFSSD position. Loss of power to EG TV-30 will fail the valve closed, allowing maximum cooling inthe CCW system which will not adversely impact PFSSD. Loss of power to other components supplied by NK4413 will not adversely impact PFSSD.

NK4416 supplies power to the steam dumps. Placing NK4416 inOFF isolates the steam dumps and prevents uncontrolled cooldown and return to criticality if the MSIVs fail to close.

Proceed to NBO2 C3 Switchgear Room Prior to performing remaining steps, the Operator C3 And Obtai Obtain Room NIA proceeds to the emergency locker and obtains a copy N/A N/A N/A N/A A Copy Of of OFN RP-01 7.

_________This Procedure. ____ ____________________

Design Basis Document for Procedure OFN RP-017 Page 60 of 102 E6-F9915, Roey.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Perform the following:

a. Obtain the following from the emergency Aradio is required to ensure communication with the C4 locker: N/A SRO at the ASP and other operators. Channel 1 is N/A N/A N/A N/A used by Operations for communication. A flashlight

Radio supplements fixed battery powered emergency lights.

Flashlight

b. Select Channel 1on radio.

Ensure Train B Pump Breakers - OPEN

NB0207 - OPEN This step sheds large loads from the NB02 bus and is The timing for this

NB0206 - OPEN required prior to starting the Train Bdiesel generator Prior to the step is based on C5 NB0205 - OPEN S inStep C6. need for the need for the No C2

NB0204 - OPEN diesel supported PFSS

NB0203 - OPEN Step C2 isolates control power to the NB02 bus and generator equipment.

NB0202 - OPEN ensures the breakers do not spuriously close.

NB0201 - OPEN

Design Basis Document for Procedure OFN RP-017 Page 61 of 102 E 1F9915, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

This action isolates off site power to the NB02 bus and The timing for this causes the diesel generator to automatically start on step is based on Ensure Feeder bus under voltage. The emergency generator is the need for the Breakers To NB02 - started to energize PFSSD equipment needed Prior to the supported PFSSD 06 OPEN S throughout this procedure. need dieselfor o equipment.

most limiting The time is No C2, 05 CN0209- OPEN Step C2 isolates control power to the NB02 bus and generat stoming NB0212 -OPEN ensures the breakers do not spuriously close, generator restoring gpressurizer backup Step C5 needs to be completed to prevent group B heaters in overloading the diesel generator. Step A7 RNO.

This step energizes relays ESA and ESB on the Train B diesel generator engine control circuit (E-1 3KJ03A).

Ensure ESA And ESB The Wolf Creek licensing basis for control room fires Relays - Energized assumes only a single spurious actuation occurs as a result of the fire. Therefore, it can be assumed that

a. Remove the break one of the two relays will energize. The timing for this glass cover from step is based on the EMERGENCY With at least one relay (ESA or ESB) energized, the the need for the START unit parallel relay (UPR) will be de-energized (E- Prior to the supported PFSSD 07 pushbutton, to 13NE13). Therefore, energize to S indroop mode and willthe diesel properly function generatoraswill not be PFSSD need for diesel equipment. The most limiting time is No 02, 05 and ESB relaysA loads are added. generator restoring pressurizer backup KJ HS-101D - Also, with one relay (ESA or ESB) energized, relay 90 group B heaters in BEK GS S VEP will be energized which will switch the electronic Step A7 RNO.

COVER voltage adjuster to a pre-determined setpoint and REMOVED ignores signals from the control room auto/manual raise/lower switches. This ensures a fire inthe control room will not affect the output voltage of the EDG during the event.

Design Basis Document for Procedure OFN RP-017 Page 62 of 102 E !F9916, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire P STEP DESCRIPTION Function BASIS oTIMING BASIS Impact?

(Note 1)(min) (Note 2) Steps (NoteComplete Align EDG B To Bus

a. At panel KJ122, place CR Fire Iso After loads are shed from the NB02 bus, and the Switch inisolate. NB02 feeder breakers are opened, the Train B diesel generator will automatically start and load to the bus 0 KJ HS-110- ISO) when NB021 I is closed. Placing KJ HS-109 in LOG/MAN allows for local voltage regulation and also

b. Check Diesel - Yes. A isolates portions of the control circuit from the control STARTED control room. Local voltage regulation is not credited for PFSSD and is disabled by actuation of the emergency room fire

c. Ensure Master start switch inStep C7. could Transfer Switch is in prevent an LOC/MAN DCP 12097 was implemented to add another KJ HS- automatic Prior to the See Section 6.5 for start of the

KJHS-109- 109 contact to the control room stop circuit to ensure a C8 need for timing basis Train B LOCIMAN S control room fire will not shut the EDG down during N/A diesel associated with EDG. The the event Inaddition, DCP 12097 added KJ HS-110 generator EDG cooling. RNO

d. At Panel NE106 and redundant fuses to ensure power is available to the field flashing circuit. However, CR 30350 provides a Check Indicator Light identified an issue where certain fuses located in method to IL LIT NE106 could blow, preventing field flashing. Step start the

e. Close EDG Output C8.d and accompanying RNO was added to address engine ifit Breaker this concern inthe interim until a permanent does not modification is implemented. CR 30350-02-04 is auto start.

NB0211- tracking the implementation of the modification.

CLOSED Closing the EDG output breaker after the EDG is

f. Check NB02 voltage started energizes the NB02 bus.

on breaker NB0201 NORMAL I _______________________________________ I~ _______________ ________ +/- _______

Design Basis Document for Procedure OFN RP-017 Page 63 of 102 E !F.9916, Rey.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq SNcti BS Complete (Note 2) Steps (e1) (min)

b. Perform the following:

1) Obtain handle from emergency locker

2) Place handle on either Air Start Valve: The RNO for Step C8.a provides an assured method for starting the Train B diesel engine ifit does not

Northeast end automatically start. Another method would be to'use between cylinders the emergency start switch, but this method may not and turbocharger work because of possible fire damage. Therefore, the RNO directs operators immediately to the assured OR method to minimize the time to start the engine.

The timing for this Prior to the

Southwest end step is based on C8 RNO The RNO for Step C8.d provides instructions to need for between cylinders S the need for the No N/A restore power to the voltage regulator and excitation diesel and generator system circuit shown on drawing M-018-00636. supported PFSSD generator Placing KJHS0109 inLOCAL/MAN inStep C8.c equipment.

3) Pull handle down prevents the new fuses from blowing when they are until diesel starts inserted. Manual voltage control switches NEHS0014B and NEHS0016B are not used inOFN

d. Perform the RP-017 and their contacts will remain open. This is following: an interim compensatory measure until a permanent modification is implemented.

1) Obtain new 15 amp fuses (two) from EDG emergency locker.

2) At panel NE106, open bottom cabinet third from left door.

A ________ _______________________________________ __________ I _______________ I ________ I _______

Design Basis Document for Procedure OFN RP-017 Page 64 of 102 E WF9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD PSDTo Req'd Time TIIGBSS Impact?

CR Fire Pee Function BASIS Comple TIMING BASIS (Note 2) Steps STEP DESCRIPTION (Note 1) (mo ) (Note 2) _Steps

3) Remove unmarked fuse block directly below Agastat.

4) Replace both 15 amp fuses and reinsert fuse block.

The ESW system supplies cooling water to the This step starts the emergency diesel engine cooler, the component ESW pump. Step cooling water heat exchanger and various room C12 closes the Ensure ESW Pump B coolers. The ESW system is also a backup source of Prior to the service water cross Breaker - CLOSED auxiliary feedwater. need for tie valve to prevent C9 S flow diversion from No C2 NB0215 - NB0215 is normally open. Breaker control power is supported ESW to SW. See CLOSED isolated inStep C2. Ifthe breaker did not close in components Section 6.5 for response to the load sequencer signal, Operators can timing basis close the breaker by pushing the manual close push associated with button. EDG cooling.

This step starts the ESW pump. Step C12 closes the Perform Attachment G Attachment G is included to provide instructions to service water cross O charge the cosing to operators to charge the closing springs ifthe breaker N/A tie valve to prevent 09 RNO springs and manually does not close. See the discussion regarding ESW to SW. See close NB0215. Attachment G basis at the end of this table. Section 6.5 for timing basis associated with EDG cooling.

Design Basis Document for Procedure OFN RP-017 Page 65 of 102 E 11F9916, Re,4. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

The Train B 480 VAC load centers and MCC breakers are not shed from the NB02 bus. Therefore, the listed breakers could remain closed. Ifthe breakers open as a result of a control room fire, this step ensures they are closed.

Step C2 disconnects control power from the NB02 bus and ensures the breakers do not spuriously open after Ensure Load Center they have been dosed.

and ESW Pumphouse NB0208 powers XPG022. PG2201 is cycled inStep MCC Breakers - A7 (RNO) to operate the pressurizer heater backup The required time group B. See Step A7 RNO discussion for more to complete this

NB0208 - information. Prior to the step is based on C10 CLOSED need for the time to place No C2

NB0210 - NB0210 powers XNG04. NG0401 is dosed inStep supported the supported CLOSED C13 to energize NG04. See Step C13 discussion for components systems inservice.

NB0213 - more information on NG04. See Steps A7 RNO, CLOSEDCli, 013 and 017.

CLOSED NB0213 powers XNG02. NG0201 is closed inStep NB0216 -

C ClI to energize NG02. See Step C11 discussion for more information on NG02.

NB0216 powers XNG06, which energizes Train B ESW pumphouse MCC NG006E. MCC NG006E powers a number of components required to ensure Train B ESW pump operability. The Train B ESW pump is directly powered from NB0215 and does not require NG006E to be energized.

Design Basis Document for Procedure OFN RP-017 Page 66 of 102 E 1F9915, R.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Perform Attachment G Attachment G is included to provide instructions to C10 RNO to charge the closing S operators to charge the closing springs ifthe breaker N/A N/A N/A N/A springs and manually does not close. See discussion regarding Attachment close the breakers. G basis at the end of this table.

This step is performed to ensure power is available to PFSSD components supplied by NG02. Power is provided to NG02 by NB0213. NB0213 is verified closed inStep CIO. NG02 supplies power to a number of PFSSD components, but only a few are Isolate Control Power needed for OFN RP-017. These include:

To NG02:

EF HV-32

a. Position NORMAL 0 EF HV-34 The required time ISOLATE switch to 0 EFHV-46 to complete this ISOLATE 0 EF HV-50 step is based on 0 SGK05B the time to place NG HIS 0 DSGL12B Prior to the the supported Cll ISOLATE 5 0 XNN06 need for te s erted

BN HV-8812B supported systems inservice. No N/A

b. On NG02, ensure 0 BG LCV-112C systems C17, C18, C19, Load Center NG02 0 EF HV-26 020, C21, C23, D7, Main Breaker-

EF HV-38 DC0, 011,2,D7, CLOSED a BGHV-8111 D13, D20.

BNLCV-112E

NG0201 - 0 DSGN01B CLOSED 0 DSGL15B Placing NG HIS-15 inisolate position will isolate the trip circuit and prevent a spurious breaker trip after the breaker has been closed. The hand switch needs to be operated first before manually closing the breaker to ensure a trip does not occur.

Design Basis Document for Procedure OFN RP-017 Page 67 of 102 E-irF9915, Rev-.-4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (min)

EF HV-32, EF HV-34, EF HV-46 and EF HV-50 are opened inSteps D10 through D12 to provide a flow path to/from ESW to the Train B containment coolers.

SGK05B is required to provide cooling to Class 1E electrical equipment rooms. The unit is started inStep D20 after all required lineups are made.

DSGL12B is the Train B CCP room cooler fan motor.

The pump room cooler provides a suitable ambient air temperature for the CCP motor. The cooler starts automatically when the pump motor starts. Failure of the room cooler to start does not prevent operation of the pump. The CCP is started inStep C23. ESW is lined up inStep C17.

XNN06 is required to energize NN02 to provide long-term power to panels RP147A and RP147B. 125 VDC battery sets NK01 2 and NK014 provide the short-term power needs for these panels. The batteries are sized to supply power to all emergency loads for 200 minutes following loss of AC power per E-10NK, at which time the alternate power source will need to be lined up.

BN HV-8812B is closed inStep C18 using BN HS-8812B. Step Cl is performed prior to C18, so power will be available when the operator performs Step C18.

BG LCV-1 12C needs to be closed onor to startino

_____ - 2C needs______

1_____ be____ LC clsepiot___r Lo

Design Basis Document for Procedure OFN RP-017 Page 68 of 102 E !FO! , R.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS TIMING BASIS Impact? Steps Complete (Note 2) eps (Note 1) (min) ( 2)

Train B CCP to ensure hydrogen is not introduced into the CCP suction. The valve is closed inStep C20 using BG HS-1 12C. Train B CCP is started inStep C23.

EF HV-26 is dosed inStep C12 using ISO/CLOSE switch EF HS-26A to prevent ESW flow diversion to the service water piping.

EF HV-38 needs to be open to ensure a full flow return path from ESW to the UHS. EF HV-38 is fully opened inStep C17 by placing EF HS-38A in ISO/OPEN position. Power needs to be restored prior to the need for this valve to be fully open.

BG HV-81 11 is required to be open to prevent Train B CCP damage during low flow conditions. BG HV-8111 is opened inStep C21 by placing BG HS-81 11A inISO/OPEN position.

BN LCV-1 12E is required to be open to provide a suction source from the RWST to the Train B CCP.

BN LCV-112E is open in Step C19 by placing BN HS-112E in ISO/OPEN position.

DSGN01 B needs to be energized for containment cooling. The coolers are started inStep D13.

DSGL15B is the Train B electrical penetration room cooler and is started in Step D7.

Design Basis Document for Procedure OFN RP-017 Page 69 of 102 E-IF9915, Ro.. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1)(mn Complete (Note 2) Steps (min)

The limiting time is At NG02AHF2, based on the need Position NORMAL This valve isolates the service water system and to establish EDG ISO/CLOSE For ESW prevents flow diversion from ESW to the service water See Section cooling. While Step B/Service Water piping. This valve needs to be closed to ensure 6.5 for timing C8 ensures the C12 Cross- Connect Valve S adequate flow to the required ESW loads. Step C1 associated StEDG is running, No N/A To ISOICLOSE restores power to the MCC cubicle for this valve. with EDG Step C6 potentially cooling. causes an EF HS-26A - DCP 12170 modified the control circuit for EF HV-26 cooling, automatic start.

ES-26A to address NRC IN92-18 concerns. See Section 6.5 for discussion on ESW and EDG cooling.

This step is performed to ensure power is available to Isolate Control Power PFSSD components supplied by NG04. NG04 To NG04: supplies power to a number of PFSSD components, but only a few are required to be energized for OFN

a. Position NORMAL RP-017. These include:

ISOLATE switch to The required time ISOLATE AL HV-30 to complete this AL HV-33 Prior to the step is based on N HIS NG AL HV-34 need for the time to place C13 ISOLATE S DSGF2B supported the supported No N/A EM HV-8803B systems systems inservice.

b. On NG04, ensure DSEMG 3B sSee Steps A4, A5, Load Center NG04

DSGL11B Al,022,028,D4 Main Breaker - EF HV-52 and D13.

CLOSED EG

EG HV-16 HV-54

NG0401 - DSGN01D CLOSED

DPJE01B Placing NG HIS-16 inisolate position will isolate the

Design Basis Document for Procedure OFN RP-017 Page 70 of 102 E lr-9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire To Prereq STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Steps (Note 1) Complete (min) (Note 2) Steps trip circuit and prevent a spurious breaker trip after the breaker has been closed. The hand switch needs to be operated first before manually closing the breaker to ensure a trip does not occur.

AL HV-5 needs to be opened to supply auxiliary feedwater to steam generator D. The valve is opened inStep A5 by placing AL HS-5 in LOCAL and AL HK-5B inOPEN. Power needs to be restored before the valve will operate.

AL HV-30 needs to be opened to supply suction to the Train B MDAFP when the CST reaches low level.

This is not a time critical step since the CST has sufficient volume for PFSSD. See Step A15 discussion.

AL HV-33 needs to be opened to supply suction to the TDAFP when the CST reaches low level. This is not a time critical step since the CST has sufficient volume for PFSSD. See Step A15 discussion.

AL HV-34 needs to be opened to ensure a suction supply from the CST to the Train B MDAFP. The valve is opened inStep A4 by placing AL HIS-34B in OPEN position. Step C13 needs to be completed before the valve will open.

DSGF2B is the Train B MDAFP room cooler. The room cooler provides a suitable ambient air temperature for the equipment inthe room. The cooler starts automatically when the pump starts as I I

Design Basis Document for Procedure OFN RP-017 Page 71 of 102 E I Fool 5, Roe."

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min) long as power is available to the cooler motor. Power is established inStep C13. See Section 6.5 for discussion about room cooling.

EM HV-8803B is opened inStep D4. Step C13 needs to be performed prior to the need for charging.

DSGL1 1B is the Train B CCW pump room cooler.

The room cooler provides a suitable ambient air temperature for the equipment inthe room. The cooler starts automatically when either Train B CCW pump starts as long as power is available to the cooler motor. The CCW pumps are started inStep C22.

EF HV-52 is opened inStep D4 by placing EF HS-52 in ISO/OPEN position. EF HV-52 needs to be open prior to the need for CCW. The CCW system is needed for CCP oil cooling and provides cooling water to the seal water heat exchanger, The Train B CCP is started inStep C23.

EG HV-16 and EG HV-54 are opened inStep D4 by placing EG HS-16A and EG HS-54 in ISO/OPEN position. EG HV-16 and EG HS-54 need to be open to ensure CCW to the seal water heat exchanger prior to starting the Train B CCP. The seal water heat exchanger provides cooling for CCP recirc flow and is needed to ensure operability of the COP. The Train B CCP is started inStep C23.

DSGN01 D needs to be energized for containment I cooling. The coolers are started inStep D13.

Design Basis Document for Procedure OFN RP-017 Page 72 of 102 E 1F9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(mrin)

DPJE01B needs to be energized to ensure Train B fuel oil transfer pump operability. The transfer pump is started inStep C28.

Start Motor Driven a. Step A4 is required to be completed to ensure an AFW Pump B. adequate suction source to the AFW pump prior to starting the pump. Step A5 is required to be

a. Verify SRO performing Attachment performed to ensureD.

to steam generator AFW flowA5 from Train B MDAFP IfStep is not complete SA-08-006 shows A has completed steps before performing this step, there is no adverse that PFSSD is A4 through Am . impact since water will recirculate back to the CST. assured ifAFW is A4stthroughdAt.

014 b. Start Motor Driven b. The MDAFP B is started by pushing the manual established to b StartumMotor Driven C14 D close push button at NB0205. Although control power 15 m inutes.

AFW pump B is isolated, the springs are charged and ready to S etin 6.3ifor operate.See Section 6.3 for NB0205 - operate. discussion about CLOSED Step C2 isolates control power to the NB02 bus and AFW.

c. Notify SRO that prevents a fire inthe control room from spuriously Motor Driven AFW opening NB0205 after it has been closed.

Pump B is running

a. DO NOT a. This RNO ensures the operator does not continue SA-08-006 shows CONTINUE until steps until AFW Pump B valve alignment is complete in that PFSSD is A4 through A5 are Steps A4 and A5. assured ifAFW is complete.

co established to

b. Ifthe breaker re-opens after it has been closed or steamigenerto 014 RNO D the springs are not charged, manual charging wil be within 15 minutes.

b. Perform Attachment required to get the breaker to close. Attachment G See Section 6.3 for Gto charge the closing provides the method to manually charge the springs. discussion about springs and manually See discussion regarding Attachment G basis at the AFW.

close NB0205 end of this table. _ __

Design Basis Document for Procedure OFN RP-017 Page 73 of 102 E ir-9015, R"~.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Ensure Motor Driven AFW Pump A Is Stopped: SA-08-006 shows The Train AMDAFP breaker is opened to stop the tSat ifthe pump is

a. Remove CLOSE pump and prevent uncontrolled AFW flow to steam st ithinu15 control power fuse (UC) generators B and C which could result inoverfilling the stopped within 15 steam generators. Although A Train equipment is not C15

NBO105/FUSE - 0 credited, spurious actuation of A Train equipment 15 actions inthe No N/A OFF needs to be mitigated ifitcould lead to unwanted procedure are consequences. Inthis case, overfilling of the steam taken, overfilling of

b. Stop Motor Driven generators is not desired and is, therefore, being steam generators B AFW Pump A prevented inOFN RP-017. and C will not occur.

NB0105 - OPEN

Design Basis Document for Procedure OFN RP-017 Page 74 of 102 E irF9915, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1)

(min)

It is assumed that the Train A containment spray Ensure Containment pump is operating Spray Pump A is and valve stopped: This step ensures the Train Acontainment spray ENHV0006 is open to cause pump is not running and depleting the RWST

a. Remove CLOSE inventory. The Train B containment spray pump is containment spray.

control power fuse (UC) isolated inStep C5. E-aF9910 (see Fire Area C-22) shows C16

NB0102/FUSE - M Pulling the fuse isolates control power from the circuit 67 that with 1 No N/A OFF to prevent a control room fire from closing the breaker. containment spray This action was approved by the NRC based on its pump operating and

b. Stop Containment inclusion inSLNRC-84-0109 (See Phase E action 18 flowing water to the Spray Pump A and Note 20 inSLNRC 84-0109) header, operators have 67 minutes to

NBO102-OPEN stop the pump before the RWST level falls below that required for safe shutdown.

Design Basis Document for Procedure OFN RP-017 Page 75 of 102 E !F9916, R"y TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

East Of NG02A, Align ESW Pump Room Ventilation:

ESW pump room ventilation maintains the ESW pump

a. Position NORMAL room temperature within required limits. Based on the ISO/OPEN switch for Wolf Creek TRM, Table TR 3.7.22-1 the maximum The timing basis ESW Pump Room temperature inthe Train B ESW pump room is 149 F depends on the Supply Damper to before equipment is declared inoperable. Maximum time for the room to ISO/OPEN allowable sustained temperature inthe room is 119 F. Prior to room heat up to a point Step C9 starts the ESW pump. Step C10 energizes reaching where the ESW No C17

GD HS-11A -S the Train B ESW pump room MCC. undesirable pump will notN/A ISO/OPENuneial pupwlnt GD HS-1 1A isolates power to the ESW pump room temperature operate. See

b. Position NORMAL supply damper and fails it open, which is the desired Section 6.5 for ISO/RUN switch for position. discussion about ESW Pump Room room cooling.

Supply Fan to GD HS-1 1 starts the supply fan, isolates the control ISO/RUN room circuits and inserts a redundant fuse.

GDHS ISO/RUN Return flow from the ESW system to the UHS is The timing basis At NGO2AHF3, required for diesel generator cooling, class 1E depends on the position NORMAL electrical equipment room cooling, auxiliary feedwater limiting time to ISOIOPEN Switch For pump room cooler, centrifugal charging pump room Prior to the establish full flow in ESW To UHS Isolation cooler, electrical penetration room cooler, containment need for full the ESW system.

18 Valve To ISOIOPEN. air coolers, component cooling water heat exchanger flow inthe The valve needs to No N/A and component cooling water pump room cooler. EF ESW system be fully open prior EF HS-38A - HS-38A isolates the control room, adds a redundant to establishing ISO/OPEN fuse inthe circuit and fully opens valve EF HV-38. CCW heat Valve EF HV-38 is maintained partially open (66%) exchanger and during normal operation and fully opens on SIS or containment air

Design Basis Document for Procedure OFN RP-017 Page 76 of 102 E ! FOS! 5, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

LOSP. Afire inthe control room could cause a short cooler flow, since that bypasses the control room handswitch and the total flow to signals the valve to close. However, based on these systems is drawing E-13EF06A and E-025-00007, Sheet 185, the 11,350 gpm per valve will not fully close because limit switch contact calculation EF-10.

ZS/16 prevents the valve from closing past the 66%

setpoint. See Section 6.5 for discussion about The ESW loads that are necessary shortly after the CCW and diesel generator is started inStep C8 are diesel containment generator cooling, class 1E electrical equipment room cooling.

cooling, auxiliary feedwater pump room cooler and electrical penetration room cooler. Based on calculation EF-10, the flow rates for each of these components are: diesel generator cooling (1,200 gpm), class 1E electrical equipment room cooling (66 gpm), auxiliary feedwater pump room cooler (128 gpm) and electrical penetration room cooler (100 gpm). The total flow to these loads is 1,494 gpm. As stated above, valve EF HV-38 will be approximately 66% open which is more than adequate to flow 1,494 gpm through this 30 inch valve. Therefore, Step C17 does not have to be performed to establish ESW flow to these loads.

Step C17 will need to be completed before the remaining loads are needed to ensure full flow inthe ESW system is available.

Design Basis Document for Procedure OFN RP-017 Page 77 of 102 E 1F9916, Rev.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1)

(min)

At NG02AFF4, Calculation XX-E-Position NORMAL 013 shows there is ISOICLOSE Switch This action prevents or mitigates a loss of RWST 01 shwstes For RWST To RHR inventory to the containment sump. The hand switch 28 minutes C19 Pump B ISO Valve To R, M isolates the control room, inserts a redundant fuse in 28 RWST drains to a No N/A ISOICLOSE. the control circuit and closes the valve. Step Cll level below that

BN HS-8812B -shton restores power to the MCC cubicle for this valve, required for cold ISO/CLOSE shutdown.

On NG02AHR3, Open This step aligns the RWST to the Train B CCP. DCP OnT NTo2AfR, B12175 Open added a control room isolation switch and See Sections 6.1 RSuction CCl: Bredundant fuse at NG02AHR3 for this valve. This Prior to the and 6.2 for C20 Suction Valve: R, M ensures valve BN HV-1 12E will open (ifclosed) and need for discussion a ndNoabout N /

N/A BN HS-1 12E - remain open throughout the event when BN HS-1 12E charging charging.

ISO/OPEN is placed inthe ISO/OPEN position and power is Irestored inStep Cl1.

At NG02AFR2, Close This valve is isolated before starting the charging VCT OUTLET ISO pump to prevent hydrogen gas intrusion into the See Sections 6.1 Valve. pump. DCP 12131 added a redundant fuse inthe Prior to the and 6.2 for C21 R. M control circuit to ensure control power is available need for discussion about No N/A

BG HS-1 12C - when the hand switch is placed in ISO/CLOSE. This charging charging.

ISO/CLOSE ensures the valve will close inresponse to hand switch actuation after NG02 is energized inStep C11.

This valve is required to be open to protect the Train B At HV-8R1 operging CCP from overheating during low flow conditions.

Pump Mini Flow DCP 12175 added a control room isolation switch and Prior to the See Sections 6.1 C22 Isolation Valve. M redundant fuse at NG02AHR1 for this valve. This need for and 6.2 for No N/A ensures valve BG HV-81 11 will open (ifclosed) and charging discussion about BG HS-8111A - remain open throughout the event when BG HS- charging.

ISO/OPEN 811 1A is placed inthe ISO/OPEN position and power is restored inStep C11.

Design Basis Document for Procedure OFN RP-017 Page 78 of 102 E lF9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Note 2) Steps (NoteComplete (mrin)

The CCW system is required to provide cooling to the Train B CCP oil cooler and the seal water heat exchanger. Both of these components support operation of the Train B CCP.

On NBO2, Start One Step B10 closes the CCW outlet valves from the CCW Pump. thermal barrier. This protects the CCW piping against water hammer and prevents inventory loss through Prior to the See Section 6.5 for C23 a. Ensure Turbine the RCP seals. See Step B10 basis. need for discussion about No B10, C2 Building Art B,Step supported CCW.

B10 is complete Step C2 isolates control power to NB02 and ensures components NB0206 does not spuriously open after it has been

b. NB0206 - CLOSED dosed.

Step C13 establishes power to the CCW pump room cooler and Step C17 completes lineup of ESW.

Therefore, room cooling will be available prior to starting the pump.

a. Perform the following: a. The RNO ensures the operator does not continue until the prerequisite steps are complete.

1) WHEN At tB, Step B10 is complete, THEN b.1 The RNO has the operator start CCW pump Dif perform Step C22.b. the B pump did not start. This RNO is included as an Prior to the See Section 6.5 for C23 RNO n enhancement since the control room fire will not need for

2) Do not continue until prevent an operator from manually closing NB0206. supported Cut8 Step C22.b is components complete. b.2 This RNO provides instructions for manually charging the springs and closing the breaker ifit failed

b. Perform the to close or did not remain closed. See discussion following: regarding Attachment G basis at the end of this table.

Design Basis Document for Procedure OFN RP-017 Page 79 of 102 E 1F9916, Rev-. I TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (min)

1) IFNB0206 can NOT be closed, THEN close NB0207 to start CCW pump D.

2) IFno CCW pump can be started, THEN perform Attachment G to charge the closing springs and manually close breakers as necessary to establish one CCW pump running.

Design Basis Document for Procedure OFN RP-017 Page 80 of 102 E1IF9916, Rov.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note )(rain) Complete (Note 2) Steps (Note 1)

Start CCP B:

a. Check RCP seal Seal cooling is no longer restored inOFN RP-017 due injection isolated and to the uncertainty inthe time before seal failure can COW service loop occur. Therefore, prior to starting the CCP, operators CaW ried overify seal injection is isolated. Seal injection is isolated inStep B 11.

Ensure l AU 8, Step The CCP oil cooler and seal water heat exchanger SA-08-006 shows 811, Bi 1 RCP seal require CCW. Therefore, the CCW system needs to the COP needs to C19, isolate M be aligned prior to starting the CCP. Step C22 starts 28 minutes. See No C20, C24 complete the CCW pumps. Steps D4 and D5 align the CCW Sections 6.1 and C21, AND service loop to ensure adequate CCW flow to the CCP 6.2 for discussion C22, components. about charging. D4, 05

" Ensure Steps D 4 Other required alignments are made by this operator through 08OCW prior to performing Step C23. These alignments are service loop made insteps C11, C19, C20 and C21. After all alignment are alignments are made, the CCP breaker is closed to complete start the pump.

b. NB0201 - CLOSED

Design Basis Document for Procedure OFN RP-017 Page 81 of 102 E !F9916, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP (Note 1)(min) Complete (Note 2) Steps (Note 1)

a. Perform the following:

1) WHEN RCP seal injection is isolated AND CCW alignment is a. The RNO ensures the operator does not continue SA-08-006 shows complete, THEN until the prerequisite steps are complete, the CCP needs to perform Step be started See within 28 024 RNO C23.b. M b. The RNO provides instructions for manually 28 minutes. No N/A charging the springs and dosing the breaker, ifit Sins. and failed to close or did not rem ain closed. See 6.2tforsiscussio

2) Do Not continue discussion regarding Attachment G basis at the end of 6.2 for discussion until Step C23.b is this table. about charging.

complete.

b. Perform Attachment G to charge the closing springs and manually close NB0201 Inform SRO That This step ensures the SRO is informed that the pumps C25 CCW and CCP Pumps N/A are operating. N/A N/A N/A N/A Have Been Started

Design Basis Document for Procedure OFN RP-017 Page 82 of 102 E !F9916, R.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP

2) Steps lete (Note (rain)

Calculation change notice AN-02-010-000-02 documents an analysis of the diesel generator room temperatures Right Of NG04D, without supply fan Align Diesel operation. The This step ensures adequate Train B diesel generator Generator Building calculation was room ventilation. The diesel generator room exhaust Ventilation: performed using 3 damper is failed open inStep C2 to ensure adequate different outside air

" Position NORMAL diesel engine combustion air. The supply fan and temperatures (97, ISO/RUN switch outside air intake damper are not required for 100 and 105 F) and for DG Ventilation combustion air but are required for room cooling.

assumed the Supply Fan to starting room GM HS-1 1B is an ISO/RUN switch that operates the ISO/RUN temperature equals C26 S Train B diesel generator room supply fan CGM01B. 155 No N/A The switch isolates the control room, adds a the outside room o GMHS-11B- temperature (very ISO/RUN redundant fuse inthe circuit and starts the fan. The fan is powered from NG04DBF6 which is energized in conservative). The Step C13. calculation shows

Open feeder that even at a breaker to GM TZ- starting room 11A Opening NG04DEF1 11 will cut power to GM TZ-1 1A and fail the damper open. This damper is on the temperature of 105 outside air intake for the room supply fan. F, ittakes 155 o NG04DEF11I - minutes to reach.

OFF the diesel generator design temperature of 122 F.

L _______ ____________________________________ I. _________ L ______________ L ________ I. _______

Design Basis Document for Procedure OFN RP-017 Page 83 of 102 E1 FOB!5, R.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (min)

For the excess letdown flow path to open, it would take spurious operation of at least 3 valves.

Flow would be limited to the isolate Possible RCS volume that can Leakage Paths: flow through the 1" excess letdown

a. On NK41, open pipe. The breaker for RCS To NK4119 and NK4407 supply power to portions of pressurizer level is Excess Letdown Heat RL001/RL002. Panel RL001/RL002 supplies power to typically held at 55 Exchanger Valves: a number of loads, including the excess letdown heat to 60%. After a trip, exchanger valves. Loss of power to these valves will the volume will C27

NK4119 -OFF M fail them closed, preventing inventory loss through this 37 shrink due to RCS No N/A path. cooldown to 561 F.

b. On NK44, open Based on SA breaker for RCS To Loss of power to the remaining loads supplied by 006, initial Excess Letdown Heat these breakers inRL0O1/RL002 will have no adverse shrinkage is Exchanger Valves: impact. typically to 30%

NR. Per WCRE-03, NK4407 - OFF 30% equates to 4,373 gallons. The volume of water below the lowest level transmitter is 637 gallons.

Therefore, the inventory that can be lost before going off scale low is

Design Basis Document for Procedure OFN RP-017 Page 84 of 102 E 1F9916, Roy.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS Complete TIMING BASIS Impact? Steps (Note 1) (min) (Note 2) 3,736 gallons.

Assuming a maximum of 100 gpm lost through the excess letdown flow path, there is at least 37 minutes available to mitigate a failed open excess letdown flow path.

NK441 1 supplies power to Separation Group 4 125 vdc loads inRL023/RL024. These loads include On NK44, Open blowdown valves BM HV-1 thru BM HV-4. SA-08-006 shows Breaker For SlG Disconnecting power to these valves will fail them the blowdown C28 Blowdown Isolation R,M,D closed, which is the desired position. 60 valves can remain No N/A Valves: open for the Loss of power to the remaining loads supplied by this modeled duration of

NK4411 -OFF breaker will have no adverse impact. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Also see discussion in Section 7.3.1.a.

Design Basis Document for Procedure OFN RP-017 Page 85 of 102 E 1F9915, Rev-.-4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP Complete (Note 2) Steps (Note 1) (rain)

Start EDG Fuel Oil Xfer Pump:

a. At NG04DDF3, The diesel engine place Emergency FO can run for at least Transfer Pump Change package 12176 added hand switch JE HS- 60 minutes using Isolation Switch in 21 C to isolate the pump control circuit from the the fuel inthe day Isolate. Control Room. Inaddition, operation of the switch will tank, given the C29 S insert a new fuse inthe circuit incase the main fuse 60 reduced loading No N/A

JE HS-21C - opened as a result of the fire. This ensures the imposed on the ISOLATE transfer pump will start when JE HS-21 B is placed in engine during PFSSD. Therefore, the RUN position. NG04 is energized inStep C13. this action should

b. At panel KJ-1 22, be com ld start Emergency Fuel be completed within Oil Transfer Pump. 60 minutes.

0 JEHS-21B-RUN

Design Basis Document for Procedure OFN RP-017 Page 86 of 102 E 1IF99115, R"y TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note )(rmin) Complete (Note 2) Steps (Note 1)

This step was added inOTSC 10-0093 as a result of condition report 31408. Step C25 has operators fully open the B EDG pump room supply damper and start The timing basis Check EDG B Room the supply fan. There are no operator actions taken depends on the Temperature for the recirculation adequate during all damper. Thisyear.

times of the lineup may not be Inthe winter time for the room to heat up or cool

a. Check room months, drawing in 100% outside air with a closed Prior to room down to a point C30 temperature greater recirculation damper could cause the room reaching where the B EDG N/A N/A than 650F temperature to drop below freezing. Inthe summer undesirable and associated months, with the recirculation damper open, the room temperature components will not temperature less than could heat up to an undesired temperature. The operate. See 110trF temperature range of 65 to 110 degrees F ensures the discussion for Step room temperature remains within the required range. C25 for further These are interim actions until a permanent resolution discussion.

is determined. Condition Report Action 30350-02-07 is tracking the resolution of this issue.

Design Basis Document for Procedure OFN RP-017 Page 87 of 102 E 1F9916, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1)(m) Complete (Note 2) Steps (min)

a. Perform the following:

This RNO performs the necessary steps to ensure the

1) Open breaker Train B EDG room temperature remains within the NG04DBF6 to stop B required range. These steps are performed locally.

EDG Room Supply Fan Opening NG04DBF6 will de-energize the supply fan

2) WHEN temperature and allow the room to heat up ifthe temperature drops The timing basis reaches 900F, THEN below 650F. When the temperature reaches 900F, depends on the close breaker the operator will re-start the fan. time for the room to NG04DBF6 to start B heat up or cool EDG Room Supply Fan When the room temperature reaches 1100 F,the down to a point operator will open breaker NG04DEF1 12 to fail the Prior to room where the ESW C30 RNO C30 Perfoliote following: recirculation into the roomdamper closed, to cool the room.allowing When 100% outside air the temperature reaching undesirable pump and N/A N/A associated

1) WHEN temperature drops to 650F, the operator will close breaker temperature components will not reaches 1100F, THEN NG04DEF 112 to re-energize the recirculation damper opents wln open breaker 12 on to allow it to open. Ifthe recirc damper does not open Section 6.5 for NG04DEF1 to fail due to the fire inthe control room, then the operator discussion about Recirc Damper closed, can perform the RNO for Step C29.a to increase the discossinao

2) ) WHEN room temperature. room cooling.

temperature reaches These are interim actions until a permanent resolution 65°F, THEN close is determined. Condition Report Action 30350-02-07 breaker 12 on is tracking the resolution of this issue.

NG04DEF1 to energize Recirc Damper.

C31 Contact SRO at ASP N/A N/A N/A N/A I For Further Direction N/A N/A

Design Basis Document for Procedure OFN RP-017 Page 88 of 102 E !F9915, R"v ~

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (rain) (Note 2) Steps (Note 1)

The PFSSD strategy is to use BG LCV-459 and BG In Rod Drive MIG LCV-460 to isolate normal letdown. Inorder to isolate ssumes0th Room Isolate Normal BG LCV-459 and BG LCV-460, PK5117 is placed in ae sothe Letdown PK5117, RC the OFF position to disrupt power to these valves and le are valves ilaseo closed D1 &SUPPORT SYS. M fail them closed. This will also disrupt power to 7 within 7,minutes No N/A CONTROL PNL. auxiliary pressurizer spray valve BGHV8145 and fail and the auxiliary RL001 &RL002. the valve closed. This action will also disrupt power to a number of other separation group 5 125 vdc loads in closed within 7 PK5117 - OFF RL001/RL002, but this will have no adverse impact on minutes.

PFSSD.

Proceed to Emergency Locker 02 2026E Level And N/A Procedure is required to complete remaining N/A N/A N/A N/A Obtain6LeeAndCy Attachment Dsteps.

Obtain A Copy Of This Procedure.

Perform The Following:

a. Obtain the following from emergency locker: Aradio is required to ensure communication with the SRO at the ASP and other operators. Channel 1 is

Radio used by Operations for communication. Aflashlight D3

Flashlight N/A supplements fixed battery powered emergency lights. N/A N/A N/A N/A

FR Jump Suit The FR jump suit is required to operate certain

Circular soft jawed breakers. The soft-jawed pliers are required to pliers disconnect the amphenal connectors for the main steam isolation valves.

b. Select Channel 1on radio

Design Basis Document for Procedure OFN RP-017 Page 89 of 102 E lr-9916, R"y TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION (Nt )Complete (Note 2) Steps (Note 1) (min)

EG HS-16A is placed inISO/OPEN to open EG HV-16 and provide a return flow path from the service loop to On NG04C, Perform the Train B CCW pump suction. The valve is required the Following: to be open to ensure CCW flow to the seal water heat exchanger, which is required to ensure Train B CCP

At NG04CJF3, operability. The valve will open when power is place EG HS-16A to restored to NG04 inStep C13. Placing the switch in ISO/OPEN ISO/OPEN before power is restored will have no

" At NG04CKF1, adverse impact.

place EG HS-54 to EG HS-54 is placed inISO/OPEN to open EG HV-54 ISO/OPEN and provide a supply flow path from the Train B CCW

" At NGE4CKF2, pump to the service loop. The valve is required to be 8803B to open to ensure CCW flow to the seal water heat PSor to the and 6.2 for timing ISO/OPEN exchanger, which is required to ensure Train B CCP need for basis for charging.

ISO/OPEN operability. The valve will not actually open until charginga D4 e Turn off M,S chrigadNo N/A NGo4CKF3, power is restored to NG04 inStep C13. Placing the charted No N/A EMHV8801B BIT switch inISO/OPEN before power is restored will have supported See Section 6.5 for DISCHARGE no adverse impact. equipment timing basis for DISCARGECCW and ESW.

ISOLATION VALVE EM HS-8803B is placed in ISO/OPEN to ensure Train Bkr B CCP flow to the RCS through the BIT. This is the

At NGE4CNF3, only boration and inventory control flow path credited.

place EF HS-52 to The valve will not actually open until power is restored ISO/OPEN to NG04 in Step C13. Placing the switch in "NTurn ff ISO/OPEN before power is restored will have no EFHV60 ESW adverse impact.

FROM CVWHX NG04CKF3 is placed inOFF to prevent spurious ISO VALVE breaker operation of EM HV-8801B. DCP 12130 modified the control circuit for EM HV-8801B to address NRC IN 92-18 concerns. Step B13 throttles EM HV-8801B.

R AA --*

AA Design Basis Document for Procedure OFN RP-017 Page 9u OT1u0 E !F99115, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'dToTime TIIGBSS CR Fire Impact? Prereq STEP DESCRIPTION Function BASIS Comple TIMING BASIS (Noat ep2 (mi) Steps (Note 1)

EF HS-52 is placed inISO/OPEN to ensure a flow path from Train B ESW to the Train B CCW heat exchanger. The Train B CCW heat exchanger is required for CCP B oil cooler and the seal water heat exchanger, which are both required for CCP operability. The valve will not actually open until power is restored to NG04 inStep C13. Placing the switch inISO/OPEN before power is restored will have no adverse impact.

NG04CHF2 is placed inoff position to prevent spurious operation of EF HV-60. This step was added as an interim compensatory measure inresponse to CR 41746, which identified that a control room fire could cause the valve to open. If this occurs, a flow imbalance would occur inthe B ESW system. DCP 13898 is being prepared to add an isolation/close switch and redundant fuse to address this concern permanently. The Evaluation of Proposed Change for DRR 11-1583 associated with OFN RP-017, Rev. 36 evaluates this change.

Valve EM HV-8801A is closed in Step B13 to prevent On NG01B, Isolate overfilling the pressurizer. Step D5 needs to be Power To EM HV- completed prior to Step B133 to prevent the valve from The timing basis to 8801A, BIT Outlet re-opening. This step was added as a compensatory close EM HV-D5 Valve measure per CR 00045442, which identified the N/A 8801A is being No N/A potential to overfill the pressurizer ifthis valve were to determined by CR

NG01BER2-OFF spuriously open as a result of a safety injection signal. 045442-02-04.

Closing valve EM HV-8801A or ensuring it is closed will prevent the pressurizer from going water solid.

Design Basis Document for Procedure OFN RP-017 Page 91 of 102 EirF9915, Rev. 4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1)(min)

Locally Ensure CCW Return From Nuclear EG HV-15 is closed to ensure flow is not diverted to Auxiliary the Train ACCW surge tank. The COW lineup inOFN Components to Train RP-01 7 maintains water flow from CCW to the excess Pror to the A CCW Is Closed: letdown heat exchanger. Therefore, Train B return need for See Section 6.5 for D6 S flow could potentially flow into the Train ACCW piping supported timing basis for No 5.c

Verify with SRO at ifEG HV-15 is open. support CCW.

ASP, that Step 5.c equipment is complete. Step 5.c opens the MCC breaker for EG HV-15 and

Ensure EG HV-15 needs to be completed before Step D5.

is closed.

a. DO NOT Prior to the See Section 6.5 for D6 RNO CONTINUE until Step S The RNO ensures the operator does not continue until need for timing basis for No 5.c 5.c is complete p the prerequisite step is complete. supported equipment CCW.

CR 41746 identified a concern where EF HV-60 could spuriously open inthe event of a control room fire.

This would cause a flow imbalance inthe ESW system and possibly reduce cooling flow to other Prior to the Locally Check EF HV- essential PFSSD components. This step was added need for See Section 6.5 for D7 60, ESW TRN B FROM S as a compensatory measure to immediately address timing basis for No D4 CCW HX B Closed the concern inthis CR. DCP 13898 is being prepared equipment ESW.

to add an isolation/close switch and redundant fuse to address this concern permanently. The Evaluation of Proposed Change for DRR 11-1583 associated with OFN RP-017, Rev. 36 evaluates this change.

Prior to the See Section 6.5 for D7 RNO Manually close EF HV- S See Step D6 Basis needfor timing basis for No D4 supported ESW.

equipment

Design Basis Document for Procedure OFN RP-017 Page 92 of 102 E ir-9915, Rev-. I TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

With the SIS flow path open, it would take a considerable This step ensures one of the two SIS test lines is amount of time to isolated to prevent flow diversion through the test line. reduce RWST In South Electrical Pen tetraion RStep D15 isolates the second line. Both valves are that needed for safe Penetration Room, normally closed and fail closed on loss of power. shutdown. Per XX-Place Boron Linj Switch EM HS-8843 will isolate power to the valve and E-013, 214,260 Upstream Test Line fail it closed. E03 1,6 D8 Switch To NORM ISOICLOSE M 711hus hours from thecan gallons RWST.

be lost N No /

N/A ISOICLOSE. The SIS test lines discharge into a common %inch Assm 50 gpm line. Flow would then pass two normally closed % lost through the 3/4"

. EM HS-8843 - inch air operated valves before returning to the RWST SIS test line, it ISO/CLOSED or the RHUT. For the failure to occur, there would would take 71 have to be 3 spurious actuations, which is extremely hours to reduce unlikely and is not postulated for a control room fire. RWST volume to a level below that required for safe shutdown.

Design Basis Document for Procedure OFN RP-017 Page 93 of 102 E !FOS! 6, Rev. I-TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1) (mot(Nte(min)

On NG02B, Start Electrical Penetration Based on the Wolf Creek TRM, Table TR 3.7.22-1, the Room Cooler: allowable temperature inthe Train B electrical The timing of this penetration room is 101 F. The maximum step is based on

a. At NG02BAF2, temperature is 131 F. the time for the place Norm/Iso- Prior to room room to reach Run switch to ISO- Switch GL HS-35, when placed inISOIRUN position, reaching temperatures D9 RUN S will isolate the control room circuit and insert a reahn beyond operability No N/A redundant fuse. However, the unit will not start until unacceptable limits of the o GL HS the start push button is depressed, which will energize temperature equipment. See ISO-RUN the 42 coil, close the seal incontact and start the unit. Section 6.5 for Therefore, both GL HS-35 and the push button need discussion on room

b. At NG02BAF2, to be actuated to start the cooler. Step C13 cooling.

depress start establishes power to the cooler.

pushbutton On NG02B, Isolate Power To EG HV-133, Step B10 verifies EG HV-133 is dosed after this step Prior to the 010 CCW RETURN HV-61 is complete. This valve is closed for the same reason need for discussion about No N/A BYPASS ISO VLV. that EG HV-61 is dosed. See the discussion for Step supported cCW.

5.c. systems COW.

NG02BHF1 - OFF This step provides confirmation to the RO that Step D8 has been completed.

Inform the Reactor See Step 022 for D11 Operator that CCW S Step C22.a requires the RO to confirm Step B10 is 28 timing basis for N/A N/A Alignment is complete. Step B13cannot be completed until Steps CCW.

Completed 5.c and D8 are complete. When Steps 5.c, D8 and B10 are complete, the RO can start the CCW pump in Step C22.b.

Design Basis Document for Procedure OFN RP-017 Page 94 of 102 E 1 FOB! 5, R.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Prereq STEP DESCRIPTION Function BASIS To TIMING BASIS Impact?

Complete (Note 2) Steps (Note 1)

(min)

DCP 11086 added a control room isolation switch and redundant fusing at MCC cubicle NG02BHF3 for valve EF HV-34. This ensures the valve will open (ifclosed)

On NG02BHF3, Open and remain open throughout the event when EF HS-ESW TO CTMT 34 is placed inthe ISO/OPEN position and power is See Section 6.5 for Isolation Valve: restored to NG02B. This valve is required to be open discussion about D12 to ensure ESW flow to the Train B containment 60 containmentNo N/A

EF HS coolers. cooling.

ISO/OPEN Step C11 establishes power to load center NG02, which supplies power to cubicle NG02BHF3. IfStep D10 is performed prior to Step Cl1, there will be no adverse impact.

DCP 11086 added a control room isolation switch and redundant fusing at MCC cubicle NG02BHR2 for valve EF HV-46. This ensures the valve will open (if On ESWNG02BHR2, Open closed) andisremain FROM CTMT EF HS-46 placed open inthethroughout ISO/OPEN the event and position when See Section 6.5 for Isolation Valve: power is restored to NG02B. This valve is required to discussion about D13 be open to ensure ESW flow from the Train B 60 containmentNo N/A EF HS46- containment coolers. cooling.

ISO/OPEN Step Cll establishes power to load center NG02, which supplies power to cubicle NG02BHR2. IfStep D01 is performed prior to Step Cl, there will be no I adverse impact

Design Basis Document for Procedure OFN RP-017 Page 95 of 102 E Ir9916, Rev.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) Complete (Note 2) Steps (Note1)(rmin)

On NG02B, open ESW TolFrom CTMT Air DCP 12131 added control room isolation switches and Cooler Valves, redundant fuses at MCC cubicles NG02BDR1 (EF

a. At NGO2BDR1 open HV-32) and NG02BDR2 (EF HV-50) for these valves.

EF HV-32 ESW BTo This ensures valves EF HV-32 and EF HV-50 will CTMT Air Coolers open (ifclosed) and remain open throughout the event when EF HS-32 and EF HS-50 are placed inthe See Section 6.5 for D14

EF HS S ISO/OPEN position and power is restored to NG02B. 60 discussion about No N/A ISO/OPEN These valves are required to be open to ensure ESW containment flow to/from the Train B containment coolers. cooling.

b. At NG02BDR2 open Step Cll establishes power to load center NG02, EF HV-50 ESW B From which supplies power to cubicles NG02BDR1 and CTMIT Air Coolers NG02BDR2. IfStep D12 is performed prior to Step

EF HS Cll, there will be no adverse impact.

ISO/OPEN Start Containment DCP 12177 installed a redundant fuse inthe control Cooler Fans B and D: circuit for each fan so that, inthe event of a fire inthe control room, the fans will start when GN HS-9A and

a. At NG02TAF1, start GN HS-17A are placed inISO/RUN position and CTMT Cooler Fan B power is restored to NG02T and NG04T.

See Section 6.5 for

GN HS-9A - Step Cl1 establishes power to load center NG02, discussion aboutr D15 ISO/RUN S which supplies power to NG02TAFI. If Step D13 is' N/A containment No N/A performed prior to Step C11, there will be no adverse cooling.

b. At NG04TAF1, start impact. cooling.

CTMT Cooler Fan D Step C13 establishes power to load center NG04,

GN HS-17A - which supplies power to NG04TAF1. IfStep D13 is ISO/RUN performed prior to Step Cl13, there will be no adverse I impact. I I I

Design Basis Document for Procedure OFN RP-017 Page 96 of 102 E-IF9916, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire eqdTim Prereq DESCRIPTION Function BASIS To TIMING BASIS Impact? Steps STEP Complete (Note 2) Steps (Note 1)

(min)

This step ensures one of the two SIS test lines is In North Electrical isolated to prevent flow diversion through the test line.

Penetration Room, Step D6 isolates the second line. Both valves are Place Boron Inj normally closed and fail closed on loss of power.

Switch EM HS-8882 will isolate power to the valve and Downstream Test fail it closed.

D16 Line NORM ISOICLOSE M 71 hours8.217593e-4 days 0.0197 hours 1.173942e-4 weeks 2.70155e-5 months See D6 discussion. No N/A ISOICLOSE. Switch to The SIS test lines discharge into a common %inch ISOICLOSE. line. Flow would then pass two normally closed %

EM HS-8882 - inch air operated valves before returning to the RWST or thetoRHUT.

have For the failure be 3 spurious to occur, actuations, whichthere would is extremely unlikely and is not postulated for a control room fire.

SA-08-006 shows Ensure MSIVs Are all four MSIVs can Closed By stay open for at Unplugging the least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as long Amphenal as there are no Connectors: This step ensures the MSIVs are closed ifthey did not other failures. The close inStep 3. The MSIVs were replaced per DCPs steam dumps are D17

AB HV A 09952 and 11608 with system medium actuated 60 isolated inStep C2 No N/A Train TB14540 valves. Unplugging the Amphenal connectors will and the steam

AB HV A isolate power to one train of solenoids and fail the generator ARVs will Train TB14533 valves closed, control

AB HV A temperature. See Train TB14538 Section 6.1 for

AB HV A additional Train TB14535 discussion regarding MSIVs.

Design Basis Document for Procedure OFN RP-017 Page 97 of 102 E !F9915, Rev-.4 TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP IN OFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact? Prereq STEP DESCRIPTION Complete (Note 2) Steps (Note 1) (min)

This step ensures the SRO knows the Amphenal Notify SRO at the Aux connectors have been pulled. The new MSIVs have See 015 D18 Shutdown Panel, N/A no external position indication so the operator at the 60 discussion. N/A N/A Status of MSIVs ASP will have to rely on available instrumentation to determine position.

Request SRO At ASP To Ensure SIG A And C ARVs - CLOSED See Section 6.1 for AB PV-1 and AB PV-3 are closed by the SRO at the discussion about D19 R, M,D ASP. AB PV-2 and AB PV-4 are isolated from the 60 steam generatorN/A CLOSED control room and controlled from the ASP. ARVs.

AB PV CLOSED Isolate air and N2 to AB PV-3, SG C ATMOSPHERIC RELIEF VLV:

a. KAV1445 -

CLOSED See Section 6.1 for D20 R, M, D This step isolates air and nitrogen and bleeds air from 60 discussion about No N/A

b. KAV1366- the regulator to prevent the valve from opening. steam generator CLOSED ARVs.

c. Vent air from regulator

d. Verify AB PV-3 closed

Design Basis Document for Procedure OFN RP-017 Page 98 of 102 E lr-9915, R"~

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq STEP (Note )(rain) Complete (Note 2) Steps (Note 1)

d. Close AB-V029, SG IfAB PV-3 cannot be closed, then manual valve AB- See Section 6.1 for D20 RNO C ATMOSPHERIC R, M,D V029 can be closed to isolate steam generator C 60 discussion about No N/A RELIEF VLV ISO ARV. steam generator

_________ ________ ARVs. ____ ___

Isolate air and N2 to AB PV-1, SG A ATMOSPHERIC REUEF VALVE

a. KAV1435-CLOSED See Section 6.1 for D21 bR, MD This step isolates air and nitrogen and bleeds air from 60 discussion about No N/A

b. KAV1364 - the regulator to prevent the valve from opening. steam generator CLOSED ARVs.

c. Vent air from regulator

d. Verify AB PV-1 closed

d. Close AB-V01 8, SG IfAB PV-1 cannot be dosed, then manual valve AB- See Section 6.1 for D21 RNO AATMOSPHERIC R, M,D V01 8 can be closed to isolate steam generator A 60 discussion about No N/A RELIEF VLV ISO ARV. steam generator ARVs.

Design Basis Document for Procedure OFN RP-017 Page 99 of 102 E !F-9916, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq Complete (Note 2) Steps (Note 1)

(min)

Technical Requirement 3.7.23 states that with one InSGKO4B Room, Class lE A/C Unit Start Class 1E This step ensures room cooling to the Class 1E inoperable, Electrical Equipment switchgear rooms. The cooler needs to be started establish EcC Unit: before the rooms reach a temperature beyond operating limits for the equipment. Based on the compensatory

. Position SGK05B TRM, Table 3.7.22-1, the maximum allowable measures within 2 D22 NORMAL S temperature inthe rooms supplied by SGK05B is 101 60 hours. or the No C9, C12 ISOIRUN Switch F. Inorder for the unit to operate, there needs to be rpo ou wil To ISO/RUN power to NG02A and ESW flow to the cooler. Power RP-017, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months will is restored inStep Cl. ESW lineup is completed by mi uieme o GK HS-103 - step C12. Steps Cll and C12 should be completed timing requirement ISO/RUN well before Step D20. to restore cooling.

ISO/RUNSee Section 6.5 for additional discussion about room cooling.

D23 Proceed As Directed N/A Attachment D is complete and the SRO will direct the N/A N/A. N/A N/A By SRO at ASP. operator at this point.

Proceed to NB02 Switchgear Room And Obtain The El Following: N/A Procedure is required to complete remaining N/A N/A N/A N/A Attachment E steps.

Copy of this procedure

Flashlight

Design Basis Document for Procedure OFN RP-017 Page 100 of 102 E 1F9916, Re".

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) (Note1)(rain) Complete (Note 2) Steps Place BN HV-8812A, Calculation XX-E-RWST TO RHR PUMP 013 shows there is A SUCTION This Step ensures BN HV-8812A is de-energized and 28 minutes E2 ISOLATION VALVE M will not spuriously operate after it has been manually 28 available before the No N/A Breaker To Off closed inthe next step. RWST drains to a level below that NG01ACR2 -OFF required for cold shutdown.

Valve BN HV-8812A is normally open and is manually closed inOFN RP-017 to prevent the RWST from In RHR Pump Room draining to the containment sump inthe event EJ HV- Based on XX-E-A,Close RWST To 881 1A spuriously opens. Valve BN HV-8812A is a 013, operators have RHR Pump A Train A valve so power may not be available, which is 28 minutes to close E3 Isolation Valve. M why manual operation is required. Step E2 isolates 28 the valve and No E2 power to the control circuit to prevent spurious prevent the RWST

BN HV-8812A - operation after the valve is closed. DCP 12173 from draining to the CLOSED modified the control circuit to ensure a control room containment sump.

fire will not damage the valve and prevent manual closure.

Design Basis Document for Procedure OFN RP-017 Page 101 of 102 E 1F9916, Re.

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire Function BASIS To TIMING BASIS Impact?

STEP DESCRIPTION (Nt )Complete (Note 2) Steps (Note 1) (min)

Ascend Ladders To 2000 Elevation Aux Feedwater Pump Room Area And Close The Following Valves:

o TD AFWP DISCHARGE TO SG AHV-8 INLET ISO.

o AL-V056 -

CLOSED

" TDIAFWP Calculation SA DISCHARGE TO 006 shows that the SGsteam generators E4 ISO. D This step isolates possible AFW flow diversion paths 35 could overfill ifthe No N/A o AL-V061 - to prevent overfilling the steam generators, valves are not CLOSED closed within 35

" MD AFWP minutes.

DISCHARGE TO SG AHV-7 INLET ISO.

o AL-V032-CLOSED o TD AFWP DISCHARGE TO SG C HV-12 INLET ISO.

o AL-V071 -

CLOSED

Design Basis Document for Procedure OFN RP-017 Page 102 of 102 E !F9915, R".-!

TABLE 7.1 DETAILED EVALUATION OF EACH ACTION STEP INOFN RP-017 PFSSD Req'd Time CR Fire STEP DESCRIPTION Function BASIS To TIMING BASIS Impact? Prereq (Note 1) (Note )(rain) Complete (Note 2) Steps Notify HP that a non- This step notifies HP that the operator entered the E5 RCA area was entered N/A auxiliary feedwater area from the RCA and the area N/A N/A N/A N/A into from the RCA. may be contaminated.

Proceed To ASP And E6 The SRO That BNV-8Inform Attachment E is complete and the SRO will direct the N/A N/A N/A N/A E6 BN HV-8812A and the N/A operator at this point.N/ NANA NA Aux Feedwater Valves Are Closed.

Actions to Protect This attachment was added based on Reference Aft F ainA Protent N/A 3.1.a. See discussion under Reference 3.1.a and N/A N/A N/A N/A Train AEquipment Step A16.

This attachment is included to provide instructions to Aft G Manual SiemensCharging Circuit of operators on howThis to manually charge the Siemens N/A circuit breakers. attachment is used for some N/A N/A N/A N/A Breakers RNO actions throughout the procedure. The springs are charged for one cycle of operation so entering the attachment will not normally be necessary. I I I II Table Notes:

1. PFSSD Functions are as follows: R - Reactivity Control; M - Reactor Coolant Makeup and Inventory Control; D - Decay Heat Removal; P -

Process Monitoring; S - Support; N/A - Not Applicable

2. The column labeled "CR Fire Impact?" identifies if a fire in the control could potentially cause the component to mis-position after the step has been completed. Yes means the component can mis-position and No means the component cannot mis-position. N/A means the question is not applicable to the step.

Design Basis Document for Procedure OFN RP-017 Appendix I E -IF9916, Rev. 4 Page I of 30 Appendix 1 OFN RP-017 Credited Component Evaluation

Design Basis Document for Procedure OFN RP-017 Appendix I E-Ir-9915, Rev-. ! Page 2 of 30 Table Al documents whether the components credited for hot standby following a control room fire are properly protected against hot shorts, open circuits or shorts to ground that could occur due to a fire in the control room. Also, the evaluation documents whether adequate isolation capability is provided to ensure the credited components remain functional and unaffected by the fire after control room isolation is completed.

This evaluation was performed to satisfy an NRC commitment made in Licensee Event Report 2010-003-00. This evaluation was originally performed as a corrective action for CR 00023410-02-01 and is being added to E-1 F9915 per CR 00044460-02-01 to ensure the information is maintained in a controlled document. The evaluation has been updated since the original evaluation in CR 00023410-02-01 to reflect the current configuration in OFN RP-017.

Table Al OFN RP-017 Credited Component Evaluation Component Evaluation ABHS0079 and The main steam isolation valves (MSIVs) are closed in OFN RP-01 7 to prevent rapid cooldown and return to criticality.

ABHS0080 Operators, upon exiting the control room, actuate All Close hand switches ABHS0079 and ABHS0080 to close the MSIVs.

The Wolf Creek fire protection licensing basis does not allow us to credit that this actually works. Therefore, later steps have operators remove power from the MSIV solenoids to fail them closed. The circuit is shown on drawings E-1 3AB26, E-1 3AB27, E-13AB28 and E-13AB29.

Power is removed from the A Train solenoids by placing NK5119 in the OFF position. This isolates separation group 1 power from MSFIS cabinet SA075A and fails the MSIVs closed. This also fails the main feedwater isolation valves closed, which is the desired PFSSD position.

Power is also removed from the A Train solenoids by removing the Amphenol connectors at the associated terminal box. Loss of power to either train of solenoids will fail the MSIVs closed. A Train was chosen for convenience. Based on review of the drawings, a fire in the control room will not cause the MSIVs to re-open after the Amphenol connectors are dis-connected.

Based on the above discussion, the MSIVs are Drotected.

Design Basis Document for Procedure OFN RP-017 Appendix I E !F99115, Re". Page 3 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation ABHV0005 Valve ABHV0005 controls steam to the turbine driven auxiliary feedwater pump (TDAFP) from Steam Generator B and opens upon loss of 125 VDC power to the solenoid valve. Redundant control power originates from NK4201 through relay panel RP334 (Dwg E-13RP14) which does not run in the control room. Placing ABHIS0005B in the open position drops power to the solenoid and opens the valve. Upon arrival at the ASP, Operators place hand switch RPHIS0001 in the ISOLATE position per OFN RP-01 7. This energizes lockout relay 86XRP3 (Dwgs E-1 3RP1 1 and E-1 3RP1 5), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. Hand switch ABHIS0005B is placed in the open position at the ASP to open the valve and allow a steam supply to the TDAFP. The control circuit is isolated from the control room when RPHIS0001 is placed in the isolate position. Drawing E-13AB01A shows the control circuit. Based on a review of this drawing, the lockout relay contacts will isolate all portions of the circuit that run to the control room. A fire in the control room will not adversely impact valve ABHV0005 after the isolation switch is operated.

Based on the above discussion, hand switch RPHIS0001 will isolate the control room and insert redundant fuses into the circuit so that hand switch ABHIS0005B will function. Therefore, ABHV0005 is protected.

ABHV0006 Valve ABHV0006 controls steam to the turbine driven auxiliary feedwater pump (TDAFP) from Steam Generator C and opens upon loss of 125 VDC power to the solenoid valve. Hand switch ABHIS0006B is placed in the closed position at the ASP to close the valve and prevent steaming steam generator C, which is not being provided with feedwater flow in procedure OFN RP-017. Upon arrival at the ASP, Operators place hand switch RPHIS0001 in the ISOLATE position per OFN RP-017. This energizes lockout relay 86XRP2 (Dwgs E-1 3RP1 1 and E-1 3RP1 5), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. Drawing E-13AB01 shows the control circuit.

The valve opens upon loss of 125 VDC power to the solenoid valve and closes when the solenoid valve is energized.

Redundant control power originates from NK4201 through relay panel RP334 (Dwg E-13RP14), which does not run in the control room. Placing RPHIS0001 in the ISOLATE position maintains power to the ABHV0006 control circuit and allows operators to maintain the valve in the closed position from the ASP. A fire in the control room will not affect operation of the valve after RPHIS0001 is placed in the isolate position. In the unlikely event valve ABHV0006 opens, PFSSD is assured because steam flow to the TDAFP remains available.

Based on the above discussion, hand switch RPHIS0001 will isolate the control room and insert redundant fuses into the circuit so that hand switch ABHIS0006B will function. Therefore, valve ABHV0006 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix 1 E ir-9915, Rev-.-4 Page 4 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation ABHV0012, MSIV Bypass valves ABHV0012, ABHV0015, ABHV0018 and ABHV0021 are failed closed in OFN RP-017 by removing 125 ABHV001 5, VDC control power from the control circuit. Control power is removed by pulling fuse #46 in panel RP209. This de-energizes ABHV001 8 and auxiliary relay 94XAB05 and subsequently de-energizes solenoid valves associated with the MSIV bypass valves and causes ABHV0021 them to close. The valve circuit is shown on drawing E-13AB23A. Panel RP209 wiring for fuse block 46 is shown on drawing E-093-00048. Based on drawing E-093-00048 fuse block 46 does supply power to auxiliary relay 94XAB05. Therefore, removal of fuse block 46 will cause the MSIV bypass valves to close. The MSIV bypass valves are not considered high/low pressure interfaces so consideration of multiple proper polarity hot shorts is not required. The negative side of the circuit shown on drawing E-1 3AB23A does not run in the control room. Therefore, after the fuse is pulled there is no possibility that the bypass valves can spuriously open as a result of a fire in the control room.

Based on the above discussion, the MSIV bypass valves are adequately protected in the event of a control room fire.

ABPV0001 and Steam generator ARVs ABPV0001 and ABPV0003 are closed in OFN RP-01 7 by isolating air and nitrogen to the valves and ABPV0003 venting air from the regulators. The ARVs are not isolated from the control room. The Train A ASP has hand switches (ABHS0001 and ABHS0003) that transfer control of ABPV0001 and ABPV0003 to the ASP but the circuits run in the control room. Drawings J-1 10-00216 and J-1 10-00220 show the loop diagram for these circuits.

For PFSSD, only two steam generators are needed to maintain hot standby. The control room fire strategy uses steam generator B and D ARVs (ABPV0002 and ABPV0004) for temperature control and closes steam generators A and C ARVs (ABPV0001 and ABPV0003) to prevent uncontrolled cooldown.

Loss of air and nitrogen to the ARVs will fail the valves closed. A fire in the control room will not cause the valves to open in the absence of air and nitrogen. Therefore, ARVs ABPV0001 and ABPV0003 are protected.

ABPV0002 and Steam generator ARVs ABPV0002 and ABPV0004 are controlled in OFN RP-017 at the ASP to control RCS temperature.

ABPV0004 Hand switches ABHS0002 and ABHS0004 at the ASP are placed in the LOCAL position to transfer control from the control room to the controller at the Train B ASP. The LOOP diagrams for ABPV0002 are shown on drawings J-1 10-00218, J-1 10-00219 and J-1 10-00933. The LOOP diagrams for ABPV0004 are shown on drawings J-1 10-00222, J-1 10-00223 and J-1 10-00934.

Based on a review of these drawings and discussion with the Instrumentation and Control group, ABHS0002 and ABHS0004 will transfer control to the ASP and the control room circuit is isolated after these switches are placed in local position.

Therefore, ABPV0002 and ABPV0004 are protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E !F9916, Re. Page 5 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation AELI0502A This level indicator is used to verify steam generator B level. Drawings E-13AE08 and M-761-02303 show the circuit arrangement. Level transmitter AELT0502 sends a signal to SB148A in the Train B ESF switchgear room. From SB148A the signal is split and sent to the main control room indicator AEL10502 and ASP indicator AEL10502A. A fire in the control room that affects AEL10502 and associated cable will not affect AELI0502A because the signal converter will isolate any effects from a short occurring in the control room. Therefore, AEL10502A is protected.

AELI0504A This level indicator is used to verify steam generator D level. Drawings E-13AE08 and M-761-02310 show the circuit arrangement. Level transmitter AELT0504 sends a signal to SB148B in the Train B ESF switchgear room. From SB148B the signal is split and sent to the main control room indicator AELI0504 and ASP indicator AELI0504A. A fire in the control room that affects AEL10504 and associated cable will not affect AEL10504A because the signal converter will isolate any effects from a short occurring in the control room. Therefore, AELI0504A is protected.

ALHV0005 Valve ALHV0005 is controlled at the ASP by placing hand switch ALHS0005 in the local position and controlling the valve using ALHK0005B. The AL HV-5 circuit is shown on drawings J-1 10-00349, J-1 10-00871 and J-1 10-00939. Technical data sheets for the Foxboro 200 system are provided in vendor manual J-1 10-00388. These drawings and data sheets were reviewed to determine the circuit configuration and operation of the local hand switch and local valve controller.

When the local hand switch (ALHS0005) is placed in the LOCAL position, relay coils on a relay logic card are energized and the contacts change state. The change of state selects the output from the controller at the ASP and de-selects the control room controller. A fire in the control room could affect the control room controller but any spurious signal would not affect the valve controller. This is because spurious signals or hot shorts originating in the control room are isolated in RP147B by either contact output isolators or isolated current to voltage converters. Based on vendor manual J-1 10-00388, these devices will prevent spurious signals or hot shorts originating in the control room from affecting the ability to control ALHV0005 from the ASP.

The physical makeup of the relay contacts allows only one possible state for each set of contacts. Therefore, the contact pair cannot be both open or both closed. One contact will be open and the other will be closed. Since the test procedure provides positive confirmation that the controller at the ASP does work, this provides reasonable assurance that the controller in the control room is completely isolated from the circuit when the local hand switch is placed in the LOCAL position.

Based on the above discussion, there is reasonable assurance that AL HV-5 is isolated from the control room by demonstration that the controller at the ASP operates the valve. Therefore, ALHV0005 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix 1 E IF99115, Re. Page 6 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation ALHV0010 Valve ALHV0010 is controlled at the ASP by placing hand switch ALHS0010 in the local position and controlling the valve using ALHK0O01 0B. The AL HV-1 0 circuit is shown on drawings J-1 10-00354, J-1 10-00940 and J-1 10-00941. Technical data sheets for the Foxboro 200 system are provided in vendor manual J-1 10-00388. These drawings and data sheets were reviewed to determine the circuit configuration and operation of the local hand switch and local valve controller.

When the local hand switch (ALHS001 0) is placed in the LOCAL position, relay coils on a relay logic card are energized and the contacts change state. The change of state selects the output from the controller at the ASP and de-selects the control room controller. A fire in the control room could affect the control room controller but any spurious signal would not affect the valve controller. This is because spurious signals or hot shorts originating in the control room are isolated in RP147B by either contact output isolators or isolated current to voltage converters. Based on vendor manual J-1 10-00388, these devices will prevent spurious signals or hot shorts originating in the control room from affecting the ability to control ALHV0010 from the ASP.

The physical makeup of the relay contacts allows only one possible state for each set of contacts. Therefore, the contact pair cannot be both open or both closed. One contact will be open and the other will be closed. Test procedure STS RP-004 provides positive confirmation that the controller at the ASP does work, so this provides reasonable assurance that the controller in the control room is completely isolated from the circuit when the local hand switch is placed in the LOCAL position.

Based on the above discussion, there is reasonable assurance that ALHV0010 is isolated from the control room. Therefore, ALHV001 0 is protected.

ALHV0030 Valve ALHV0030 is opened when necessary using ALHIS0030B to supply the Train B MDAFP with ESW. Upon arrival at the ASP, Operators place hand switch RPHIS0002 in the ISOLATE position per OFN RP-01 7. This energizes lockout relay 86XRP5 (Dwgs E-13RP12 and E-1 3RP1 5), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. Drawing E-1 3AL04B shows the control circuit for this valve. Based on a review of this drawing, the lockout relay contacts will isolate all portions of the circuit that run to the control room. A fire in the control room will not adversely impact valve ALHV0030 after the isolation switch is operated.

Based on the above discussion, hand switch RPHIS0002 will isolate the control room and insert redundant fuses into the circuit so that hand switch ALHIS0030B will function. Therefore, valve ALHV0030 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9916, Re. Page 7 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation ALHV0033 OFN RP-017 places ALHIS0033B in the close position to ensure valve ALHV0033 is closed. Step A15 opens the valve when it is necessary to swap to ESW to supply the TDAFW pump. Upon arrival at the ASP, Operators place hand switch RPHIS0002 in the ISOLATE position per OFN RP-017. This energizes lockout relay 86XRP6 (Dwgs E-13RP12 and E-13RP15), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. The control circuit is shown on drawing E-1 3AL04B. Based on a review of this drawing, the lockout relay contacts will isolate all portions of the circuit that run to the control room. A fire in the control room will not adversely impact valve ALHV0033 after the isolation switch is operated.

Based on the above discussion, hand switch RPHIS0002 will isolate the control room and insert redundant fuses into the circuit so that hand switch ALHIS0033B will function. Therefore, ALHV0033 is protected.

ALHV0034 OFN RP-017 places ALHIS0034B in the open position to open valve ALHV0034. The ALHV0034 circuit is isolated from the control room when RPHIS0002 is placed in the isolate position. Upon arrival at the ASP, Operators place hand switch RPHIS0002 in the ISOLATE position per OFN RP-017. This energizes lockout relay 86XRP5 (Dwgs E-13RP12 and E-13RP1 5), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. The control circuit is shown on drawing E-13AL02B. Based on a review of this drawing, the lockout relay contacts will isolate all portions of the circuit that run to the control room. A fire in the control room will not adversely impact valve ALHV0034 after the isolation switch is operated. The valve may not readily open when ALHIS0034B is placed in the open position because power is not restored to the MCC until Step C13. This is acceptable because AFW is not needed until 15 minutes into the event. Step C13 is completed prior to 15 minutes.

Based on the above discussion, hand switch RPHIS0002 will isolate the control room and insert redundant fuses into the circuit so that hand switch ALHIS0034B will function. Therefore, ALHV0034 is protected.

ALHV0036 Valve ALHV0036 is manually operated in OFN RP-017 because this valve is powered from Train A MCC cubicle NG03CEF4.

Power is disconnected from the valve by opening Train A MCC cubicle breaker NG03CEF4. Train A components are not protected against faults occurring as a result of a control room fire. The control circuit for valve ALHV0036 is shown on drawing E-13AL02C. Change package 12170 modified the control circuit to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures a control room fire will not damage the valve and prevent it from being opened manually. Therefore, ALHV0036 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix 1 E 1IF994, Re. Page 8 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation APLI0004B Condensate Storage Tank (CST) Level Indicator APLI0004B is used by operators in OFN RP-017 to verify level in the CST.

When level drops to 14%, the procedure directs operators to swap to the ESW source. OFN RP-017 also directs operators to use the local indicator. Level indicator APLI0004B circuit is shown on drawing J-1 10-00098. Based on a review of this drawing, the level indicator is not isolated from the effects of a control room fire and could provide erroneous readings. The Note above the Step in OFN RP-01 7 where APLI0004B is used states that level indicator APLI0004B could be affected by the fire. Therefore, Operators will be aware that they should not rely on this level indicator. Isolation of this level indicator is not required because level in the CST is not a concern initially since sufficient volume exists to supply the steam generators for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . At that time, sufficient personnel will be available to locally monitor CST level. Therefore, the configuration is acceptable.

BBLI0460B This level indicator is used to verify pressurizer level. Drawings E-13BB16 and M-761-02304 show the circuit arrangement.

Level transmitter BBLT0460 sends a signal to SB148A in the Train B ESF switchgear room. From SB148A the signal is split and sent to the main control room indicator BBLI0460A and ASP indicator BBLI0460B. A fire in the control room that affects BBLI0460A and associated cable will not affect BBLI0460B because the signal converter will isolate any effects from a short occurring in the control room. Therefore, BBLI0460B is protected.

BBPI0406X This pressure indicator is used to verify RCS pressure is being maintained between 2000 and 2300 psig. The circuit arrangement is shown on drawings E-13BB16 and M-761-02311. Pressure transmitter BBPT0406 sends a signal to SB148B in the Train B ESF switchgear room. From SB148B the signal is split and sent to the main control room indicator BBPI0406 and ASP indicator BBPI0406X. A fire in the control room that affects BBPI0406 and associated cable will not affect BBTPI0406X because the signal converter will isolate any effects from a short occurring in the control room. Therefore, BBPI0406X is protected.

BBTI0423X This temperature indicator is used to verify RCS Loop 2 cold leg temperature. Drawings E-13BB15 and M-761-02301 show the circuit arrangement. Loop 2 cold leg temperature element BBTE0423B sends a signal to Cabinet 2A which is SB148A located in the Train B ESF switchgear room (Fire Area C-1 0). From SB1 48A the signal is split and sent to the main control room indicator BBTI0423B and ASP indicator BBTI0423X. A fire in the control room that affects BBTI0423B and associated cable will not affect BBTI0423X because the signal converter will isolate any effects from a short occurring in the control room.

Therefore, BBTI0423X is protected.

BG8402B Valve BG8402B is a manual valve. A control room fire will not affect operation of the valve. Therefore, BG8402B is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9916, Rev-.4 Page 9 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation BGHV81 11 Valve BGHV81 11 is opened in OFN RP-017 to ensure adequate minimum flow through the Train B charging pump. This prevents heatup and damage to the pump. Hand switch BGHS81 11A, located at MCC cubicle NG02AHRI, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-13BGI C. The circuit was modified in DCP 12175 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02AHR1. A previous step restores power to the MCC so that when the switch is actuated, the valve will open.

Based on the above discussion, valve BGHV81 11 is protected.

BGLCV01 12C Valve BGLCV01 12C is closed in OFN RP-017 to isolate the VCT from the charging header. Hand switch BGHS0112C is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and close the valve. The circuit is shown on drawing E-1 3BG1 2A. The circuit was modified in DCP 12131 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will close when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and close the valve. Power to the valve is from MCC cubicle NG02AFR2. A previous step restores power to the MCC so that when the switch is actuated, the valve will close.

Based on the above discussion, valve BGLCV01 12C is protected.

BGV0017 Valve BGV0017 is a manual valve. A control room fire will not affect operation of the valve. Therefore, BGV0017 is protected.

BGV0101 Valve BGV01 01 is a manual valve. A control room fire will not affect operation of the valve. Therefore, BGV01 01 is protected.

BGV0105 Valve BGV0105 is a manual valve. A control room fire will not affect operation of the valve. Therefore, BGV0105 is protected.

BNHV8812A Valve BNHV8812A is manually closed in OFN RP-017 to prevent draindown of the RWST to the containment sump. This valve is powered from Train A MCC cubicle NG01ACR2. The operator removes power from the valve by opening NG01ACR2 before manually closing the valve. The control circuit is shown on drawing E-1 3BN03. The circuit is not isolated from the control room. Removal of power will prevent spurious operation of the valve in the event of a control room fire. DCP 12173 modified the control circuit to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve can be manually closed when needed. Therefore, valve BNHV8812A is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I EIF-9916, Rev. 4 Page 10 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation BNHV8812B Valve BNHV8812B is closed in OFN RP-017 to prevent flow diversion from the RWST to the containment sump. Hand switch BNHS8812B is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and close the valve. The circuit is shown on drawing E-13BN03A. The circuit was modified in DCP 12173 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will close when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and close the valve. Power to the valve is from MCC cubicle NG02AFF4. A previous step restores power to the MCC so that when the switch is actuated, the valve will close.

Based on the above discussion, valve BNHV8812B is protected.

BNLCV01 12E Valve BNLCV0112E is opened in OFN RP-017 to establish a suction source from the RWST to the Train B CCP. Hand switch BNHSO1'12E, located at MCC cubicle NG02AHR3, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-13BNO1A. The circuit was modified in DCP 12175 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02AHR3. A previous step restores power to the MCC so that when the switch is actuated, the valve will open.

Based on the above discussion, valve BNLCV01 12E is protected.

EFHV0026 Valve EFHV0026 is closed in OFN RP-01 7 to prevent flow diversion from ESW to the service water piping. Hand switch EFHS0026A is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and close the valve. The circuit is shown on drawing E-13EF02A. The circuit was modified in DCP 12170 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will close when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and close the valve. Power to the valve is from MCC cubicle NG02AHF2. A previous step restores power to the MCC so that when the switch is actuated, the valve will close.

Based on the above discussion, valve EFHV0026 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9916, Roy.! Page 11 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EFHV0032 Valve EFHV0032 is opened in OFN RP-01 7 to establish Train B ESW flow to the Train B containment coolers. Hand switch EFHS0032, located at MCC cubicle NG02BDR1, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-13EF07A. The circuit was modified in DCP 12131 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position.

The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02BDR1. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EFHV0032 is protected.

EFHV0034 Valve EFHV0034 is opened in OFN RP-017 to establish Train B ESW flow to the Train B containment coolers. Hand switch EFHS0034, located at MCC cubicle NG02BHF3, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EF09A. The circuit was modified in DCP 11086 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on themotor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position.

The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02BHF3. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EFHV0034 is protected.

EFHV0038 Valve EFHV0038 is opened in OFN RP-01 7 to establish Train B ESW flow to the UHS. Hand switch EFHS0038A, located at MCC cubicle NG02AHF3, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-13EF06A. The circuit was modified in DCP 12170 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02AHF3. A previous step restores power to the MCC so that when the switch is actuated, the valve will open.

Based on the above discussion, valve EFHV0038 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E-IF9915, Rev. 4 Page 12 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EFHV0046 Valve EFHV0046 is opened in OFN RP-017 to establish Train B ESW flow to the Train B containment coolers. Hand switch EFHS0046, located at MCC cubicle NG02BHR2, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EF09A. The circuit was modified in DCP 11086 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position.

The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02BHR2. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EFHV0046 is protected.

EFHV0050 Valve EFHV0050 is opened in OFN RP-017 to establish Train B ESW flow to the Train B containment coolers. Hand switch EFHS0050, located at MCC cubicle NG02BDR2, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EF08A. The circuit was modified in DCP 12131 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position.

The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG02BDR2. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EFHV0050 is protected.

EFHV0052 Valve EFHV0052 is opened in OFN RP-017 to establish Train B ESW flow to the Train B CCW heat exchanger. Hand switch EFHS0052, located at MCC cubicle NG04CNF3, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EF05A. The circuit was modified in DCP 12172 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position.

The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG04CNF3. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EFHV0052 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 4F9"&,-Re. Page 13 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EFHV0060 / Valve EFHV0060 is de-energized and closed in OFN RP-01 7 to prevent a flow imbalance in the essential service water (ESW)

NG04CHF2 system. The valve is normally closed with manual bypass valve EFV0090 throttled to maintain proper flow for normal and emergency conditions. Condition report 00041746 identified that valve EFHV0060 is not operated in procedure OFN RP-017 and that if the valve spuriously opens as a result of the fire, a flow imbalance would occur and ESW flow to credited components may not be adequate. Therefore, a compensatory measure was added to OFN RP-017 to open breaker NGO4CHF2 and close EFHV0060. Valve EFHV0060 has not been modified to address NRC IN 92-18. Change package 13898 is being prepared to modify the valve.

A fire in the control room could cause valve EFHV0060 to open and be damaged in the open position. The condition is being addressed by change package 13898.

EGHV0015 Valve EGHV0015 is manually closed in OFN RP-017 to prevent flow diversion from Train B CCWto Train A CCW. Breaker NG03CHF3 is opened in an earlier step to remove power from the circuit. The circuit is shown on drawing E-13EG05C. The circuit was modified in DCP 12170 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve can be manually closed when necessary.

A fire in the control room could damage the control circuit for the valve but the damage will not cause the valve to spuriously operate after the breaker is opened. Therefore, valve EGHVOO1 5 is protected.

EGHV0016 Valve EGHV0016 is opened in OFN RP-017 to establish Train B CCW flow from the service loop. Hand switch EGHS0016A, located at MCC cubicle NG04CJF3, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EG05A. The circuit was modified in DCP 12172 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG04CJF3. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EGHV0016 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I EIFf99:16, Re". Page 14 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EGHV0054 Valve EGHV0054 is opened in OFN RP-017 to establish Train B CCW flow to the service loop. Hand switch EGHS0054, located at MCC cubicle NG04CKF1, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EG05D. The circuit was modified in DCP 12172 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG04CKF1. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EGHV0054 is protected.

EGHV0061 Valve EGHV0061 is manually closed in OFN RP-017 because this valve is powered from Train A MCC cubicle NG03CKF3.

Train A components are not protected against faults occurring as a result of a control room fire. An operator removes 480 VAC power from the valve by opening NG03CKF3 before another operator manually closes the valve in another step. The control circuit is shown on drawing E-13EG09A. The circuit is not isolated from the control room, nor is it required to be isolated. Removal of power will prevent spurious operation of the valve in the event of a control room fire. A 120 VAC hot short on the control room portion of the circuit will not cause the valve to spuriously operate because 480 VAC power has been removed from the valves power circuit. DCP 12130 modified the control circuit to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures this does not occur so the valve can be manually operated when needed. Therefore, valve EGHV0061 is protected.

EGHV01 33 Valve EGHV0133 is manually closed in OFN RP-017. This valve is powered from Train B MCC cubicle NG02BHF1. An operator removes 480 VAC power from the valve by opening NG02BHF1 before another operator manually closes the valve in another step. The control circuit is shown on drawing E-13EG18A. The circuit is not isolated from the control room, nor is it required to be isolated. Removal of power will prevent spurious operation of the valve in the event of a control room fire. A 120 VAC hot short on the control room portion of the circuit will not cause the valve to spuriously operate because 480 VAC power has been removed from the valves' power circuit. DCP 12130 modified the control circuit to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures this does not occur so the valve can be manually operated when needed. Therefore, valve EGHV0133 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E I FOS, Rev.4 Page 15 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EMHV8801A I Valve EMHV8801A is closed in OFN RP-017 to prevent overfill of the pressurizer. This valve is powered from Train A MCC NG01 BER2 cubicle NG01 BER2. An operator removes 480 VAC power from the valve by opening NG01 BER2 before another operator manually closes the valve in another step. The control circuit is shown on drawing E-13EM02. The circuit is not isolated from the control room, nor is it required to be isolated. Removal of power will prevent spurious operation of the valve in the event of a control room fire. A 120 VAC hot short on the control room portion of the circuit will not cause the valve to spuriously operate because 480 VAC power has been removed from the valves' power circuit. Change package 13898 will be modifying the valve control circuit to address NRC IN 92-18 to ensure the valve can be manually closed. The pressurizer overfill concern was identified in CR 00045442.

EMHV8801B I Valve EMHV8801B is throttled in OFN RP-017 to control charging injection flow. This valve is powered from Train B MCC NG04CKF3 cubicle NG04CKF3. An operator removes 480 VAC power from the valve by opening NG04CKF3 before another operator manually throttles the valve in another step. The control circuit is shown on drawing E-13EM02A. The circuit is not isolated from the control room, nor is it required to be isolated. Removal of power will prevent spurious operation of the valve in the event of a control room fire. A 120 VAC hot short on the control room portion of the circuit will not cause the valve to spuriously operate because 480 VAC power has been removed from the valves' power circuit. DCP 12130 modified the control circuit to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve can be manually throttled when needed. Therefore, valve EMHV8801 B is protected.

EMHV8803B Valve EMHV8803B is opened in OFN RP-01 7 to establish Train B CCP flow to the boron injection tank (BIT). Hand switch EMHS8803B, located at MCC cubicle NG04CKF2, is used to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and open the valve. The circuit is shown on drawing E-1 3EM02B. The circuit was modified in DCP 12175 to address NRC IN 92-18 concerns. The concern in NRC IN 92-18 was that a hot short on the motor operator valve circuit could bypass the valves torque and limit devices and drive the valve to damage in the undesired position. The modification ensures the valve will open when the hand switch is actuated. Based on a review of the drawing, the hand switch will isolate all portions of the control room and open the valve. Power to the valve is from MCC cubicle NG04CKF2. If the hand switch is actuated before power is restored to the MCC, there will be no adverse impact. The valve will move to the open position when power is restored.

Based on the above discussion, valve EMHV8803B is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9916, Re". Page 16 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation EMHV8843 Valve EMHV8843 is closed in OFN RP-017 to prevent flow diversion from charging through the SIS test line which discharges to the RWST or the RHUT. Hand switch EMHS8843 is used to close the valve but does not completely isolate the control room. The circuit is shown on drawing E-1 3EM04A.

The valve is a solenoid operated valve that requires 125 VDC to open. Actuation of hand switch EMHS8843 to the ISO/CLOSE position will open contacts on the positive side of the circuit and de-energize the solenoid. The negative side of the circuit is not isolated. Based on a review of the drawing, a positive hot short in the control room affecting this circuit will not cause the valve to open because the isolation contacts on the hand switch will be open, preventing the re-energization of the solenoid.

Based on the above discussion, valve EMHV8843 is protected.

EMHV8882 Valve EMHV8882 is closed in OFN RP-017 to prevent flow diversion from charging through the SIS test line which discharges to the RWST or the RHUT. Hand switch EMHS8882 is used to close the valve but does not completely isolate the control room. The circuit is shown on drawing E-1 3EM05A.

The valve is a solenoid operated valve that requires 125 VDC to open. Actuation of hand switch EMHS8882 to the ISO/CLOSE position will open a contact on the positive side of the circuit and de-energize the solenoid. The negative side of the circuit is not isolated. Based on a review of the drawing, a positive hot short in the control room affecting this circuit will not cause the valve to open because the isolation contacts on the hand switch will be open, preventing the re-energization of the solenoid.

Based on the above discussion, valve EMHV8882 is protected.

FCHV0312 Valve FCHV0312 is opened using FCHIS0312B at the ASP. This allows steam to flow to the turbine driven auxiliary feedwater pump. Upon arrival at the ASP, Operators place hand switch RPHIS0001 in the ISOLATE position per OFN RP-01 7. This energizes lockout relay 86XRP1 (Dwgs E-1 3RP1 1 and E-1 3RP1 5), isolates the control room portions of the circuit and inserts redundant fuses to ensure the remaining portions of the circuit are energized. The control circuit for FCHV0312 is shown on drawing E-1 3FC23. Based on a review of this drawing, the lockout relay contacts will isolate all portions of the circuit that run to the control room. A fire in the control room will not adversely impact valve FCHV0312 after the isolation switch is operated.

Based on the above discussion, hand switch RPHIS0001 will isolate the control room and insert redundant fuses into the circuit so that hand switch FCHIS0312B will function. Therefore, valve FCHV0312 is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E F9916, Rev. 4 Page 17 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation FCHV0313 Hand switch FCHS0313 is placed in LOCAL position at the ASP to transfer control of FCHV0313 to the ASP and controlling the valve using FCHIK0313B. Drawings J-1 10-00642, J-1 10-00647 and J-1 10-00942 show the loop diagram for valve FCFV0313. Technical data sheets for the Foxboro 200 system are provided in vendor manual J-1 10-00388. These drawings and data sheets were reviewed to determine the circuit configuration and operation of the local hand switch and local valve controller.

When the local hand switch (FCHS0313) is placed in the LOCAL position, relay coils on a relay logic card are energized and the contacts change state. The change of state selects the output from the controller at the ASP and de-selects the control room controller. A fire in the control room could affect the control room controller but any spurious signal would not affect the valve controller. This is because spurious signals or hot shorts originating in the control room are isolated in RP147B by either isolated voltage to current converters, contact output isolators or isolated current to voltage converters. Based on vendor manual J-1 10-00388, these devices will prevent spurious signals or hot shorts originating in the control room from affecting the ability to control FCHV0313 from the ASP.

Based on the above discussion, there is reasonable assurance that the control room is isolated when FCHS0313 is placed in LOCAL position. Therefore, valve FCHV0313 is protected.

GDHS001 1 Hand switch GDHS001 1 isolates the Train B ESW pump room supply fan from the control room, inserts a redundant fuse on the secondary side of the control power transformer, and starts the fan. The circuit is shown on drawing E-K3GD01A. Based on a review of the schematic, the hand switch will isolate all portions of the control room and start the fan. Therefore, the fan will operate during the event.

Exhaust damper GDTZ001 1C opens when supply fan CGDO1 B starts. The exhaust damper circuit is shown on drawing E-K3GDO3. When hand switch GDHS001 1 is placed in the ISO/RUN position, auxiliary relay 3XGD2 is energized, which closes a contact and energizes the contactor relay 42 and starts the fan. Relay 42, when energized, opens a contact in the exhaust damper circuit, which de-energizes the exhaust damper and fails it in the full open position. None of the circuits associated with the exhaust damper are run in the control room. Therefore, the control room fire will not affect the exhaust damper.

Hand switch GDHS001 1A isolates the Train B ESW pump room outside air supply damper (GDTZ001 1A) from the control room and opens the damper. The circuit is shown on drawings E-K3GD04A and J-1 10-00569.

Based on drawing J-1 10-00569, the outside air supply damper closes on increasing current from a 4 - 20 mA Foxboro control circuit. Loss of signal current would fail the damper open. When hand switch GDHS001 1A is placed in the ISO/OPEN position, the signal current is isolated and the damper fully opens due to the decrease in current to 0 mA. The hand switch is located in room 3302 (Train B ESF switchgear room). Therefore, a fire in the control room cannot bypass the switch and cause the damper to close.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1FO915, Rev. 4 Page 18 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation The recirculation damper (GDTZ001 1B) for the Train B ESW pump room is not included in the PFSSD design. A control room fire could cause the damper to fail in the full open, full closed or partially open position due to a smart hot short on the positive polarity of the 4 - 20 mA circuit (Dwg. J-1 10-00569). A restriction plate installed in the recirculation duct will limit airflow in the recirculation line to about 57% per Calculation GD-331.

During normal operation, the outside air intake damper and recirculation damper operate as necessary to maintain the ESW pump room within design limits. In the winter months, most of the air flow is recirculated with minimal outside air makeup. In the summer months, most of the air flow is exhausted with minimal or no recirculation. For PFSSD following a control room fire regardless of time of year, the supply fan is started, the outside air intake damper and exhaust damper are fully opened and the recirculation damper is not controlled and could fail open, closed or somewhere in between. Consideration was not given for ensuring the room temperature is maintained within design limits. CR 00031408 has been written to address this issue.

Based on the above discussion, the Train B ESW pump room supply fan, exhaust damper and outside air supply damper are protected. However, the OFN RP-017 confiquration may not be acceptable for all times durinq the year.

GKHS0103 Class 1E electrical equipment A/C unit SGK05B is started in OFN RP-01 7 to provide cooling to the Train B Class 1E electrical equipment rooms. Hand switch GKHS0103 is placed in the ISO/RUN position to isolate the control room, insert a redundant fuse on the secondary side of the control power transformer, and start the unit. The circuit is shown on drawings E-1 3GK1 3A, M-622.1A-00002 and M-622.1A-00003.

Based on a review of these drawings, hand switch GKHSO103 will isolate all portions of the control room and start the unit.

After the switch is placed in the ISO/RUN position, a fire in the control room will not affect the unit. Therefore, SGK05B is protected.

GLHS0035 Train B electrical penetration room cooler SGL15B is started in OFN RP-017 to ensure adequate cooling to the equipment in the room. The circuit is shown on drawing E-13GL12A. Hand switch GLHS0035 is placed in the ISO/RUN position to isolate the control room and insert a redundant fuse in the control circuit. Then the operator depresses the start pushbutton on the MCC cubicle to start the unit. The unit is powered from MCC cubicle NG02BAF2.

Based on a review of the drawing, hand switch GLHS0035 will isolate all portions of the control room. The pushbutton will energize the 42 relay, close the seal-in contact and start the unit. Therefore, SGL1 5B is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9916, Roy.4 Page 19 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation GMHS0011B Train B diesel generator room supply fan CGM01B is started in OFN RP-017 using hand switch GMHS001 18. The hand switch isolates the control room, inserts a redundant fuse on the secondary side of the control power transformer, and starts the fan. The circuit is shown on drawing E-1 3GMOIA. Based on a review of the drawing, the hand switch will isolate all portions of the control room and start the fan. Power to the fan is from MCC cubicle NG04DBF6. A previous step restores power to the MCC so that when the switch is actuated, the fan will start.

Exhaust damper GMHZ0019 fails open when NK4413 is opened in an earlier step in OFN RP-017. The control circuit for GMHZ0019 is shown on drawing E-13GM04A. Hand switch GMHS0019B is no longer used in OFN RP-017 since disconnecting control power will open the damper. Therefore, exhaust damper GMHZ001 9 is protected.

Train B diesel generator room supply damper actuator GMTZ0011A is opened in OFN RP-017 to ensure a sufficient supply of outside air to the supply fan. The damper fails open on loss of power. OFN RP-017 has an operator remove power from the damper actuator by opening breaker NG04DEF1 11. The circuit is shown on drawing E-1 3GM02. After power is removed, a fire in the control room cannot cause the damper to close.

The recirculation damper (GMTZOO11 B) for the Train B diesel generator room is not included in the PFSSD design. A control room fire could cause the damper to fail in the full open, full closed or partially open position due to a smart hot short on the positive polarity of the 4 -20 mA circuit (Dwg. J-110-00565). A restriction plate installed in the recirculation duct will limit airflow in the recirculation line to about 69% per Calculation GM-336.

During normal operation, the outside air intake damper and recirculation damper operate as necessary to maintain the Train B EDG room within design limits. In the winter months, most of the air flow is recirculated with minimal outside air makeup. In the summer months, most of the air flow is exhausted with minimal or no recirculation. For PFSSD following a control room fire regardless of time of year, the supply fan is started, the outside air intake damper and exhaust damper are fully opened and the recirculation damper is not controlled and could fail open, closed or somewhere inbetween. Consideration was not given for ensuring the room temperature is maintained within design limits. CR 00031408 has been written to address this issue.

Based on the above discussion, the Train B diesel generator building supply fan, supply damper and exhaust damper are protected. Therefore, there will be sufficient combustion air for the diesel engine. However, this configuration may not be adequate for maintaining room temperature at all times during the year.

Design Basis Document for Procedure OFN RP-017 Appendix I E !F9915, Re" ' Page 20 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation GNHS0009A Containment cooler SGN01B is started in OFN RP-017 to maintain the containment temperature within acceptable limits.

Hand switch GNHS0009A is placed in ISO/RUN position to start the cooler from MCC NG02TAF1. The circuit is shown on drawing E-1 3GN02A. Based on a review of the drawing, the hand switch will isolate all portions of the control room, insert a redundant fuse on the secondary side of the control power transformer, and start the cooler. Therefore, a fire in the control room will not affect the cooler after the hand switch is placed in the ISO/RUN position.

Based on the above discussion, containment cooler SGN01 B is protected.

GNHS0017A Containment cooler SGN01 D is started in OFN RP-017 to maintain the containment temperature within acceptable limits.

Hand switch GNHS0017A is placed in ISO/RUN position to start the cooler from MCC NG04TAF1. The circuit is shown on drawing E-1 3GN02A. Based on a review of the drawing, the hand switch will isolate all portions of the control room, insert a redundant fuse on the secondary side of the control power transformer, and start the cooler. Therefore, a fire in the control room will not affect the cooler after the hand switch is placed in the ISO/RUN position.

Based on the above discussion, containment cooler SGN01D is protected.

JEHSO021C Pump PJE01B is the Train B emergency diesel generator fuel oil transfer pump. The pump is started in OFN RP-017 by first placing hand switch JEHS0021C in the ISOLATE position then placing hand switch JEHS0021B in the RUN position. The circuit is shown on drawing E-13JE01A.

Based on a review of the drawing, hand switch JEHS0021C will isolate all portions of the control room from the circuit and insert a redundant fuse in the secondary side of the control power transformer. Hand switch JEHS0021 B will start the pump and maintain it running until the hand switch is placed in the STOP position.

Based on the above discussion, pump PJEO1B is protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E-IF-O4,6,-Re*. Page 21 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation KJHS0101D Procedure OFN RP-017 has operators remove the break glass from switch KJHS0101D to actuate the switch. This step energizes relays ESA and ESB on the Train B diesel generator engine control circuit (Dwg E-13KJ03A). Multiple hot shorts could cause the control power fuses that provide power to both ESA and ESB relays to open, causing a loss of power to the relays. However, the Wolf Creek licensing basis for control room fires assumes only a single spurious signal occurs as a result of the fire. Therefore, it can be assumed that one of the two relays will energize.

With at least one relay (ESA or ESB) energized, the unit parallel relay (UPR) will be de-energized (Dwg E-13NE13).

Therefore, the diesel generator will not be in droop mode and will function properly as PFSSD loads are added.

Also, with one relay (ESA or ESB) energized, relay 90 VEP will be energized which will switch the electronic voltage adjuster to a pre-determined setpoint and the voltage adjuster will ignore signals from the control room auto/manual raise/lower switches. This ensures a fire in the control room will not affect the output voltage of the EDG during the event.

Based on the above discussion, actuation of KJHSO101 D will achieve the desired outcome.

KJHS0109 Hand switch KJHS01 09 is placed in the LOC/MAN position to isolate portions of the Train B diesel generator start/stop circuit from the control room. The switch also transfers control of the Train B diesel generator to the local panel in the diesel generator room.

Based on drawing E-13KJ03A, KJHS0109 will isolate the control room stop portion of the circuit. This will ensure a fire in the control room will not inadvertently cause the diesel engine to shut down.

KJHS0110 Hand switch KJHS01 10 is placed in the ISO position to isolate the Train B diesel generator control circuit from the control room and insert redundant fuses in a portion of the circuit.

DCP 12097 added KJHS01 10 and redundant fuses to ensure power is available to the field flashing circuit. However, CR 30350 identified an issue where certain fuses located in NE106 could blow, preventing field flashing. Steps were added to address this concern in the interim until a permanent modification is implemented.

Based on a review of drawing E-1 3KJ03A, KJHS01 10 will isolate the control room so that the speed relays will be energized when the diesel engine reaches a designated speed. However, as stated above, a portion of the field flashing circuit could be affected such that the field may not flash. This would prevent the generator from generating voltage. CR 30350 is tracking this issue.

Design Basis Document for Procedure OFN RP-017 Appendix I E FOS! 6, Re-.4 Page 22 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NBO102 Breaker NB01 02 is opened to prevent operation of the Train A containment spray pump. The close control power fuse is first removed to ensure the breaker does not close as a result of the control room fire. The circuit is shown on drawing E-1 3EN01.

The fuses that are removed are the two 15 amp fuses that protect the close circuit. The remainder of the circuit stays energized. A hot short from a fire in the control room could re-energize the positive polarity of the close circuit. However, the negative polarity will remain de-energized because the negative side of the close circuit does not run to the control room.

Therefore, a fire in the control room will not cause a hot short that closes the breaker.

Based on the above discussion, breaker NBO102 is protected.

NB0201 through OFN RP-017 opens breakers NB0201 through NB0207, NB0209 and NB0212 to shed most of the major loads from NB02.

NB0207, NB0209 and NB0212 are opened to fail off-site power to NB02 and cause an automatic start of the Train B emergency diesel NB0209 and generator. Some of the loads are added by OFN RP-01 7 after the Train B emergency diesel generator is started. Control NB0212 power to the breakers is de-energized in a previous step. The breakers are opened by pushing the manual trip push button on the breakers. The breakers are closed when needed by pushing the manual close push button. The charging springs allow 1 cycle of operation without control power. The discussion for NK4401 / NB02 shows that the breakers are protected from the effects of a control room fire and will not spuriously operate after control power is removed. Therefore, the breakers are protected.

NB0208, These breakers are closed to energize various load centers and motor control centers. The discussion for NK4401 / NB02 NB10210, shows that the breakers are protected from the effects of a control room fire and will not spuriously operate after control power NB0213 and is removed. Therefore, the breakers will remain closed for the duration of the event.

NB0216 NB0211 NB0211 is closed to energize the NB02 bus from the Train B diesel generator. A previous step removes control power from the breaker, so spurious opening of the breaker caused by the control room fire will not occur. The control circuit for NB0211 is shown on drawing E-1 3NE1 1. The discussion for NK4401 / NB02 shows that the breaker is protected from the effects of a control room fire and will not spuriously operate after control power is removed. Therefore, NB0211 is protected.

NB0215 NB0215 is closed to energize the Train B ESW pump. A previous step removed control power from the breaker, so spurious opening of the breaker caused by the control room fire will not occur. The control circuit for NB0215 is shown on drawing E-K3EF01A. The discussion for NK4401 / NB02 shows that the breaker is protected from the effects of a control room fire and will not spuriously operate after control power is removed. Therefore, NB0215 will remain closed for the duration of the event.

Design Basis Document for Procedure OFN RP-017 Appendix 1 E !FOB!5, Re. Page 23 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NGHIS001 5 Breaker NG0201 is verified to be closed (or manually closed if not) in OFN RP-017 to ensure power is available to required NG0201 loads fed from bus NG02. All PFSSD loads that are powered from NG02 are shown on drawing E-1 F9424B. Not all of these loads are required after a control room fire. The control circuit for NG0201 is shown on drawing E-13NG1 lB. Prior to closing (or verifying closed) NG0201, hand switch NGHIS001 5 is placed in the ISOLATE position to isolate the trip portion of the NG0201 control circuit from the control room. Based on a review of drawing E-1 3NG1 1B, placing NGHIS001 5 in the ISOLATE position will isolate the trip circuit and prevent NG0201 from tripping. If the breaker has tripped prior to placing NGHIS0015 in the ISOLATE position, and the close control power fuse has blown as a result of the fire, the breaker can be re-closed because the close springs will be charged. Therefore, the configuration is acceptable.

NGHIS0016 / Breaker NG0401 is verified to be closed (or manually closed if not) in OFN RP-017 to ensure power is available to required NG0401 loads fed from bus NG04. All PFSSD loads that are powered from NG02 are shown on drawing E-1 F9424D. Not all of these loads are required after a control room fire. The control circuit for NG0401 is shown on drawing E-1 3NG1 1A. Prior to closing (or verifying closed) NG0201, hand switch NGHIS0016 is placed in the ISOLATE position to isolate the trip portion of the NG0201 control circuit from the control room. Based on a review of drawing E-1 3NG1 1A, placing NGHIS0016 in the ISOLATE position will isolate the trip circuit and prevent NG0401 from tripping. If the breaker has tripped prior to placing NGHIS0016 in the ISOLATE position, and the close control power fuse has blown as a result of the fire, the breaker can be re-closed because the close springs will be charged. Therefore, the configuration is acceptable.

NK4119 and The excess letdown isolation valves are failed closed in OFN RP-017 by placing 125 VDC disconnect switches NK4119 and NK4407 NK4407 in the OFF position. This de-energizes power to the valves and fails them closed. The circuit is shown on drawing E-l 3BG48. The power distribution arrangement is shown on drawing E-1 3RL02. The excess letdown valves are considered high/low pressure interfaces so consideration of multiple spurious actuations is required.

Based on a review of drawing E-1 3BG48, loss of power to the circuit will fail the valves closed. In order for both series valves to re-open, it would take four independent proper polarity hot shorts. Opening NK41 19 and NK4407 will de-energize any potential separation group 4, 125 VDC sources in RL001/RL002. Switch PK5117 is opened in an earlier step, which removes 125 VDC from the separation group 5 source to RL001/RL002. Switch PK521 1, which provides separation group 6 125 VDC power to RLI001/RL002, is not opened in OFN RP-017. However, separation group 6 cables cannot come in contact with separation group 4 cables because of the physical separation requirements of IEEE 384, which are discussed in drawing E-11013 (5.8.1.8). Therefore, the excess letdown isolation valves will not spuriously open after power has been removed using NK4119 and NK4407.

Based on the above discussion, the excess letdown isolation valves are protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E !F9916, R" Page 24 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NK4401 Disconnect switch NK4401 is placed in the OFF position to de-energize breaker control power for bus NB02. There are no control room circuits that would prevent operation or cause spurious operation of this switch. Therefore, NK4401 is protected.

Removing breaker control power from the NB02 bus in this manner prevents spurious operation of equipment supplied by NB02. The schematic diagram for each NB02 breaker is identified in the following table.

Breaker Schematic NB0201 E-13BG01A NB0202 E-13EMO1 NB0203 E-13EN01 NB0204 E-13EJ01 NB0205 E-13AL01B NB0206 E-13EGOIC NB0207 E-13EGO1D NB0208 E-13PG12A NB0209 E-13NB14 NB0210 E-13NG10A NB0211 E-13NE1I NB0212 E-13NB15 NB0213 E-13NG1OA NB0214 Spare NB0215 E-K3EF01A NB0216 E-K3NG10A NB0217 Spare A review of each schematic diagram shows that a single hot short from an energized source conductor in the control room will not cause the control circuit on any of the equipment to become re-energized after control power has been removed. Two simultaneous hot shorts would be needed to re-energize the control circuit. Two or more proper polarity hot shorts are not assumed except for high/low pressure interface components. The equipment fed from N802 is not considered high/low pressure interface so the potential to re-energize the control circuit is not credible. Therefore, the NB02 bus is protected.

Design Basis Document for Procedure OFN RP-017 Appendix 1 E IF9916, Rev. Page 25 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NK4411 The steam generator blowdown valves are failed closed in OFN RP-017 by placing 125 VDC disconnect switch NK4411 in the OFF position. The blowdown valves are not high/low pressure interfaces so consideration of multiple spurious actuations is not required. Switch NK4411 will not spuriously actuate in the event of a control room fire. Therefore, switch NK4411 is protected. The circuit for the blowdown valves is shown on drawings E-1 3BM06A through E-1 3BM06D. The power distribution is shown on drawing E-13RL07.

When NK4411 is placed in the OFF position, the blowdown valves will fail closed. It would take multiple proper polarity hot shorts to re-energize the valves, which is not postulated in the case of non-high/low pressure interfaces. Therefore, opening NK4411 will effectively close the blowdown valves and maintain them closed for the duration of the event.

Based on the above discussion, the steam generator blowdown valves are protected.

NK4413 Disconnect switch NK4413 is placed in the OFF position to remove 125 VDC control power from certain components fed from control room panel RL019 and RL020. There are no control room circuits that would prevent operation or cause spurious operation of this switch. Therefore, NK4413 is protected. The power distribution circuit for NK4413 is shown on drawing E-13RL05. The PFSSD equipment supplied by NK4413 includes GMHZ0019, EGHV0070A, EGHV0070B and EGTV0030. Loss of 125 VDC control power to these components will fail the components in their desired position. None of these components are high/low pressure interfaces so multiple proper polarity hot shorts do not need to be considered. The control circuit for these components is shown on drawings E-13GM04A, E-13EG08 and E-13EG16. Based on a review of these drawings it would take two proper polarity hot shorts to re-energize the control circuit for these components to fail them in an undesired position after switch NK4413 is placed in the OFF position. A single hot short will not cause the control circuit to re-energize.

Therefore, these components are protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E I OB!6,ReV.4 Page 26 of 30 Table All OFN RP-017 Credited Component Evaluation Component Evaluation PThe reactor NK4414 and head vent valves are failed closed in OFN RP-017 by placing 125 VDC disconnect switches NK4414 and NK5109 NK5109 in the OFF position. This de-energizes power to the head vent valves and closes the valves. The circuit is shown on drawing E-1 3BB30. The power distribution arrangement is shown on drawing E-1 3RL06. The head vent valves are considered high/low pressure interfaces so consideration of multiple spurious actuations is required.

Based on a review of drawing E-1 3BB30, loss of power to the circuit will fail the valves closed. In order for both series valves to re-open, it would take four independent proper polarity hot shorts. Opening NK4414 and NK5109 as well as NK5108 and NK4419 in earlier steps will de-energize any potential 125 VDC sources in RL021/RL022 and make this failure mode non-credible. Switch PK6117, which provides separation group 5 125 VDC power to RL021/RL022 and switch PK5205, which provides separation group 6 125 VDC power to RL021/RL022, is not opened in OFN RP-017. However, separation group 5 and 6 cables cannot come in contact with separation group 1 and 4 cables because of the physical separation requirements of IEEE 384, which are discussed in drawing E-11013 (5.8.1..B). Therefore, the reactor head vent valves will not spuriously open after power has been removed using NK4414 and NK5109.

Based on the above discussion, the reactor head vent valves are orotected.

rotected..

e.. tv ... le . .

NK4416 Disconnect on ....

switch ab .. v .. ic .. s ...in NK4416 ter is placed...

in. a the

...trh . a..

OFF position to remove 125 VDC control power from SB032D. This action is taken to fail the steam dumps and cooldown valves closed. The steam dumps are not high/low pressure interfaces so multiple proper polarity hot shorts do not need to be considered. The control circuits for the steam dumps and cooldown valves are shown on schematic diagrams E-13AB08, E-13AB09, E-13AB11A, E-13AB111B, E-13AB11C, E-13AB12 and E-13AB31.

Based on a review of these drawings it would take two proper polarity hot shorts to re-energize the control circuit for the steam dumps and cooldown valves to fail them in an undesired position after switch NK4416 is placed in the OFF position. A single hot short will not cause the control circuit to re-energize. Therefore, the steam dumps and cooldown valves are protected.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F-9915, Rev" Page 27 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NK4421 Disconnect switch NK4421 is placed in the OFF position to de-energize pressurizer PORV BBPCV0456A and fail it closed.

There are no control room circuits that would prevent operation or cause spurious operation of this switch. Therefore, NK4421 is protected. De-energizing the PORV circuit in this manner prevents spurious opening of the PORV. The PORV circuit is shown on drawing E-1 3B140. Based on a review of this drawing, a single hot short from an energized source conductor in the control room will not cause the PORV to open. It would take multiple simultaneous negative and positive hot shorts to re-energize the PORV circuit. Two or more proper polarity hot shorts are not assumed except for high/low pressure interface components. The following paragraph discusses the combination of circuit failures necessary to cause the PORVs to open.

Based on a review of drawing E-1 3BB40, in order for the PORV to open, the hot shorts would have to occur in control room panel RL021. A minimum of three 'smart' hot shorts would have to occur to open a PORV. These hot shorts include one external positive hot short, one external negative hot short and a conductor-to-conductor hot short. The external 125 VDC power source would have to be from the same separation group because IEEE-384 and E-1 1013 (5.8.1) do not allow cables of different separation groups to touch. Setroute was reviewed for all the separation group 4 cables with a 125 VDC potential (designated by a letter K after the system designation in the cable scheme) running to panel RL021. Based on this review the only other 125 VDC source that could energize the PORV is NK4414, which is a Separation Group 4 power supply. This switch is opened in Step C2 of OFN RP-01 7.

Based on the above discussion, pressurizer PORV BBPCV0456A will not spuriously open after switches NK4421 and NK4414 are opened.

Design Basis Document for Procedure OFN RP-017 Appendix I E !F9916, R"~. Page 28 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation NK5108 Disconnect switch NK5108 is placed in the OFF position to de-energize pressurizer PORV BBPCV0455A and fail it closed.

There are no control room circuits that would prevent operation or cause spurious operation of this switch. Therefore, NK5108 is protected. De-energizing the PORV circuit in this manner prevents spurious opening of the PORV. The PORV circuit is shown on drawing E-1 3BB40. Based on a review of this drawing, a single hot short from an energized source conductor in the control room will not cause the PORV to open. It would take multiple simultaneous negative and positive hot shorts to re-energize the PORV circuit. Two or more proper polarity hot shorts are not assumed except for high/low pressure interface components. The pressurizer PORVs are not considered high/low pressure interfaces per License Amendment 193. The following paragraph discusses the combination of circuit failures necessary to cause the PORVs to open.

Based on a review of drawing E-1 3BB40, in order for the PORV to open, the hot shorts would have to occur in control room panel RL021. A minimum of three 'smart' hot shorts would have to occur to open a PORV. These hot shorts include one external positive hot short, one external negative hot short and a conductor-to-conductor hot short. The external 125 VDC power source would have to be from the same separation group because IEEE-384 and E-1 1013 (5.8.1) do not allow cables of different separation groups to touch. Setroute was reviewed for all the separation group 1 cables with a 125 VDC potential (designated by a letter K after the system designation in the cable scheme) running to panel RL021. Based on this review the only other 125 VOC source that could energize the PORV is NK5109, which is a Separation Group 1 power supply. This switch is opened in Step C2 of OFN RP-017.

Based on the above discussion, pressurizer PORV BBPCV0455A will not spuriously open after switches NK4421 and NK4414 are opened.

NK51 19 Disconnect switch NK5119 supplies power to main steam and feedwater isolation cabinet SA075A. Opening this disconnect switch removes power from the Train A solenoids on the Main Steam Isolation Valves and Main Feedwater Isolation Valves.

This will fail the valves in the closed position, which is the desired position for PFSSD.

PA01 07, These breakers are manually tripped to stop the RCPs. The control circuit is not isolated from the control room, nor is it PA0108, required to be isolated. Per OFN RP-01 7, operators first trip the breaker, remove control power, then verify that the breaker is PA0204 and still tripped. Control power is removed by opening disconnect switches PK4103 and PK6204. Removal of control power PA0205 ensures control room fire damage will not inadvertently re-start the pump. Verification ensures the pump did not re-start prior to control power being removed. The circuit for all four RCPs is shown on drawing E-13BB01. The procedure adequately addresses tripping the RCP breakers and includes necessary steps to ensure the pumps do not re-start. Therefore, the configuration is acceptable.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9915, R. Page 29 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation PK4103 Disconnect switch PK4103 is placed in the OFF position to remove control power from PA01. For a control room fire, this is required to remove control power from breakers PA0107 and PA0108 for RCPs PBB01A and PBB01 B, respectively, to ensure the RCPs do not re-start after they have been stopped. Other breakers on PA01 are not required for PFSSD following a control room fire. There are no control room circuits that would prevent operation or cause spurious operation of this, switch.

Therefore, PK4103 is protected.

The control circuit for PA0107 and PA0108 is shown on drawing E-13BB01. Based on a review of this drawing it would take two proper polarity hot shorts to re-energize the control circuit for these breakers to start the pumps after switch PK4103 is placed in the OFF position. A single hot short will not cause the control circuit to re-energize. The RCPs are not considered high low pressure interfaces so consideration of two proper polarity hot shorts is not required. Therefore, there is reasonable assurance that the RCPs will not spuriously start after they have been stopped.

Based on the above discussion, removal of control power from PA01 in this manner will prevent spurious operation of RCPs PBB01A and PBB01 B. Therefore, the configuration is acceptable.

PK5117 Disconnect switch PK5117 is opened in OFN RP-017 to fail normal letdown valves BGLCV0459 and BGLCV0460 closed and fail auxiliary pressurizer spray valve BGHV8145 closed. The letdown valve circuit is shown on drawing E-13BG10. The auxiliary spray circuit is shown on drawing E-13BG19. The power distribution arrangement for PK5117 is shown on drawing E-1 3RL02. The letdown isolation valves are considered high/low pressure interfaces so consideration of multiple spurious actuations is required. The spray valve is not considered a high/low pressure interface so multiple proper polarity hot shorts do not need to be considered.

Letdown Valves Based on a review of drawing E-13BG10, loss of power to the circuit will fail the letdown valves closed. In order for both series valves to re-open, it would take four independent proper polarity hot shorts. Opening PK5117 as well as NK4119 and NK4407 in another step will de-energize these potential 125 VDC sources in RL001/RL002. The separation group 6 source of 125 VDC power remains available from switch PK521 1. Based on E-1 1013 (5.8.3) separation groups 5 and 6 cables could be bundled together within the control room cabinets. Therefore, a source of 125 VDC power is available in RL001/RL002 to re-energize and open the valves.

When PK5117 is opened, the two series letdown isolation valves (BGLCV0459 and BGLCV0460) fail closed and all three parallel letdown orifice isolation valves (BGHV8149A, BGHV8149B and BGHV8149C) fail closed. To re-establish a letdown flow path, three valves would need to re-open (both letdown isolation valves and one letdown orifice isolation valve). This would require six independent proper polarity hot shorts (3 negative and 3 positive) which is not credible.

Design Basis Document for Procedure OFN RP-017 Appendix I E 1F9915, R. Page 30 of 30 Table Al OFN RP-017 Credited Component Evaluation Component Evaluation Based on the above discussion, there is reasonable assurance that the letdown isolation valves will not re-open after PK5117 is placed in the OFF position.

Auxiliary Pressurizer Spray Valve Based on a review of drawing E-1 3BG1 9, loss of power to the circuit will fail the spray valve closed. In order for the valve to re-open, it would two independent proper polarity hot shorts which is not postulated for non-high/low pressure interfaces.

Based on the above discussion, there is reasonable assurance that the auxiliary pressurizer spray valve will not re-open after PK5117 is placed in the OFF position.

PK6204 Disconnect switch PK6204 is placed in the OFF position to remove control power from PA02. For a control room fire, this is required to remove control power from breakers PA0204 and PA0205 for RCPs PBB01D and PBB01C, respectively, to ensure the RCPs do not re-start after they have been stopped. Other breakers on PA02 are not required for PFSSD following a control room fire. There are no control room circuits that would prevent operation or cause spurious operation of this switch.

Therefore, PK6204 is protected.

The control circuit for PA0204 and PA0205 is shown on drawing E-1 3BB01. Based on a review of this drawing it would take two proper polarity hot shorts to re-energize the control circuit for these breakers to start the pumps after switch PK6204 is placed in the OFF position. A single hot short will not cause the control circuit to re-energize. The RCPs are not considered high low pressure interfaces so consideration of two proper polarity hot shorts is not required. Therefore, there is reasonable assurance that the RCPs will not spuriously start after they have been stopped.

Based on the above discussion, removal of control power from PA02 in this manner will prevent spurious operation of RCPs PBBO1C and PBB01D. Therefore, the configuration is acceptable.

Design Basis Document for Procedure OFN RP-017 Appendix 2 EE-*F9915, Rev. Page 1 of 34 Appendix 2 Control Room Fire Consequence Evaluation for Motor Operated Valves

Design Basis Document for Procedure OFN RP-017 Appendix 2 E I FOBI 6, Rev. 4 Page 2 of 34 Table A2 documents an evaluation of the impact on post-fire safe shutdown if a fire occurs in the control room and affects motor operated valve circuits. The evaluation was originally performed per a corrective action for CR 041746-02-02. The evaluation has been added to E-1 F9915 to ensure the information is maintained in a controlled document.

Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BGHIS8109 RL001 M-12BG03 (E-6) BGHV8109 Normal Charging Valve could open The NCP is not used for PFSSD. If loss of flow occurs in Pmp Recirc or remain closed. the charging header and this valve fails closed, the NCP could be damaged. This will have no adverse impact on PFSSD since the Train B CCP is available inthe event of a control room fire.

BGHIS01 12C RL001 M-12BG03 (E-7) BGLCV0112C VCT Outlet Valve Valve can fail Valve is closed in OFN RP-017 by placing BGHS01 12C in closed or remain the ISO/CLOSE position. Ifthe valve fails closed before open. lining up the RWST, the operating charging pump will lose suction and will be damaged. If RCP seal cooling flowpath remains available, then the pumps would have 12 gpm on he suction side, which is not sufficient to protect the running pump. Ifthe seal flowpath is affected, which is possible for a fire inthis cabinet, there will be no flow inthe system. Since the NCP is the normally operating pump and is not credited for PFSSD, damage to it will not adversely affect PFSSD. Ifthe valve remains open there is possibility of H2 intrusion into the charging pump suction 3s discussed for other components throughout this table.

NSIS would provide a permissive for the valve to close but he valve would not dose until the RWST to charging valve s open. Therefore, a SIS would not cause a loss of suction to the pump.

BGHIS01 12B RL001 M-12BG03 (F-7) BGLCV0112B CT Outlet Valve Valve could close See discussion for BGHIS01 12C.

or remain open.

BGHIS8112 RL001 M-12BGO1 (E-3) BGHV8112 Seal Water Ret Cont Valve could close See discussion for BGHIS8100.

so Valve or remain open.

BGHIS8100 RL001 M-12BG01 (E-2) BGHV8100 Seal Water Ret Cont Valve could close Ifthe valve closes, seal leakoff flow would be directed to Iso Valve or remain open. the reactor coolant drain tank rather than the seal water heat exchanger. There is no adverse impact on PFSSD if his occurs. RCP seal damage will not occur because FN RP-017 stops the RCPs and isolates seal injection.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E -1 F9 16,o. 4 Page 3 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumen P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BGHIS8104 RLI001 M-12BG05 (B-4) BGHV8104 Immediate Borate to Valve could open The valve can fail in any position with no impact on CCP Suction or remain closed. PFSSD. If the valve fails open with the boric acid transfer pumps running, boron will be added to the RCS, causing a reduction in reactivity. If the valve fails closed, it is in the correct PFSSD position.

BGHIS8110 RL001 M-1 2BG03 (E-3) BGHV81 10 CP A Recirc Valve could close f the A CCP is running at the time of the fire and this valve or remain open. closes with little or no flow in the system, the pump could be damaged. The NCP is normally operating, so this is not concern under normal operating conditions. The B CCP

s credited for a control room fire so damage to the A CCP due to a control room fire will not adversely impact PFSSD.

BNHIS0112D RLI001 1-12BNO1 (B-5) BNLCV0112D :WST to CCP alve could open f the valve opens, there is no adverse impact on PFSSD or remain closed. since it would provide a suction source to the charging pump header. Ifthe valve remains dosed, CCP suction would be available from the VCT unless the VCT outlet valves close. OFN RP-017 lines up the RWST up to the charging header by opening BNLCV01 12E before starting the B CCP. Therefore, failure of this valve to open will not affect PFSSD in the event of a control room fire.

BNHIS0112E RL001 * -12BNO1 (F-3) BNLCV0112E RWST to CCP Valve could open If the valve opens, there is no adverse impact on PFSSD or remain closed. since it would provide a suction source to the charging Dump header. If the valve remains closed, CCP suction would be available from the VCT unless the VCT outlet ialves close. OFN RP-017 lines up the RWST up to the charging header before starting the B CCP. The valve is opened by placing BNHS01 12E in the ISO/OPEN position.

EGHIS8111 RL001 M-12BG03 (E-4) BGHV8111 CCP B Recirc alve could close, f the B CCP is running at the time of the fire and this valve causing a loss of closes with little or no flow in the system, the pump could CCP B mini flow. be damaged. The NCP is normally operating, so this is not a concern under normal operating conditions. Procedure OFN RP-017 opens this valve by placing BGHS81 11A in the ISO/OPEN position.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9915, Rev. 4 Page 4 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BGHIS8106 RL001 M-12BG03 (E-3) BGHV8106 CCP to Regen Hx Valve could open If this valve closes, it is in the desired PFSSD position. If it Iso or close remains open, charging flow would continue until manual valve BG8402B is closed.

BGHIS8105 RL001 M-12BG03 (E-3) BGHV8105 CCP to Regen Hx Valve could open If this valve closes, it is in the desired PFSSD position. If it Iso or close remains open, charging flow would continue until manual valve BG8402B is closed.

BGHS81Q10 RL001 M-12BG03 (E-3) BGHV8110 CCP A Recirc Iso Could cause a Switch is used to reset a safety injection signal. Based on Reset spurious reset or a review of drawing E-13BGI 1B, fire damage to the switch

revent a reset. will not cause the valve to open or close. Furthermore, the valve is not credited for PFSSD following a control room fire so the position of the valve will not affect PFSSD.

BGHS8111 RLOO1 M-12BG03 (E-5) BGHV8111 CP B Recirc Iso ;ould cause a Switch is used to reset a safety injection signal. Based on Reset 5punous reset or a review of drawing E-13BG1 1C, fire damage to the switch Drevent a reset. will not cause the valve to open or dose. Therefore, there s no adverse impact on PFSSD. Procedure OFN RP-017 opens this valve by placing BGHS81 1IA in the ISO/OPEN

)osition. Damage to the switch and associated cables will I__ _ _ot prevent BGHS81 11A from performing this function.

BGHIS8357A RL001 M-12BG03 (C-4) BGHV8357A OCP A to RCP Seals Valve could open None. Seal injection is isolated by closing BGV0101 and or remain closed. BGV0105 in procedure OFN RP-017. With the valve open or closed, there is no adverse impact on PFSSD.

BGHIS8357B RL001 M-12BG03 (B-4) BGHV8357B OCP B to RCP Seals Valve could open None. Seal injection is isolated by closing BGV0101 and or remain closed. BGV0105 in procedure OFN RP-017. With the valve open Fr closed, there is no adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E IF9916, Re". Page 5 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged rBBHIS8157A RL001 M-12BB02 (E-1) BBHV8157A Excess Letdown to Could allow excess Could potentially lose -50 gpm to the PRT if one excess PRT etdown flow to the etdown heat exchanger inlet flowpath (2 valves) also PRT if 2 other open. The excess letdown heat exchanger inlet valves are valves to the lso controlled from RLOO1, so this condition could occur excess letdown but it would require multiple spurious operations. Wolf heat exchanger :reek is not required to consider multiple spurious also open. operations in the event of a control room fire. Furthermore, excess letdown is isolated in OFN RP-017 by opening breakers NK4119 and NK4407 to fail the excess letdown alves dosed. Based on E-1F9915, operators have 37 minutes to mitigate a failed open excess letdown flowpath ssuming 100 gpm loss. OFN RP-017A opens BBHV8157A to re-establish a letdown flowpath for cold shutdown. Valve BBHV8157A has been modified to address IN 92-18 concerns and is therefore available.

BBHIS8157B RL001 M-12BB02 (D-1) BBHV8157B Excess Letdown to Could allow excess Could potentially lose -50 gpm to the PRT if one excess PRT etdown flow to the etdown heat exchanger inlet flowpath (2 valves) also PRT if 2 other )pens. The excess letdown heat exchanger inlet valves ialves to the are also controlled from RLOO1, so this condition could excess letdown ccur but it would require multiple spurious operations.

eat exchanger Wolf Creek is not required to consider multiple spurious lso open. operations in the event of a control room fire. Furthermore, excess letdown is isolated in OFN RP-017 by opening breakers NK4119 and NK4407 to fail the excess letdown ialves closed. Based on E-1F9915, operators have 37 minutes to mitigate a failed open excess letdown flowpath assuming 100 gpm loss. OFN RP-017A opens BBHV8157B to re-establish a letdown flowpath for cold shutdown. Valve BBHV8157B has been modified to address IN 92-18 concerns and is therefore available.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E1 FOB!6, Rw. Page 6 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumenl P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged AEHIS0016 RL005 M-12AE01 (E-5) ,EHV0016 SG Feed Pump A Could cause the The main feedwater pumps are not used for PFSSD. If the FW Disch Valve valve to close or valve doses, PFSSD is achieved using auxiliary feedwater remain open. If the valve stays open, backflow through the pump is revented by check valve AEV0023. Steam generator overfill is prevented by opening switch NK5119 to fail close the MFIVs. Therefore, damage to this switch will not adversely impact PFSSD.

AEHIS0015 RL005 M-12AEO1 (C-5) AEHV0015 SG Feed Pump B Could cause the The main feedwater pumps are not used for PFSSD. If the FW Disch Valve valve to close or /alve closes, PFSSD is achieved using auxiliary feedwater remain open. Ifthe valve stays open, backflow through the pump is Drevented by check valve AEV0022. Steam generator overfill is prevented by opening switch NK5119 to fail close the MFIVs. Therefore, damage to this switch will not adversely impact PFSSD.

ý,LHIS0036A RL005 M-12AL01 (13-4) ALHV0036 CST to TDAFP Valve could This valve is required to be open in OFN RP-017 to Suction spuriously close. provide a suction source from the CST to the TDAFP. The valve is verified open in Step B7 and opened if it is not.

This is a Train A valve so it is not isolated from the control room. Rather, the power is de-energized in Step 5.c to prevent spurious operation. If the valve spuriously closes before opening the breaker, an operator can locally open the valve. The valve was modified in DCP 12170 to address IN 92-18. Therefore, damage to this switch will not adversely impact PFSSD.

ALHIS0032A RL005 M-12AL01 (D-3) ,LHV0032 ESW A to TDAFP Valve could This valve is normally closed and is not used in OFN RP-Suction spuriously open or 017. Train A ESW is not used in OFN RP-017. The valve remain dosed. can fail in any position with no adverse impact on PFSSD.

ALHIS0035A RL005 M-12AL01 (D-3) ,LHV0035 CST to MDAFP A Valve could Valve is normally open to provide a suction source from spuriously dose. he CST to the Train A MDAFP. The Train A MDAFP is not used in OFN RP-017 and therefore this valve can fail closed with no adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E !F9946, Re. Page 7 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged ALHIS0031A RL005 M-12ALO1 (E-3) ALHV0031 -SW to MDAFP A Valve could Valve is normally closed and opens on LSP signal to spuriously open or )rovide a suction source from Train A ESW to the Train A remain closed. MDAFP. The Train A MDAFP is not used in OFN RP-017.

his valve can fail in any position with no adverse impact on PFSSD.

ALHIS0033A RL005 M-12AL01 (C-3) ALHV0033 ESW to TDAFP Valve could This valve is opened in OFN RP-01 7 when aligning the spuriously open or alternate AFW source. The valve is isolated from the remain dosed. control room using RP HIS-2 in Step A-I. If the valve fails open it is possible that ESW would enter the TDAFP suction, which would allow raw water to enter the steam generators. This will not adversely affect PFSSD. If the valve fails dosed, it can be lined up to the TDAFP after it is isolated in Step Al. The valve was modified to address IN 92-18 in DCP 12170. In either case, there is no adverse impact on PFSSD.

LHIS0034A RL005 M-12AL01 (H-4) ALHV0034 CST to MDAFP B Valve could Valve is required to be open to provide the primary source spuriously dose. of AFW from the CST to the Train B MDAFP. The valve is isolated from the control room in Step Al using RP HIS-2 and opened using AL HIS-34B at the ASP. The valve was modified in DCP 12170 to address IN 92-18. Therefore, spurious operation of the valve will not adversely impact PFSSD.

LHIS0030A RL005 M-12AL01 (G-3) LHV0030 ESW to MDAFP B Valve could This valve is opened in OFN RP-017 when aligning the spuriously open or altemate AFW source. The valve is isolated from the remain dosed. ntrol room using RP HIS-2 in Step A-i. Ifthe valve fails

pen it is possible that ESW would enter the MDAFP B suction, which would allow raw water to enter the steam 3enerators. This will not adversely affect PFSSD. Ifthe ialve fails dosed, it can be lined up to the B MDAFP after t is isolated in Step Al. In either case, there is no adverse mpact on PFSSD. The valve was modified in DCP 12170 go address IN 92-18.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, R. Page 8 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged FCHIS0312A RL005 M-12FC02 (G-3) FCHV0312 TDAFP Trip and Could prevent This valve is required in OFN RP-017 to provide steam to Throttle Valve operation of the the TDAFP. The valve is isolated from the control room in valve. Step Al and opened in Step A13. If the valve goes full pen, steam would flow only if either valve ABHV0005 or ABHV0006 and valve FCFV0313 also open. Valve FCFV0313 is normally open with the controller in manual and set to 3850 RPM. Therefore, with the proper valve ineup there could be steam release through the TDAFP.

Excessive steam flow would likely result in FCHV0312 I tripping on high speed.

ALHKO007A RL006 M-12AL01 (F-8) ALHV0007 SG A MD Aux FW B Could prevent flow Damage to this switch could cause a loss of auxiliary Control Valve control from feedwater flow control from the Train B MDAFP to SG A.

MDAFP B to SG A. The Train B MDAFP is used in OFN RP-017 to supply SG D only. SG A is not credited in OFN RP-017 since the dump valve is on Train A. If this valve were to open while running the Train B MDAFP, auxiliary feedwater would flob to SG A but with possibly no steam dump capability the SG would overfill. Manual valve ALVO032 is closed in OFN RP-017 to prevent overfilling SG A.

ALHKO009A RL006 M-12AL01 (E-8) ALHV0009 SG B MD Aux FWA Could prevent flow Damage to this switch could cause a loss of auxiliary Control Valve control from feedwater flow control from the Train A MDAFP to SG B.

MDAFP A to SG B. The Train A MDAFP is not used in OFN RP-017. The pump is secured in OFN RP-017 to prevent overfilling SGs B and C.

ALHKO01 1A RL006 M-12AL01 (C-8) ALHV0011 SG C MD Aux FWA Could prevent flow Damage to this switch could cause a loss of auxiliary Control Valve control from feedwater flow control from the Train A MDAFP to SG C.

MDAFP A to SG C. The Train A MDAFP is not used in OFN RP-017. The pump is secured in OFN RP-017 to prevent overfilling SGs 13Band C.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E-1F9916, Rev. 4 Page 9 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged ALHKO005A RL006 M-12ALO1 (H-8) ALHV0005 SG D MD Aux FW B Could prevent flow Damage to this switch could cause a loss of auxiliary Control Valve 7ontrol from feedwater flow control from the Train B MDAFP to SG D.

MDAFP B to SG D. This valve is credited in OFN RP-017 to ensure a flow path from MDAFP B to SG D. The valve is controlled in Step

45. Prior to Step A5 the valve could either fail open, fail

osed or fail somewhere in-between. There is no adverse mpact on PFSSD prior to controlling the valve. The lesign of the valve would not allow it to be damaged per IN

)2-18 so the valve was not modified to address this ncern. This is because the valve is a positionable MOV using hand controller ALHKO005A. Fire damage to the controller or circuits will not bypass the limit switches at the valve. Also, the thermal overloads for the valve are not.

bypassed, so they would open to protect the valve.

Therefore, the valve cannot be damaged in a manner described in IN 92-18.

OHS-WL025A RL013 M-0024, Sh. 2 WL0014 Low Level Iso VIv :ould prevent The makeup water system is not required for PFSSD.

'H-6) trl Sw 3peration of the Spurious operation of the valve will not adversely impact valve. safe shutdown.

DHS-WL026A RL013 A-0024, Sh. 2 0WL0015 Dewater Iso VIv Ctrl ould prevent The makeup water system is not required for PFSSD.

H-5) Sw operation of the Spurious operation of the valve will not adversely impact I alve. safe shutdown.

OHS-WL028A RL013 -0024, Sh. 2 OWL0017 Dewater Disch Viv ould prevent The makeup water system is not required for PFSSD.

H-3) Ctr Sw peration of the Spurious operation of the valve will not adversely impact

_alve. safe shutdown.

3HS-WL027A RL013 M-0024, Sh. 2 OWL0016 Blowdown Iso Vlv ould prevent The makeup water system is not required for PFSSD.

(D-6) Ctrl Sw peration of the Spurious operation of the valve will not adversely impact I'*UO talI t%'tflA

t -n . - - - - - - ..- - ... --..

_alve.

afe shutdown.

K~LU1 6 M-uu24, ,n. 2 (1--OWL0018 Blowdown Disch Vlv Could prevent The makeup water system is not required for PFSSD.

)HS-WL029AB 3) Ctrl Sw operation of the Spurious operation of the valve will not adversely impact valve. safe shutdown.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F-906, R. Page 10 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room nstrumenl P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BNHIS0003 RL017 M-12BNO1 (C-3) BNHV0003 RWST to Could close or If the valve remains in its normally open position with no Containment Spray remain open. other spurious actuations, there would be no adverse Pump B *mpact on PFSSD. However, if the CS B pump starts and he containment spray isolation valve opens then Train B containment spray would occur and RWST inventory will be depleted until containment spray is stopped. The flow n the containment spray system with one pump operating is approximately 3,000 gpm. Based on calculation XX-E-013, Appendix 1, a maximum of 214,260 gallons of water n be lost from the RWST to maintain sufficient volume to achieve cold shutdown. Therefore, operators have approximately 71 minutes to stop the containment spray pump. The Train B pump is stopped in OFN RP-017 prior to 71 minutes. Therefore, the pump will be stopped within the required time period to prevent unacceptable RWST

__raindown.

ENHIS0007 RL017 M-12EN01 (B-7) ENHV0007 Containment Recirc Could spuriously This valve is not credited for PFSSD. If it spuriously opens Sump to open. Dr remains closed there is no adverse impact on PFSSD.

Containment Spray -heck valve ENVO008 will prevent the RWST from Pump B _lraining to the containment sump if the valve opens.

ENHIS0016 RL017 M-12EN01 (D-4) ENHV0016 Spray Additive Tank -ould open or 'his valve is not credited for PFSSD. If it spuriously opens solation Valve remain closed. r remains closed there is no adverse impact on PFSSD.

ENHIS0012 RL017 M-12EN01 (C-4) ENHV0012 ontainment Spray Could spuriously Ifthis valve opens with no other spurious actuations, there Isolation Valve open. would be no adverse impact on PFSSD. However, if the CS B pump starts then containment spray would occur, taking suction from the RWST. 71 minutes are available to mitigate this condition before the RWST reaches a level below that required for cold shutdown. Operators stop the CS B pump in OFN RP-017 prior to 71 minutes.

Therefore, the pump would be stopped within the required time period to prevent unacceptable RWST draindown.

BNHIS8806B RL017 M-12BNO1 (E-3) BNHV8806B RWST to SI Pumps Could close or f this valve remains in its normally open position, then Suction remain open. there would be no adverse impact on PFSSD. If a purious SIS occurs, there is no adverse impact because e SI pumps will not inject if RCS pressure is above 1565 si. The Sl pumps are not credited for PFSSD so if the

_alve closes, there would be no adverse impact.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E I F991 6, Re". Page 11 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EMHIS8923B RL017 M-12EM01 (D-7) EMHV8923B SI Pump B Suction Could close or If this valve remains in its normally open position, then Isolation Valve remain open. there would be no adverse impact on PFSSD. Ifa spurious SIS occurs, there is no adverse impact because he SI pumps will not inject if RCS pressure is above 1565

)si. Ifthe valve spuriously closes, there is no adverse mpact since the Train B SI pump is not credited for

_FSSD.

EMHIS8924 RL017 M-12EM01 (G-8) EMHV8924 CVCS to SI pump ould close or Ihis normally open valve, along with normally dosed Suction 2emain open. )arallel valves EMHV8807A and EMHV8807B provide an Itemate SI pump suction path from the CVCS suction header. The Sl system is not used for PFSSD. This valve can fail in any position with no adverse impact on PFSSD.

EMHIS8807B RL017 M-12EMO1 (F-7) EMHV8807B CVCS to SI pump 3ould open or f this normally closed valve opens with the SI pumps off, Suction "emain dosed. there is no adverse impact on PFSSD. If the pumps start there will be no flow in the system and RWST inventory will be maintained.

BNHIS8813 RL017 M-12BNO1 (C-7) BNHV8813 SI Return to RWST .*ould close or This normally open valve provides a return flowpath from

emain open. he SI pumps to the RWST. If the valve closes with SI umps running, damage could occur to the pumps if there is no flow in the system. The Sl pumps are not credited for PFSSD so there would be no adverse impact.

BNHIS8813A RL017 -12BNO1 (C-7) BNHV8813 Valve BNHV8813 Could close or This switch is a power lockout for valve BNHV8813 and is Power Lockout remain open. normally in the ISO position, which maintains the valve in the open position. There is no adverse impact on PFSSD if this switch is affected.

EJHIS8804B RL017 M-12EJO1 (B-4) EJHV8804B RHR HX B to Si Could open or The valve is required to remain closed for PFSSD when Pump B remain dosed. operating Train B RHR for cold shutdown. If the valve opens prior to reaching RHR entry conditions there would be no adverse impact on PFSSD. Valve was modified to address IN 92-18 and is closed in OFN RP-017A to support cold shutdown.

EMHIS8814B RL017 M-12EM01 (B-5) EMHV8814B SI Pump B Return to Could close or This normally open valve provides a return flowpath from RWST remain open. the Train B SI pump to the RWST. Ifthe valve closes with Train B SI pump running, damage could occur to the pump if there is no flow in the system. The Train B SI pump is not credited for PFSSD so there would be no adverse impact.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E U9916E, Re". Page 12 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumenl P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EMHIS8821B RL017 M-12EM01 (D-4) EMHV8821B SI Pump B to RCS Could close or The position of this valve (open or closed) has no adverse Cold Leg Injection remain open. impact on PFSSD. If the SI pumps are running, injection will not occur until the RCS pressure drops below 1565

_sig.

EMHIS8802B RL017 -12EMO1 (D-4) EMHV8802B SI Pump B Could open or The position of this valve (open or closed) has no adverse Discharge Valve remain dosed. impact on PFSSD. If the SI pumps are running, injection will not occur until the RCS pressure drops below 1565 psig.

EMHIS8802BA RL017 -12EMOI (D-4) EMHV8802B Valve EMHV8802B Could open or The position of this valve (open or closed) has no adverse Power Lockout remain dosed. *mpact on PFSSD. If the SI pumps are running, injection will not occur until the RCS pressure drops below 1565 psig.

EMHIS8835 RL017 M-12EM01 (C-4) EMHV8835 SI Cold Leg Injection Could close or The position of this valve (open or closed) has no adverse Valve remain open. *mpact on PFSSD. If the SI pumps are running, injection will not occur until the RCS pressure drops below 1565 psig.

EMHIS8835A RL017 M-12EM01 (C-4) EMHV8835 Valve EMHV8835 Could close or The position of this valve (open or closed) has no adverse Power Lockout remain open. impact on PFSSD. If the SI pumps are running, injection will not occur until the RCS pressure drops below 1565 psig.

EMHIS8821A RL017 M-12EMO1 (E-4) EMHV8821A SI Pump A to RCS Could close or The position of this valve (open or closed) has no adverse Cold Leg Injection remain open. impact on PFSSD. If the SI pumps are running, injection Nill not occur until the RCS pressure drops below 1565

- :)sig.

EMHIS8802A RL017 M-12EMO1 (F-4) EMHV8802A SI Pump A Could open or The position of this valve (open or closed) has no adverse Discharge Valve remain dosed. mpact on PFSSD. Ifthe SI pumps are running, injection Nill not occur until the RCS pressure drops below 1565

)sig.

EMHIS8802AA RL017 M-12EMO1 (F-4) EMHV8802A Valve EMHV8802A Could open or The position of this valve (open or closed) has no adverse Power Lockout remain dosed. mpact on PFSSD. If the SI pumps are running, injection Nill not occur until the RCS pressure drops below 1565

)sig.

EMHIS8923A RL017 M-12EM01 (F-7) EMHV8923A SI Pump A Suction Could close or Ifthis valve remains in its normally open position with no Isolation Valve remain open. ther spurious actuations, then there would be no adverse impact on PFSSD. If the valve spuriously closes, there is So adverse impact since the Train A SI pump is not

_redited for PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E irF9816, Rev. I Page 13 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room nstrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EMHIS8814A RL017 M-12EM01 (B-6) EMHV8814A SI Pump A Return to Could close or This normally open valve provides a return flowpath from RWST remain open. the Train A SI pump to the RWST. If the valve closes with Train A SI pump running, damage could occur to the pump f there is no flow in the system. The Train A SI pump is iot credited for PFSSD so there would be no adverse mpact.

ENHIS0006 RL017 M-12EN01 (H-4) ENHV0006 Train A Containment Could spuriously f this valve opens with no other spurious actuations, there Spray Isolation open. vould be no adverse impact on PFSSD. However, if the A Valve ',S pump starts then containment spray would occur, aking suction from the RWST. 71 minutes are available to nitigate this condition before the RWST reaches a level

elow that required for cold shutdown. The CS A pump is 3topped in OFN RP-017 prior to 71 minutes. Therefore,

_he pump will be stopped within the required 71 minutes.

BNHIS0004 RLO17 M-12BNO1 (B-3) BNHVO0O4 PWST to Could close or f the valve remains in its normally open position with no Containment Spray remain open. )ther spurious actuations, there would be no adverse Pump A *mpact on PFSSD. However, if the A CS pump starts and he containment spray isolation valve opens, Train A ntainment spray would occur and RWST inventory will e depleted until containment spray is stopped. The flow in the containment spray system with one pump operating is approximately 3,000 gpm. Based on calculation XX-E-013, Appendix 1, a maximum of 214,260 gallons of water

an be lost from the RWST to maintain sufficient volume to achieve cold shutdown. Therefore, operators have approximately 71 minutes to stop the containment spray pump. The A CS pump is stopped in OFN RP-017 prior to 1 minutes. Therefore, RWST inventory will be maintained.

ENHIS0015 RL017 M-12ENO1 (D-6) ENHVOO15 Spray Additive Tank Could open or This valve is not credited for PFSSD. If it spuriously opens Isolation Valve emain closed. -- o r remains closed there is no adverse impact on PFSSD.

ENHIS0001 RL017 M-12EN01 (G-7) ENHV0001 Containment Recirc -ould spuriously This valve is not credited for PFSSD. If it spuriously opens Sump to )pen. or remains closed there is no adverse impact on PFSSD.

ontainment Spray Check valve ENVO002 will prevent the RWST from Pump A _lraining to the containment sump if the valve opens.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E !FOB! 6, Re". Page 14 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BBHIS8702A RL017 M-12BB01 (F-4) BBPV8702A RCS Hot Leg to None This valve is normally deenergized and is maintained RHR Pump A closed. Damage to the hand switch will have no adverse impact on PFSSD since the valve cannot move from the closed position. Prior to lining up RHR for shutdown

_ooling, the valve is lined up in OFN RP-017A.

EJHIS8701A RL017 M-12EJ01 (G-8) EJHV8701A RCS Hot Leg to None This valve is normally deenergized and is maintained RHR Pump A closed. Damage to the hand switch will have no adverse mpact on PFSSD since the valve cannot move from the losed position. Prior to lining up RHR for shutdown

_ooling, the valve is lined up in OFN RP-017A.

8NHIS8812A RL017 M-12BN01 (B-3) BNHV8812A RWST to RHR alve could close 'fthe valve closes there is no adverse impact on PFSSD.

Pump A Suction or remain open. Ifthe valve remains open and valve EJHV881 1A opens, hen the RWST would drain to the containment sump.

DFN RP-017 closes BNHV8812A to prevent draindown via his path. BNHV8812A has been modified to address IN 2-18 per DCP 12173. Calculation XX-E-013, Appendix 1 has determined there is 28 minutes to mitigate RWST lraindown to the sump if one RWST to sump flowpath fails open. This condition will be mitigated before the RWST

_d _lrops below minimum level needed for cold shutdown.

EJHIS881 1A RL017 M-12EJ01 (F-7) EJHV8811A tint Recirc Sump to Valve could Damage to this switch could cause the valve to open. In RHR A Suction spuriously open. addition, valve BNHV8812A may not automatically close as designed, causing the RWST to drain to the sump. This condition is mitigated in OFN RP-017 by manually closing r L_ BNHV8812A within the required time period of 28 minutes.

The valve was modified to address NRC IN 92-18.

EJHIS0610 RL017 M-12EJ01 (H-6) EJFCV0610 RHR Pump A Valve could close. Damage to this switch has no adverse impact on PFSSD liniflow Valve since the Train A RHR system is not credited for a control room fire. The position of this valve (open or closed) will

_ _ _ave no adverse impact on hot standby.

EJHIS8804A RL017 M-12EJ01 (H-4) EJHV8804A RHR A to CVCS Iso Valve could open Jalve is required to remain closed when operating Train A Valve or remain closed. RHR to prevent flow diversion to the charging header. The 3osition of this valve (open or closed) will have no adverse mpact on hot standby. The Train A RHR system is not Credited for a control room fire so spurious operation of this

_alve will have no adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 EIF-9916, Re. Page 15 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EJHIS8716A RL017 M-12EJ01 (E-3) EJHV8716A RHR Pump A Hot Valve could close Damage to this switch could cause the valve to close or Leg Recirc or remain open. prevent it from dosing. The Train A RHR system is not credited for PFSSD following a control room fire so damage to this switch will have no adverse impact on the ability to achieve cold shutdown. The position of this valve (open or closed) will have no adverse impact on hot standby. OFN RP-017A closes EJHV8840 to prevent hot leg recirculation when lining up RHR for cold shutdown.

EJHIS8809A RL017 M-12EJ01 (G-3) EJHV8809A RHR A to Cold Leg Valve could close The Train A RHR system is not credited for a fire in the Injection Loops 1 or remain open. ntrol room. The position of this valve (open or dosed) and 2. will have no adverse impact on safe shutdown.

EJHIS8809AA RL017 M-12EJO1 (G-3) EJHV8809A Valve EJHV8809A Valve could dose The Train A RHR system is not credited for a fire in the

)ower lockout. or remain open. ntrol room. The position of this valve (open or dosed) will have no adverse impact on safe shutdown.

EMHIS8807A RL017 M-12EM01 (G-7) EMHV8807A CVCS to SI pump Valve could open f this normally dosed valve opens with no other spurious Suction or remain dosed. ctuations, there is no adverse impact on PFSSD. If the umps start there will be no flow in the system and RWST inventory will be maintained.

EJHIS8809B RL017 M-12EJ01 (C-3) EJHV8809B RHR B to Cold Leg Valve could close This valve is credited for a fire in the control room when nj Loops 3 and 4 or remain open. lining up Train B RHR in OFN RP-017A for cold shutdown.

Spurious operation of the valve during hot standby will not impact PFSSD. The valve was modified to address IN 92-18.

EJHIS8809BA RL017 M-12EJ01 (C-3) EJHV8809B RHR B to Cold Leg Valve could close This valve is credited for a fire in the control room when Inj Loops 3 and 4 or remain open. lining up Train B RHR in OFN RP-017A for cold shutdown.

Spurious operation of the valve during hot standby will not

mpact PFSSD. The valve was modified to address IN 92-18.

EJHIS8840 RL017 M-12EJ01 (E-3) EJHV8840 RHR Hot Leg Recirc Valve could open This valve is dosed in OFN RP-017A to prevent hot leg Valve or remain dosed. recirculation. The position of this valve (open or closed) will have no adverse impact on hot standby.

EJHIS8840A RL017 M-12EJ01 (E-3) EJHV8840 RHR Hot Leg Recirc Valve could open This valve is closed in OFN RP-014 to prevent hot leg Valve or remain closed. recirculation. The position of this valve (open or closed) will have no adverse impact on hot standby. The valve was modified to address IN 92-18.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, Re. Page 16 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EJHIS8716B RL017 M-12EJ01 (C-3) EJHV8716B RHR Pump B Hot Valve could close Damage to this switch could cause the valve to close or Leg Recirc or remain open. prevent it from dosing. The position of this valve (open or cosed) will have no adverse impact on hot standby. OFN RP-01 7A doses EJHV8840 to prevent hot leg recirculation when lining up RHR for cold shutdown.

EJHIS0611 RL017 M-12EJ01 (B-6) EJFCV0611 RHR B Miniflow Valve could close. If the valve closes there will be no adverse impact unless valve the Train B RHR pump starts in which case the pump would have no recirc flow. The pump is stopped (or prevented from starting) in OFN RP-017. Valve EJFCV0611 is lined up in OFN RP-017A when placing RHR in service. The valve was modified to address IN 92-18.

EJHIS8701B RL017 M-12EJ01 (C-8) EJHV8701B RCS Hot Leg to None This valve is normally deenergized and is maintained RHR Pump B closed. Damage to the hand switch will have no adverse impact on PFSSD since the valve cannot move from the closed position. Prior to lining up RHR for shutdown ooling, the valve is lined up in OFN RP-017A.

BBHIS8702B RL017 M-12BB01 (H-5) BBPV8702B RCS Hot Leg to None This valve is normally deenergized and is maintained RHR Pump B losed. Damage to the hand switch will have no adverse impact on PFSSD since the valve cannot move from the

losed position. Prior to lining up RHR for shutdown I ooling, the valve is lined up in OFN RP-017A.

BNHIS8812B RL017 M-12BNO1 (D-3) BNHV8812B RWST to RHR B Valve could close Ifthe valve closes there is no adverse impact on PFSSD.

Suction or remain open. Ifthe valve remains open and valve EJHV881 1B opens, hen the RWST would drain to the containment sump.

OFN RP-017 closes BNHV8812B using BNHS8812B.

Calculation XX-E-013, Appendix 1 has determined there is 28 minutes to mitigate RWST draindown to the sump if one RWST to sump flowpath fails open. This condition will be mitigated before the RWST drops below minimum level needed for cold shutdown.

-JHIS881 1B RL017 M-12EJ01 (D-7) EJHV8811B ttmt Recirc Sump to Valve could Damage to this switch could cause the valve to open. In RHR B Suction spuriously open. addition, valve BNHV8812B may not automatically close as designed, causing the RWST to drain to the sump. This condition is mitigated in OFN RP-017 using switch BNHS8812B.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, Rev.-4 Page 17 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged BNHIS8806A RL017 M-12BNO1 (B-5) BNHV8806A RWST to SI Pumps Could close or f this valve remains in its normally open position with no Suction remain open. other spurious actuations, then there would be no adverse mpact on PFSSD. The SI pumps are not credited for PFSSD so if the valve closes, there would also be no adverse impact.

EGHIS0101 RL017 M-12EG02 (G-4) EGHV0101 CCW to RHR HX A Valve could open Ifthe valve opens, there is no adverse impact. If the valve or close closes, CCW flow to the Train A RHR heat exchanger would be prevented. The Train A RHR system is not credited for safe shutdown following a fire in the control room. The valve can fail in any position with no adverse impact on PFSSD.

EGHIS0102 RL017 -12EG02 (C-4) EGHV0102 CCW to RHR HX B Valve could open Ifthe valve opens, there is no adverse impact. Ifthe valve or close closes, CCW flow to the Train B RHR heat exchanger would be prevented. The Train B RHR system is credited for safe shutdown following a fire in the control room. The system is lined up in OFN RP-017A. The valve has been modified to address NRC IN 92-18.

BNHIS8812AA RL017 M-12BNO1 (B-3) BNHV8812A RWST to RHR Valve could close See discussion for BNHIS8812A.

Pump A Suction or remain open.

BNHIS8812BA RL017 M-12BNO1 (D-3) BNHV8812B RWST to RHR B Valve could close See discussion for BNHIS8812B.

Suction or remain open.

EMHIS8803B RL018 M-12EM02 (B-7) EMHV8803B CP B to BIT Valve could remain Valve is required to be open in OFN RP-017. The valve is closed or open. manually opened in OFN RP-017 Step B12. If the valve spuriously opens, it is in the desired position and PFSSD is unaffected. The valve has been modified to address NRC IN 92-18.

EMHIS8803A RL018 M-12EM02 (C-7) EMHV8803A CCP A to BIT Valve could remain Valve is not used in OFN RP-017. If it spuriously opens or closed or open. fails in the closed position there is no impact on PFSSD.

EPHIS8808B RL018 M-12EP01 (F-5) EPHV8808B ,ccum Tank B Could cause the The position of this valve (open or closed) has no impact Outlet Iso Valve valve to close or on PFSSD. The valve is used to control lineup of the remain open. accumulator to the RCS. The accumulator tanks are not used for PFSSD and therefore spurious operation of the

ýalve will not adversely impact PFSSD. During shutdown, the accumulators are prevented from injecting in OFN RP-017A by isolating the outlet valves.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1FOB!6, Re". Page 18 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EPHIS8808A RL018 M-12EP01 (G-5) EPHV8808A Accum Tank A Could cause the The position of this valve (open or closed) has no impact Outlet Iso Valve valve to close or on PFSSD. The valve is used to control lineup of the remain open. accumulator to the RCS. The accumulator tanks are not used for PFSSD and therefore spurious operation of the valve will not adversely impact PFSSD. During shutdown, the accumulators are prevented from injecting in OFN RP-017A by isolating the outlet valves.

EPHIS8808C RL018 M-12EP01 (D-5) EPHV8808C ,ccum Tank C Could cause the The position of this valve (open or closed) has no impact Outlet Iso Valve valve to close or on PFSSD. The valve is used to control lineup of the remain open. accumulator to the RCS. The accumulator tanks are not used for PFSSD and therefore spurious operation of the valve will not adversely impact PFSSD. During shutdown, the accumulators are prevented from injecting in OFN RP-0 17A by isolating the outlet valves.

EPHIS8808D RL018 M-12EP01 (B-5) EPHV8808D Accum Tank D ould cause the The position of this valve (open or dosed) has no impact Outlet Iso Valve valve to close or on PFSSD. The valve is used to control lineup of the remain open. accumulator to the RCS. The accumulator tanks are not used for PFSSD and therefore spurious operation of the valve will not adversely impact PFSSD. During shutdown,

he accumulators are prevented from injecting in OFN RP-17A I by isolating the outlet valves.

EMHIS8801B RL018 M-12EM02 (D-4) EMHV8801 B BIT Discharge Iso Could cause the This valve is required to be open in OFN RP-017 to Valve valve to open or rovide a charging path to the RCS. Step B18 opens the remain dosed alve locally manually. If the valve opens as a result of the ire, it is in the desired PFSSD position. The valve has

__een modified to address NRC IN 92-18.

EMHIS8801A RL018 M-12EM02 (E-4) EMHV8801A BIT Discharge Iso Could cause the his valve is not used in OFN RP-017. Ifthe valve opens Valve valve to open or -s a result of the fire, then a flow path from charging to the remain dosed RCS will be established as required. Ifthe valve fails to open, valve EMHV8801B is opened in Step B18.

Therefore, spurious operation of the valve will not affect PFSSD.

KCHIS0253B RL18 M-12KC02 (B-6) KCHV0253 Fire Protection Could prevent A fire in the control room does not require operation of the Header Outer Ctmt operation of the containment fire suppression system. Damage to this

_so Valve valve switch has no adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1FOB! , Re. Page 19 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence, if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged Valve is normally closed. If the valve opens, valve EGHVOO12 will prevent ESW water from entering the CC"A ESW to CCW Train Could cause the system. If both valves open, the CCW surge tank would fill M-12EGO1 (C-7) EGHV0014 BMakeupvalvetoope olid, however this would not impact the ability of the COW 1B Makeup alve to open. ystem to perform its intended function. If necessary, nanual valve EGVO185 could be closed to isolate the

_akeup.

/alve is normally closed. If the valve opens, valve EGHVOO14 will prevent ESW water from entering the CCVA ESWto CCWTrain Could cause the system. If both valves open, the CCW surge tank would fill EGHIS012 RL019 -12EGO1 (C-8) EGHV012 B Makeup valve to open. solid, however this would not impact the ability of the CCW system to perform its intended function. If necessary,

-nanual valve EGV0185 could be closed to isolate the

_nakeup.

Calves are closed when operating the Train A CCW ystem and opened when operating the Train B CCW Could cause the ystem. Ifthe valves spuriously open, they are in the EGHS0016 RL019 M-12EGO1 (C-7) EGHVO16, CW Train B to/from valves to close or esired PFSSD position for OFN RP-017. If the valves are EGHV0054 Service Loop open. osed, OFN RP-017 opens them using switches EGHS0016A and EGHS0054. The valves were modified

_o address IN 92-18.

alve is normally open and can be in any position for OFN RP-017. This valve, or bypass valve EGHV0126, needs to ould cause the be open for cold shutdown when using the excess letdown EGHIS0071 RL019 M-12EG3 (H-6) EGHV0071 OCW to RCS Iso alve to close or heat exchanger. If the valve fails closed, it will be manually Valve remain open. open in OFN RP-017A. If the valve fails open, the CCW system is protected from a steam bubble by closing EGHV0061 and EGHV0133 in OFN RP-017. Valve was I_ modified to address IN 92-18.

Valve is normally open and can be in any position for OFN RP-017. This valve, or bypass valve EGHV0127, needs to ould tocause the be open for cold shutdown when using the excess letdown EGHIS0058 RL019 MI-12EG03 (H-6) EGHV0058 CCW to RCS Iso valve close or heat exchanger. If the valve fails closed, it will be manually Valve ropen open.

rvemain systemin is OFN RP-017A.

protected from Ifathe valve steam fails open, the CCW bubble by closing EGHV0061 and EGHV0133 in OFN RP-017. Valve was Modified to address IN 92-18.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E IF9916, Re,.

I Page 20 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumeni P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged Valve isnormally open and can be in any position for OFN RP-017. This valve is not required for cold shutdown. If ECW Return from vould Ralve tocause closethe or the If thevalve valve failsdosed, fails it is in the desired PFSSD position.

EGHiS062 L019 V-12EG03 (A-5) -GHV0062 RCS Iso Valve "emain open. steam bubble byopen, theEGHV0061 closing CCW system andisEGHV0133 protected from in OFN RP-017.

Valve is normally open and can be in any position for OFN RP-01 7. This valve, or bypass valve EGHV01 30, needs to be open for cold shutdown when using the excess letdown EGHIS0060 CCW Return from Could cause the heat exchanger. Ifthe valve fails closed, it will be manuall GH RL019 (A-5) EGHV60so R-12EGS3 Valve alve to close or open in OFN RP-017A. Ifthe valve fails open, there is no remain open. adverse impact if CCW continues to flow through the RCP bearing coolers, motor air coolers, excess letdown heat exchanger and RCDT heat exchanger. Valve was modified to address IN 92-18.

Valve is normally open and is required to be dosed in OFN CCW Return from Could cause the RP-017 to prevent a postulated steam bubble from forming RL019 (B-5) EGHV61 C CS Isos-12EGa3 e

Valve valve emaintoopen.

dose or in the CCW piping, potentially causing a water hammer.

The valve is manually closed in OFN RP-017. Valve was modified to address IN 92-18.

alve is normally open and can be in any position for OFN RP-017. This valve, or bypass valve EGHV0131, needs to

)e open for cold shutdown when using the excess letdown Return from Could cause the heat exchanger. If the valve fails closed, it will be manually EGHIS059 9RL019 M-12EG033CCW (1-5) EGHV0059 RCS Iso Valve valve to dose or )pen in OFN RP-017A. If the valve fails open, there is no remain open. dverse impact if CCW continues to flow through the RCP earing coolers, motor air coolers, excess letdown heat

ýxchanger and RCDT heat exchanger. Valve was mnodified to address IN 92-18.

Valve is normally open and can be in any position for PFSSD. If the valve closes, ESW return to the UHS is ESW B to Service ould tocause ralve dosetheor ontrolled byremains EFHV0040 EFHV0038 in OFN isRP-017. Ifthisimpact valve and S(rater emain open. because proper ESWopen, flow there no adverse is ensured. Therefore, spurious I_ I_ _peration of this valve will not affect PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, R"y Page 21 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged Valve is normally throttled and is required to be fully open Could cause the in OFN RP-017. Ifthe valve fails open, it is in the desired EFHIS0038 RL019 M-12EF02 (D-2) EFHV0038 ESW B to UHS valve to close or PFSSD position. If it fails closed, it will be opened in OFN remain open. RP-01 7 using the isolation handswitch at the MCC. Valve has been modified to address IN 92-18.

Could cause the alve is normally open and can be in any position for EFHIS0041 RL019 M-12EF02 (E-2) EFHV0041 ESW A to Service alve to lose or PFSSD. Train A ESW is not credited for PFSSD in OFN Water rRP-017. Therefore, spurious operation of this valve will remain open. ot adversely impact PFSSD.

This valve is normally closed with manual valve EFV0090 throttled to provide the proper flow for SIS or LOSP. If the 0ESW B Return from ould cause the valve opens, flow balance in the ESW system will be EFHIS0060 RL019 M-12EF02 (D-3) EFHV0060 ECW HxRalve B to open or affected. Ifthe valve doses, ESW flow through the CCW Hemain dosed, heat exchanger is ensured via normally throttled manual valve EFV0090. DCP 13898 is being prepared to modify the valve to address IN 92-18.

ould cause the ESt Jalve is required to be open in OFN RP-017 to ensure EFHIS046 RL019 -12EF02 (C-6) EFHV46from Ctmt to ose or roper operation of the containment air coolers. The valve Coolers Air s opened in OFN RP-017 when lining up the containment emain open. colers. Valve has been modified to address IN 92-18.

m cause the ESould alve is required to be open in OFN RP-017 to ensure EFHIS0050 RL019 M-12EF02 (C-6) EFHV5 Ctmt alve to close or proper operation of the containment air coolers. The valve Air Coolers remain open. s opened in OFN RP-017 when lining up the containment eoolers. Valve has been modified to address IN 92-18.

This flowpath is required to be isolated in OFN RP-017 to

)revent flow diversion from ESW to the service water ESW B from Service Could cause the system. Valve EFHV0026, which is installed in series with EFHIS0024 RL019 -12EF01 (E-6) EFHV0024 Water Cross valve to close or his valve, is isolated in OFN RP-017. If EFHV0024 Connect remain open. loses, then it is in the desired PFSSD position. If EFHV0024 remains open, valve EFHV0026 is closed to isolate this flowpath.

Could cause the alve is normally open and is required to be open for OFN EFHIS0052 RL019 M-12EF02 (D-5) EFHV0052 ESW B to CCW Hx alve to dose or RP-017. If the valve spuriously closes, it is opened in OFN RP-017 ddress using B EFHS0052. Valve has been modified to Iemain open. IN 92-18.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1-F991, Rev. 4 Page 22 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumen P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged ould cause the Valve is required to be open in OFN RP-017 to ensure EFHIS0032 RL019 M-12EF02 (C-8) EFHV032 ESW B to Ctmt Air alve to close or :roper operation of the containment air coolers. The valve Coolers remain open *s opened in OFN RP-017 using EFHS0032. Valve has remainopen._ *een modified to address IN 92-18.

ould cause the Valve is required to be open in OFN RP-017 to ensure EFHIS0034 RL019 M-12EF02 (C-7) EFHV0034 ESW B to Ctmt Air aive to aose or Droper operation of the containment air coolers. The valve Coolers open. *emain s opened in OFN RP-017 using EFHS0034. Valve has moeen modified to address IN 92-18.

ESWA from Service ould cause the rrain A ESW is not used in OFN RP-017. Spurious EFHIS0023 RL019 M-12EF01 (F-6) EFHV0023 ater Cross alve to close or peration of this valve will not adversely impact PFSSD.

_onnect remain open.

EFHIS0051 ESW A to CCW Hx 'ould cause the Train A ESW is not credited in OFN RP-017. Spurious RL019 -12EF02 (H-5) EFHV0051 alve to dose or operation will not adversely impact PFSSD.

______________emain open. ______________________

EFHIS031 ESW A to Could cause the Train A ESW is not credited in OFN RP-017. Spurious

-FI001 RL019 MI-12EF02 (G-8) EFHV0031 3ontainmentontanmetAir Ai /alve to close or ale todos or peration will not adversely impact PFSSD.

_oolers remain open.

-SW A to EFHSA033 to -ould uThcause the rain A ESW is not credited in OFN RP-017. Spurious EFHIS0033 ~L019 M-12EF02 (G-7) EFHV0033 ontainment Air 3ooles ialve to dose

,eain pen. or operation will not adversely impact PFSSD.

-_-oolersAemain open. the 5ESWA from Service ould cause the rain A ESW is not used in OFN RP-017. Spurious EFI00 R:L019 MI-12EF01 (F-7) EFHV0025 Water Conaer Cross Cemtondose /alve to close or operation of this valve will not adversely impact PFSSD.

_____________ o~~~nnect remain open. ________________________

Valve is normally open and can be in any position for PFSSD. If the valve closes, ESW return to the UHS is ESW B to Service Water vould alve tocause osetheor controlled byremains EFHV0042 EFHV0038 inthere OFN isRP-017. If this valve and

aeemain open. because proper ESWopen, no adverse flow is ensured. impact Therefore, spurious operation of this valve will not affect PFSSD.

ESW E S0 CCWAHxReturn B from remi Could cause osen. the Train A ESW operation is not of this used valve willinnot OFN RP-017.impact adversely SpuriousPFSSD.

EFHIOO5 -2EF2RL19 (-3)EFHVO59 OW x Bemain open.

ESWA from 'ould cause the rain A ESW is not credited in OFN RP-017. Spurious EFHIS0045 RL019 M-12EF02 (G-6) -FHV045 ontainment Air valve to close or peration will not adversely impact PFSSD.

_oolers remain open.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, R"v Page 23 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged This flowpath is required to be isolated in OFN RP-017 to ESW B from Service Could cause the revent flow diversion from ESW to the service water EFHIS0026 RL019 M-12EF01 (E-7) EFHV0026 Water Cross valve to close or system. The valve is isolated in OFN RP-017 using EFHS0026A. If it spuriously closes, it is in the desired onnect remain open. PFSSD position. Valve has been modified to address IN 92-18.

EFHI50049 RESW A from -ould cause the Train A ESW is not credited in OFN RP-017. Spurious RL019 -12EF02 (G-6) EFHV0049 Containment Air /alve to close or peration will not adversely impact PFSSD.

Coolers "emain open. operationwillnotadverselyimpactPFSS__

HE Uould cause the Train A ESW is not credited in OFN RP-017. Spurious EFHIS0037 FRL019 M-12EF02 (G-3) EFHV0037 ESW A to UHS ialve to close or o eai nwl o d esl m atP S D "emain open. peration will not adversely impact PFSSD.

cause the alve is normally open and can be in any position for Vould (2ESW Eater A to Service oulv toose oe PFSSD. Train A ESW is not credited for PFSSD in OFN "emai ose RP-01 7. Therefore, spurious operation of this valve will nopen. not adversely impact PFSSD.

These valves are open when operating the Train A CCW system. Valve EGHV0015 is manually dosed in OFN RP-

.aould cause the 017 to prevent flow diversion from Train B CCW to Train A EGHS0015 RL019 -12EGO1 (D-6) EGHV0015, CW Train A to/from alves to close or CCW system. Valve EGHV0015 has been modified to EGHV053 Service Loop emain open. address IN 92-18. Valve EGHV0053 is not used in OFN RP-017 because check valve EGV0036 will prevent flow from the train B CCW system to the train A CCW system.

EGHIS0011 RL019 -12EGOI EGHI001 1-1EG0 (F-8) EGHV RL19 (F8) -HV0111 ESW SW too CCW CW Pumpould Pmp alve tocause open the or Train A CCW is not credited in OFN RP-017. Spurious A "emain dosed. operation will not adversely impact PFSSD.

3ould cause the EGHIS0013 RL019 -12EGO1 (F-7) EGHV0013 ESW Aalveto CCW Pump to open or Train A CCW is not credited in OFN RP-017. Spurious A____________ ______remain dosed. peration will not adversely impact PFSSD.

Valve is normally closed and can be in any position for FN RP-017. This valve, or valve EGHV0059, needs to be open for cold shutdown when using the excess letdown CW Retur Ctmt ould tocause the heat exchanger. Ifthe valve fails closed, valve EGHV0059 EGHIS0131 RL'2s (C-5) EGHVv131 o-.12EG03 alve open or is manually opened in OFN RP-017A. If the valve fails remain dosed. open, there is no adverse impact, as CCW would continue to flow through the RCP bearing coolers, motor air coolers, xcess letdown heat exchanger and RCDT heat exchanger.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E irF9916, Roy.-4 Page 24 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged Valve is normally closed and can be in any position for OFN RP-017. This valve, or valve EGHV0058, needs to CCW Supply Ctmt Could cause the be open for cold shutdown when using the excess letdown EGHIS0127 RL020 M-12EG03 (G-4) EGHV0127 Wso Valve valve to open or heat exchanger. Ifthe valve fails closed, valve EGHV0058 remain dosed. ill be manually open in OFN RP-017A. If the valve fails open, the CCW system is protected from a steam bubble by closing EGHV0061 and EGHV0133 in OFN RP-017.

Could prevent

)peration of the Valve is normally closed with this hand switch in the ISO EGHIS0131A RL020 -12EG3 (C-5) EGHV0131 CCW Retum Ctmt )ower lockout position, preventing accidental opening of the valve.

Iso Valve 'eature but will not Damage to this switch alone will not cause the valve to muse the valve to open. PFSSD is assured if this switch is damaged.

)pen.

Valve is normally open and is required to be closed in OFN Eould cause the RP-017 to prevent a postulated steam bubble from forming EGHiS0133 RL020 M-12EG03 (D-5) EGHV0133 CW Re t alve to open or n the CCW piping, potentially causing a water hammer.

semain dosed, The valve is manually dosed in OFN RP-017. Valve has

)een modified to address IN 92-18.

'ould prevent 6alve is normally dosed with this hand switch in the ISO

)peration of the osition, preventing accidental opening of the valve.

EGHIS0133A RL020 -12EG03 (D-5) EGHV0133 soCW Return Ctmt Valve ower lockout

eature Damage to this switch alone will not cause the valve to but will notDaaetthssicalnwllotauehevveo Valveause bthe v o )pen. PFSSD is assured if this switch is damaged. Valve has been modified to address IN 92-18.

open.

f the valve opens, there is no adverse impact on PFSSD.

GSHIS021 RL020 M-12GS01 (G-) GSHV021 Hyd Purge Outer Valve could open Valve GSHV0020 will remain closed or, if GSHV0020 also Itmt Iso Vlv or remain dosed, opens, the Aux Building ESF filters will prevent release of radioactivity. In either case, PFSSD is assured.

Valve is normally closed and can be in any position for OFN RP-017. This valve, or valve EGHV0060, needs to be open for cold shutdown when using the excess letdown R5CW Return Ctmt Could cause the heat exchanger. Ifthe valve fails closed, valve EGHV0060 EGHIS0130 EGL020 3 I-12EGs3 (B-5) EGHV0130 WValve valve to open or is manually opened in OFN RP-017A. Ifthe valve fails remain dosed. pen, there is no adverse impact as CCW continues to ow through the RCP bearing coolers, motor air coolers, xcess letdown heat exchanger and RCDT heat exchanger.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F9916, Roy.4 Page 25 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged Valve is normally closed and can be in any position for

)FN RP-017. This valve, or valve EGHV0071, needs to CCW Supply Ctmt Could cause the be open for cold shutdown when using the excess letdown EGHIS0126 RL020 M-12EG03 (G-5) EGHV0126 CW Sply valve to open or ieat exchanger. Ifthe valve fails closed, valve EGHV0071 semain dosed. Nill be manually open in OFN RP-017A. Ifthe valve fails Dpen, the CCW system is protected from a steam bubble

_y closing EGHV0061 and EGHV0133 in OFN RP-017.

ýould prevent peration of the Valve is normally closed with this hand switch in the ISO EGHIS0130A FRL020 MI-12EG03 (B-5) EGHV0130 (CW Retum Ctmt ower t

lockout u

position, preventing accidental opening of the valve.

so Valve eature but will not Damage to this switch alone will not cause the valve to use the valve to open. PFSSD is assured if this switch is damaged.

Lpen.

Valve is normally closed and can be in any position for ould cause the OFN RP-017. This valve is not required for cold shutdown.

EGHIS0132 RL020 -12EG3 (B-4) EGHV0132 CCW Return Ctmt valv et he If the valve fails dosed, it is in the desired PFSSD position.

so Valve remaintoosed. If the valve fails open, the CCW system is protected from a steam bubble by closing EGHV0061 and EGHV0133 in OFN RP-017.

Could prevent

)peration of the Valve is normally closed with this hand switch in the ISO EGHIS01 32A RL020 M-12EG03 (B-4) EGHV0132 CCW Return Ctmt 3ower lockout position, preventing accidental opening of the valve.

iso Valve 'eature but will not Damage to this switch alone will not cause the valve to muse the valve to )pen. PFSSD is assured if this switch is damaged.

)pen.

if the valve opens, there is no adverse impact on PFSSD.

GSHIS020 RL020 M-12GS01 (G-5) GSHV020 Hyd Purge Inner Valve could open Valve GSHV0021 will remain closed or, if GSHV0021 also Ctmt Iso Viv or remain dosed. opens, the Aux Building ESF filters will prevent release of radioactivity. In either case, PFSSD is assured.

The Post-Accident Sampling System is not used for PFSSD. If the valve opens, CCW will flow to the PASS EGHIS0072 RL020 M-12EG2 (H-2) EGHV072 W Iso to PASS oould prevent coolers only if three other valves also open. If this occurs, perao o there is no adverse impact on PFSSD since the CCW eystem is sized to supply this load concurrent with all PFSSD loads.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E V OSl 6, Re". Page 26 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumen P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged The Post-Accident Sampling System is not used for PFSSD. If the valve opens, CCW will flow to the PASS EGHIS0074 RL020 M-112EG02 (H-1) EGHV0074 CCW Iso to PASS Hou-ld(Aprevent oolers only if three other valves also open. If this occurs, peraton operation o the of here is no adverse thrisn ad e eim impactcto on PFSSD F S since the CCWW sneteC alve. system is sized to supply this load concurrent with all PFSSD loads.

Could prevent operation of the Valve is normally closed with this hand switch in the ISO EGHIS0127A RL2 -12EG03 (G-4) EGHV0127 CCW Supply Ctmt Dower lockout position, preventing accidental opening of the valve.

Iso Valve 'eature but will not Damage to this switch alone will not cause the valve to

ause the valve to open. PFSSD is assured if this switch is damaged.

)pen.

]'he Post-Accident Sampling System is not used for PFSSD. If the valve opens, CCW will flow to the PASS EGHIS073 RL020 -12EG2 (H-2) EGHV073 CoW Iso to PASS prevent ooolers only if three other valves also open. Ifthis occurs, peratn th here is no adverse impact on PFSSD since the CCW aystem is sized to supply this load concurrent with all

_PFSSD loads.

The Post-Accident Sampling System is not used for rPFSSD. Ifthe valve opens, CCW will flow to the PASS EGHIS075 RL020 -12EG2 (H-i) EGHV075 CW Iso to PASS oould prevent coolers only if three other valves also open. Ifthis occurs, peratn th here is no adverse impact on PFSSD since the CCW system is sized to supply this load concurrent with all r__ PFSSD loads.

RL021 Could cause the Spurious opening of the valve will not cause a loss of PRT Drain to Ctmt valve to spuriously nventory in the RCS. The valve is used to drain the BBHIS8037A IM-12BB02 (D-3) BBHV8037A Norm Sump open. contents of the PRT to the sump.

RL021 Could cause the Spurous opening of the valve will not cause a loss of PRT Drain to Ctmt valve to spuriously nventory in the RCS. The valve is used to drain the BBHIS8037B VI-12BB02 (D-3) BBHV8037B Norm Sump open. contents of the PRT to the sump.

RL021 The pressurizer PORVs are closed in OFN RP-017 by disconnecting power to the circuit. This will fail the valves Could prevent closed. Therefore, failure of this valve to close will have no BBHS8000A V_-12BB02 (E-7) BBHV8000A Cold O/P Arm Sw closing the valve. adverse impact on PFSSD.

RL021 The pressurizer PORVs are closed in OFN RP-017 by disconnecting power to the circuit. This will fail the valves ould prevent closed. Therefore, failure of this valve to close will have no BBHS8000B _ _ -12BB02 (F-8) BBHV8000B old O/P Arm Sw ,osing the valve. adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1Fr916, R. Page 27 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumen P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged RL021 RCP thermal barrier cooling is not credited in OFN RP-Could cause 017. The CCW service loop is isolated in OFN RP-017 so spurious operation there will be no flow to the thermal barrier. Spurious BBHIS0013 M-12BB03 (C-3) BBHV0013 CCW from RCP A of the valve. )peration of this valve will have no adverse impact.

RL021 RCP thermal barrier cooling is not credited in OFN RP-Could cause )17. The CCW service loop is isolated in OFN RP-017 so spurious operation here will be no flow to the thermal barrier. Spurious BBHIS0014 MI-12BB03 (C-3) BBHV0014 CW from RCP B of the valve. )peration of this valve will have no adverse impact.

RL021 RCP thermal barrier cooling is not credited in OFN RP-

-ould cause 17. The CCW service loop is isolated in OFN RP-017 so spurious operation here will be no flow to the thermal barrier. Spurious BBHIS0015 M-12BB03 (C-3) BBHV0015 CCW from RCP C 3f the valve. operation of this valve will have no adverse impact.

RL021 RCP thermal barrier cooling is not credited in OFN RP-

'ould cause )17. The CCW service loop is isolated in OFN RP-017 so purious operation here will be no flow to the thermal barrier. Spurious BBHIS0016 -12BB03 (C-3) BBHV0016 .CW from RCP D of the valve. operation of this valve will have no adverse impact.

RL021 eal injection is not required for OFN RP-017. Seal njection is isolated in OFN RP-017 using valves BGV0101 Seal Wtr Supply to Could cause the and BGV0105. Spurious closure of this valve will have no BBHIS8351A M-12BB03 (D-5) BBHV8351A RCP A valve to close. adverse impact on PFSSD.

RL021 Seal injection is not required for OFN RP-017. Seal injection is isolated in OFN RP-017 using valves BGV0101 Seal Wtr Supply to Could cause the and BGV0105. Spurious closure of this valve will have no BBHIS8351B M-12BB03 (D-5) BBHV8351B RCP B valve to close. adverse impact on PFSSD.

RL021 Seal injection is not required for OFN RP-017. Seal injection is isolated in OFN RP-017 using valves BGV0101 Seal Wtr Supply to Could cause the and BGV0105. Spurious closure of this valve will have no BBHIS8351C M-12BB03 (D-5) BBHV8351C RCP C valve to close. adverse impact on PFSSD, RL021 Seal injection is not required for OFN RP-017. Seal njection is isolated in OFN RP-017 using valves BGV0101 Seal Wtr Supply to Could cause the and BGV0105. Spurious closure of this valve will have no BBHIS8351 D M-12BB03 (D-5) BBHV8351D RCP D valve to close. adverse impact on PFSSD.

RL021 The pressurizer PORVs are closed in OFN RP-017 by disconnecting power to the circuit. This will fail the valves ould prevent Posed. Therefore, failure of this valve to close will have no BBHIS8000A M-12BB02 (E-7) BBHV000A Cold O/P Arm Sw losing the valve. adverse impact on PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 1F991, Rev.-4 Page 28 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged RL021 The pressurizer PORVs are closed in OFN RP-017 by disconnecting power to the circuit. This will fail the valves Could prevent cosed. Therefore, failure of this valve to close will have no BBHIS8000B M-12BB02 (F-7) BBHV8000B Cold O/P Arm Sw closing the valve. dverse impact on PFSSD.

RL021 alve controls CCW flow to the Fuel Pool Hx. The fuel Could cause ool cooling system is not required for PFSSD. Spurious Fuel Pool Hx CCW spurious operation peration of the valve will not adversely impact safe ECHIS001 1 M-12ECO1 (H-5) ECHV0011 Disch Iso A of the valve. hutdown.

RL021 alve controls CCW flow to the Fuel Pool Hx. The fuel ould cause ool cooling system is not required for PFSSD. Spurious Fuel Pool Hx CCW purious operation peration of the valve will not adversely impact safe ECHIS0012 _ M-12ECO1 (E-5) ECHV0012 Disch Iso B f the valve. shutdown.

LFHIS0105 RL023 M-12LF03 (C-5) LFHV0105 Control/Aux Bldg ould cause the The auxiliary building drainage system is not relied on for Sump Iso Vlv alve to close or PFSSD. Spurious operation of this valve will not adversely open. impact PFSSD.

LFHIS0106 RL023 M-12LF03 (C-4) LFHV0106 Control/Aux Bldg ould cause the The auxiliary building drainage system is not relied on for Sump Iso VIv jalve to close or PFSSD. Spurious operation of this valve will not adversely open. mpact PFSSD.

AFHIS0113 RL023 M-12AF02 (C-7) AFLVO113C Feed Wtr Htr 4A Iso Could cause the ihe feed water heaters are not required for PFSSD.

Iv /alve to close or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHS0106 RL023 M-12AF02 (E-7) AFLVO106C Feed Wtr Htr 3A Could cause the rhe feed water heaters are not required for PFSSD.

Drain Iso Vlvs talve to close or Spurious operation of the valve will not adversely impact open. safe shutdown.

AFHIS0144 RL023 -12AF02 (C-5) AFLVO144C Feed Wtr Htr 4B Iso ould cause the The feed water heaters are not required for PFSSD.

Iv alve to close or Spurious operation of the valve will not adversely impact open. safe shutdown.

AFHS0136 RL023 M-12AF02 (E-5) AFLVO136C Feed Wtr Htr 3B ould cause the The feed water heaters are not required for PFSSD.

Drain Iso VIvs alve to close or Spurious operation of the valve will not adversely impact

_pen. safe shutdown.

AFHISO173 RL023 M-12AF02 (C-3) AFLVO173C Feed Wtr Htr 4C Iso Could cause the The feed water heaters are not required for PFSSD.

VIv /alve to close or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

FHS0165 L023 M-12AF02 (E-3) AFLVO165C Feed LDrain Wtr Htr 3C Iso VIvs 3ould cause the The feed water heaters are not required for PFSSD.

/alve to close or Spurious operation of the valve will not adversely impact

_ _pen. Safe shutdown.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E !F9916, Roy. 4 Page 29 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumeni P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged AFHS0007 RL023 M-12AF01 (G-8) AFLVO007C Feed Wtr Htr 7A Could cause the The feed water heaters are not required for PFSSD.

AFLVO007D Drain Iso Vlvs valve to dose or Spurious operation of the valve will not adversely impact AFLVO007E open. safe shutdown.

AFHS0012 RL023 M-12AFOI (E-7) AFLVO012C Feed Wtr Htr 6A -ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs ialve to dose or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHS0012 RL023 M-12AF01 (E-7) AFLV0012D MSR C Scavenging Could cause the The feed water heaters are not required for PFSSD.

Steam to HP Htr 6A /alve to close or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHS0012 RL023 M-12AFO1 (E-7) AFLVO012E MSR A Scavenging Could cause the The feed water heaters are not required for PFSSD.

Steam to HP Htr 6A ialve to dose or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHIS0024 RL023 M-12AF01 (D-7) AFLV0O24C Feed Wtr Htr 5A Iso ould cause the The feed water heaters are not required for PFSSD.

VIv ialve to close or Spurious operation of the valve will not adversely impact pen. safe shutdown.

AFHS0058 RL023 M-12AFOI (F-2) AFLVO058C Feed Wtr Htr 7B 3ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs /alve to dose or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

FHS0058 RL023 M-12AFO1 (F-2) AFLV0058D Feed Wtr Htr 7B ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs /alve to dose or Spurous operation of the valve will not adversely impact pen. safe shutdown.

AFHS0058 RL023 M-12AF01 (F-2) AFLVO058E Feed Wtr Htr 78 ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs alve to close or Spurious operation of the valve will not adversely impact

_pen. safe shutdown.

AFHS0044 RL023 M-12AF01 (E-3) AFLV0044C Feed Wtr Htr 68 ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs alve to close or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHS0044 RL023 M-12AF01 (E-3) AFLVO044D Feed Wtr Htr 6B 3ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs /alve to close or Spurious operation of the valve will not adversely impact

)pen. safe shutdown.

AFHS0044 RL023 M-12AF01 (E-3) AFLV0044E Feed Wtr Htr 6B ould cause the The feed water heaters are not required for PFSSD.

Drain Iso Vlvs salve to close or Spurious operation of the valve will not adversely impact

_pen. safe shutdown.

AFHIS0064 RL023 M-12AFO1 (D-3) FLVO064B Feed Wtr Htr 58 iso ould cause the The feed water heaters are not required for PFSSD.

Iv ralve to close or Spurious operation of the valve will not adversely impact Spen. Iafe shutdown.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E !F9916, Re". Page 30 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumeni P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged AFHIS0210 RL023 M-12AF01 (C-3) AFHV0210 Htr Drn Tk Start Up Could cause the The heater drain tank is not required for PFSSD. Spurious Drn to Cond valve to close or operation will not impact safe shutdown.

open.

kDHIS0008 RL023 M-12AD02 (C-3) ADHV0008 Cond Pump A Disch .ould prevent The condensate pumps are not required for PFSSD.

so )peration of the Spurious operation of the valve will not adversely impact valve. safe shutdown.

ADHIS0017 RL023 -12AD02 (C-5) ADHV0017 Cond Pump B Disch Gould prevent The condensate pumps are not required for PFSSD.

Iso operation of the Spurious operation of the valve will not adversely impact

_alve. v_ safe shutdown.

4DHIS0024 RL023 M-12AD02 (C-7) ADHV0024 Cond Pump C Disch ould prevent The condensate pumps are not required for PFSSD.

Iso operation of the Spurious operation of the valve will not adversely impact

_alve. safe shutdown.

kDHIS0028 RL023 M-12AD02 (C-2) ADHV0028 Cond Demin Bypass Could prevent The valve is not required for PFSSD. Spurious operation operation of the of the valve will not adversely impact safe shutdown.

valve.

LFHIS0095 RL023 -12LF09 (F-2) LFFV0095 Cont Sump Iso Vlv :ould cause the The reactor building drainage system is not relied on for ialve to close or PFSSD. Spurious operation of this valve will not adversely

_pen. o_ mpact PFSSD.

FCHIS0004 RL023 M-1 2FC03 (H-3) FCHV0004 SGFP Turb A Above Could cause the The SGFP is not required for PFSSD. Damage to the Seat Drain /alve to close or switch will have no adverse impact on PFSSD.

)pen.

FCHIS0104 RL023 M-12FC04 (H-3) FCHV0104 SGFP Turb B Above Could cause the The SGFP is not required for PFSSD. Damage to the Seat Drain /alve to close or switch will have no adverse impact on PFSSD.

)pen.

FCHIS0007 RL023 M-12FC03 (H-3) FCHV0007 SGFP Turb A Below Could cause the The SGFP is not required for PFSSD. Damage to the Seat Drain talve to close or switch will have no adverse impact on PFSSD.

open.

=CHIS0107 RL023 -12FC04 (H-3) FCHV0107 SGFP Turb B Below ould cause the The SGFP is not required for PFSSD. Damage to the Seat Drain ialve to close or switch will have no adverse impact on PFSSD.

_ _ _pen.

=CHIS0012 RL023 -12FC03 (F-3) FCHV0012 SGFP Turb A Above ould cause the The SGFP is not required for PFSSD. Damage to the Seat Drain - alve to close or switch will have no adverse impact on PFSSD.

___________ _______ _____________ pen.

-CHIS01 12 RL023 -12FC04 (F-3) FCHV0112 - GFP Turb B Above ,ould cause the The SGFP is not required for PFSSD. Damage to the eat Drain alve to close or switch will have no adverse impact on PFSSD.

IS pen.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E FOS! 6Rw. Page 31 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged FCHIS0013 RL023 M-12FC03 (F-3) FCHV0013 SGFP Turb A Below Could cause the The SGFP is not required for PFSSD. Damage to the Seat Drain valve to close or switch will have no adverse impact on PFSSD, open.

FCHIS01 13 RL023 M-12FC04 (F-3) FCHV0113 SGFP Turb B Below Could cause the The SGFP is not required for PFSSD. Damage to the Seat Drain /alve to close or switch will have no adverse impact on PFSSD.

)pen.

FCHIS0071 RL023 M-12FC03 (A-4) FCHV0071 SGFP Turb A Could cause the The SGFP is not required for PFSSD. Damage to the Startup Drain talve to close or switch will have no adverse impact on PFSSD.

_) _pen.

FCHIS0171 RL023 M-12FC04 (A-4) FCHV0171 SGFP Turb B 3ould cause the The SGFP is not required for PFSSD. Damage to the Startup Drain /alve to close or switch will have no adverse impact on PFSSD.

)pen.

ADHIS01 13 RL023 M-12AD01 (F-4) ADHV01 13A, Vacuum Breaker ould cause the The condenser vacuum breaker valves are not required for ADHV0113B, Valves /alve to close or PFSSD. Spurious operation will not adversely impact ADHV0113C, )pen. PFSSD.

ADHV0113D _

KAHIS0030 RL024 M-12KA01 (C-1) KAHV0030 nst Air Supply to H2 Could cause the The H2 control system is not credited for PFSSD. Damage Ctrl System valve to close or- to this switch will not adversely impact safe shutdown.

remain open.

ACHIS0251 RL024 -12AC02 (G-6) ,CHV0251, 2nd Stage Reheater Could cause the The moisture separator reheater is not required for CHV0252, Steam Drains valves to close or PFSSD. Spurious operation of the valves will have no CHV0261, open. adverse impact on safe shutdown.

_CHV0263 ACHIS0189 RL024 I-12AC02 (G-7) CHV0189A, 1st Stage Reheater ;ould cause the The moisture separator reheater is not required for CHV0189B, Steam Supply /alve to close or PFSSD. Spurious operation of the valve will have no CHV0189C, 3pen. adverse impact on safe shutdown.

__CHV0189D ABHIS0032 RL024 M-12AB03 (H-5) BHV0031, 2nd Stage Reheater ',ould cause the Valve is required to be closed if the MSIVs cannot be IBHV0032 Steam Supply valve to close or closed to prevent uncontrolled steam release. OFN RP-pen. 017 closes the MSIVs so spurious operation of this valve vill not adversely impact PFSSD.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E 41FOS 6, Rev. Page 32 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged

&CHIS0131 RL024 M-12AC02 (F-2) ACHV0118, Cold Reheat Line Could cause the The MSR drains are not required for PFSSD. Damage to ACHV0120, Drains valves to close or the switch will have no adverse impact on safe shutdown.

ACHV0121, open.

CHV0122, CHV0123, CHV0124, CHV0125, CHV0126, CHV0144, CHV0145, CHV0152, CHV01 53, ACHV0255 ACHIS0253 RL024 -12AC02 (F-6) CHV0253, 1st Stage Reheater Could cause the The MSR drains are not required for PFSSD. Damage to CHV0254, Steam Drains ialves to close or he switch will have no adverse impact on safe shutdown.

CHV0262, )pen.

_,CHV0264 DHS0055 RL024 12AD02 (G-6) DHV0055, .P Htr 1A to 4A Isol Could cause the The low pressure heaters are not required for PFSSD.

_ CDHV0066

_ _pen. Valves /alves to dose or Damage to the switch will have no adverse impact on safe hutdown.

ADHS0043 ZL024 -12AD02 (G-4) DHV0043, -P Htr 1B to 4B Isol ould cause the he low pressure heaters are not required for PFSSD.

DHV0054 Jalves alves to dose or amage to the switch will have no adverse impact on safe Spen. hutdown.

ADHS0030 RL024 M-12AD02 (G-2) DHV0030, -P Htr IC to 4C Isol ould cause the e low pressure heaters are not required for PFSSD.

DHV0041 Valves alves to close or amage to the switch will have no adverse impact on safe

_pen. shutdown.

ADHIS0042 RL024 V-12AD02 (G-3) ADHV0042 -P Htr Bypass ould cause the he low pressure heaters are not required for PFSSD.

Valves alve to close or amage to the switch will have no adverse impact on safe I pen. shutdown.

AEHIS0017 RL024 -12AE01 (E-5) AEHV0017, HP Htr 5B, 6B and ould cause the he heaters are not required for PFSSD. Spurious AEHV0034 7B Isol Vlvs alves to close or peration of the valves will have no adverse impact on safe open. hutdown.

AEHIS0018 RL024 -12AE01 (E-4) AEHV0018, HP Htr 5A, 6A and ould cause the e heaters are not required for PFSSD. Spurious AEHV0033 7A Isol Vlvs alves to close or peration of the valves will have no adverse impact on safe Spen. shutdown.

A.EHIS0038 RL024 -12AE01 (G-4) AEHV0038 HP Htrs Bypass ould cause the he heaters are not required for PFSSD. Spurious Valves alve to close or peration of the valves will have no adverse impact on saf open. hutdown.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E-11;9916, R"v Page 33 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrument P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged EAHIS0005 RL024 M-12EA02 (G-3) EAHV0005 Serv WMr Return to Could cause the The service water system is not credited for PFSSD. The CW System valve to close or ESW system is the credited service water supply.

open. Spurious operation of this valve will not adversely impact

_safe shutdown.

EAHIS0006 RL024 -12EA02 (H-3) EAHV0006 Serv Wtr Return to Could cause the The service water system is not credited for PFSSD. The CW System ialve to close or ESW system is the credited service water supply.

)pen. Spurious operation of this valve will not adversely impact safe shutdown.

CHIS01 19 RL024 M-1 2AC02 (F-2) ACHV01 19, MSR Shell Drain Jog Could cause the The MSR drains are not required for PFSSD. Damage to CHV0127, ontrol alves to close or he switch will have no adverse impact on safe shutdown.

ACHV0129, pen.

ACHV0148, ACHV0149, ACHV0150, ACHV0151, ACHV0225 ACHIS0072 RL024 M-12AC01 (C-6) ACHV0071, Startup Drain Valve Could cause the The startup drains are not required for PFSSD. Damage to ACHV0072 /alves to close or the switch will have no adverse impact on safe shutdown.

open.

ACHS0181A RL024 M-12AC02 (H-7) ACPV0181A, Reheater Steam -ould cause the The MSR's are not required for PFSSD. Damage to the ACPV0181B, High Load Valves ialves to close or switch will have no adverse impact on safe shutdown.

CPV0181C, open.

_CCPVO181 D I CHIS0134 RL024 M-12AC01 (H-7) ACHV0130, Main Stop and Could cause the ]-he drains are not required for PFSSD. Damage to the

,CHV0134, ontrol Viv Startup valves to close or switch will have no adverse impact on safe shutdown.

,CHV0135, Drains open.

,CHV0136,

,CHV0137, ACHV0256,

,CHV0260, ACHV0261, ACHV0263 ACHS0181B RL024 M-12AC02 (H-7) ACPV0181A Main Steam Supply -ould cause the The MSR's are not required for PFSSD. Damage to the to 2nd Stage alve to close or witch will have no adverse impact on safe shutdown.

_ Reheater pen.

Design Basis Document for Procedure OFN RP-017 Appendix 2 E *F9916, Rev. 4 Page 34 of 34 Table A2 Control Room Fire Consequence Evaluation for Motor Operated Valves Control Room Instrumeni P&ID Drawing Associated Description Consequence if Impact on PFSSD in the Event of a Control Room Fire Instrument Location MOV(s) Damaged The main steam seal system is not required for PFSSD.

Main Steam Seal Valve could fail Steam flow is isolated when the MSIVs are closed.

AHIS001 RL026 M-12CA1 (G-8) AHV0001 Feed Valve open or closed. Therefore, spurious operation of this valve will not adversely impact safe shutdown.

The main steam seal system is not required for PFSSD.

Main Steam Seal Valve could fail Steam flow is isolated when the MSIVs are closed.

Feed Valve open or closed. Therefore, spurious operation of this valve will not

-adversely impact safe shutdown.

The auxiliary steam seal system is not required for PFSSD Aux Steam Seal Valve could fail Steam flow is isolated when the MSIVs are closed.

Feed Valve open or closed. Therefore, spurious operation of this valve will not adversely impact safe shutdown.

The steam seal system is not required for PFSSD. Steam Steam Seal Man Valve could fail flow is isolated when the MSIVs are closed. Therefore, Unloading VIv open or closed. spurious operation of this valve will not adversely impact safe shutdown.

The main steam seal system is not required for PFSSD.

Main Stm Hdr to Stm Valve could fail Steam flow is isolated when the MSIVs are closed.

Seal System open or closed. Therefore, spurious operation of this valve will not adversely impact safe shutdown.

FBHV0080, r aould prevent The auxiliary steam system is not required for PFSSD.

FBPV0017A, Htm Alignment 3peration of the Damage to the switch will not adversely impact safe

_____________FAlignment FBPV0017B valves. 5hutdown.

Jalves are not used for PFSSD. Damage to the switch will BMHV0100, Htrs 5AStm B)dwn and 53 ould cause alves theor to open have no adverse

)lowdown impact is isolated on PFSSD.

in OFN Steam RP-017 by generator opening breaker MMlignment lose. N1K4411.

EHV0102, FWP PAE02 Inlet ould prevent he motor driven feedwater pump is not required for AEHS0103 RL027 M-12AE01 (G-2) EHV0103 and Outlet Iso peration of the PFSSD. Damage to the switch will have no adverse Valves Ialves. mpact on safe shutdown.

v t e Letter Sequence Request
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MONTHYEAR2011-05-24 [Table View]

ET 12-0033, License Amendment Request (LAR) for Deviation from Fire Protection Requirements

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ET 12-0033, License Amendment Request (LAR) for Deviation from Fire Protection Requirements

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