ML031220453

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NRC Special Inspection Report IR 05000458/02-007, Preliminary White Finding
ML031220453
Person / Time
Site: River Bend Entergy icon.png
Issue date: 05/02/2003
From: Howell A
NRC/RGN-IV/DRP
To: Hinnenkamp P
Entergy Operations
References
EA-03-077, IR-02-007
Download: ML031220453 (19)


See also: IR 05000458/2002007

Text

May 2, 2003

EA-03-077

Paul D. Hinnenkamp

Vice President - Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

SUBJECT:

RIVER BEND STATION - NRC SPECIAL INSPECTION REPORT 50-458/02-07

PRELIMINARY WHITE FINDING

Dear Mr. Hinnenkamp:

On February 7, 2003, the NRC issued the subject special inspection report, which discussed a

finding concerning the failure to properly lock open Condensate Prefilter Vessel Bypass Flow

Control Valve CNM-FCV200. This apparent violation resulted in a loss of feedwater flow to the

reactor pressure vessel following a reactor scram on September 18, 2002.

This finding was assessed based on the best available information, including influential

assumptions, using the Significance Determination Process described in NRC Inspection

Manual Chapter 0609 and was preliminarily determined to be a finding with some increased

importance to safety (White), which may require additional NRC inspection. The finding has a

preliminary assessment of low to moderate safety significance because the combination of risk

associated with a loss of feedwater and from external events, such as a fire in conjunction with

a loss of the feedwater system, over a period of approximately 126 days. This caused the

probability of core damage to increase by approximately 1.6 X 10-6/yr. The most significant

transient sequences contributing to the increase in risk were those involving the failure of the

main feedwater system following a reactor trip combined with the random failures of the high

pressure core spray, the reactor core isolation cooling, and the automatic depressurization

systems. The NRC Significance Determination Process Phase 3 risk evaluation is enclosed.

Our preliminary determination was discussed with members of your staff during a telephone call

on April 11, 2003.

This finding was also an apparent violation of Technical Specification 5.4.1 in that

Valve CNM-FCV200 was not properly locked open in accordance with required procedures and

is being considered for escalated enforcement action in accordance with the "General

Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),

NUREG-1600. The current Enforcement Policy is included on the NRCs Web site at

http://www.nrc.gov/what-we-do/regulatory/enforcement.html.

Entergy Operations, Inc.

-2-

Since the NRC has not made a final determination in this matter, no Notice of Violation is being

issued for this inspection finding at this time. In addition, please be advised that the number

and characterization of apparent violations described in the subject inspection report may

change as a result of further NRC review.

Before we make a final decision on this matter, we are providing you an opportunity to:

(1) present your perspectives on the facts and assumptions used by the NRC to arrive at the

proposed finding and its preliminary significance at a Regulatory Conference, or (2) submit your

position on the proposed finding and preliminary significance to the NRC in writing. If you

request a Regulatory Conference, it should be held within 30 days of the receipt of this letter

and we encourage you to submit supporting documentation at least one week prior to the

conference in an effort to make the conference more efficient and effective. If a Regulatory

Conference is held, it will be open for public observation. If you decide to submit only a written

response, such submittal should be sent to the NRC within 30 days of the receipt of this letter.

Please contact David Graves at 817/860-8141 within 10 business days of the date of receipt of

this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we

will continue with our significance determination and enforcement decision and you will be

advised by separate correspondence of the results of our deliberations on this matter.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Arthur T. Howell III, Director

Division of Reactor Projects

Docket: 50-458

License: NPF-47

Enclosure:

SDP Phase 3 Evaluation

cc w/enclosure:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Entergy Operations, Inc.

-3-

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

General Manager

Plant Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Director - Nuclear Safety

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

Mark J. Wetterhahn, Esq.

Winston & Strawn

1401 L Street, N.W.

Washington, DC 20005-3502

Manager - Licensing

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

The Honorable Richard P. Ieyoub

Attorney General

Department of Justice

State of Louisiana

P.O. Box 94005

Baton Rouge, Louisiana 70804-9005

H. Anne Plettinger

3456 Villa Rose Drive

Baton Rouge, Louisiana 70806

Entergy Operations, Inc.

-4-

President

West Feliciana Parish Police Jury

P.O. Box 1921

St. Francisville, Louisiana 70775

Michael E. Henry, State Liaison Officer

Department of Environmental Quality

P.O. Box 82135

Baton Rouge, Louisiana 70884-2135

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, Texas 78701-3326

Entergy Operations, Inc.

-5-

Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (PJA)

Branch Chief, DRP/B (DNG)

Senior Project Engineer, DRP/B (RAK1)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

D. P. Loveless (DPL)

G. F. Sanborn, D:ACES (GFS)

K. D. Smith, RC (KDS1)

F. J. Congel, OE (FJC)

OE:EA File (RidsOeMailCenter)

ADAMS:  Yes

 No Initials: __dng____

 Publicly Available

 Non-Publicly Available

 Sensitive

 Non-Sensitive

R:\\_RB\\2003\\RBS Choice Letter.wpd

RIV:C:DRP/B

SRA/DRS

D:ACES

NRR/DIPM

D:DRP

DNGraves

DPLoveless

GFSanborn

LADudes

ATHowell III

/RA/

/RA/

GMVasquez for E - DNGraves

/RA/

5/1/03

5/1/03

5/1/03

4/28 /03

5/2/03

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

ENCLOSURE

Preliminary Significance Determination

A.

Brief Description of Issue

In May 2002, a full-flow condensate filter bypass valve was improperly manipulated such

that, if a large feedwater transient occurred, such as one that would occur following a

reactor scram, the valve could fail closed, and the feedwater and condensate systems

would be lost as a source of makeup water to the reactor vessel.

On September 18, 2002, following a reactor scram, the valve failed closed, resulting in

the loss of feedwater and condensate systems. Additionally, the reactor water cleanup

system, which returns water to the reactor via the feedwater system, continued to inject

hot water into the feedwater system and backwards into the condensate system through

open recirculation valves. The control rod drive hydraulic pumps, which take suction

from the condensate system, began cavitating (which lasted for approximately

70 minutes) as a result of the hot reactor water being introduced into the pump suction.

The cavitation of the operating pump was not detected by the control room operators.

Main feedwater is the normal source of water supply to the reactor, and CRD hydraulics

provides an additional source of makeup that is utilized when necessary. Both systems

have risk significance.

The event is described in significant detail in NRC Inspection Report 50-458/2002-07.

B.

Statement of the Performance Deficiency

Performance Deficiency: The licensee installed a plant modification, in a temporary

condition, without providing sufficiently detailed operating procedures and/or operator

training.

Supporting Information: On May 15, 2002, operators failed to properly lock Condensate

Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 in the open position as

required by SOP-0007, Revision 21, Condensate System. As a result, following a

reactor scram, normal system flow oscillations caused the valve to close. The closure of

Valve CNM-FCV200 resulted in a loss of all power conversion system flow.

Bypass Valve CNM-FCV200 was installed during the licensees Spring maintenance

outage as part of a modification to provide full-flow condensate filtration. The segment

of line in which the valve was installed carries 100 percent of the condensate flow

without redundancy. The modification was left in an incomplete condition. Normal

operations of the system were permitted, provided the bypass valve was locked in the

open position, and the bifurcating lines to the filters were isolated. This configuration

should have left the system operating as if in a premodified condition. The configuration

of the valve was not reassessed until after the September 18 reactor scram.

-2-

The air operator for Valve CNM-FCV200 was not connected to a controller, nor to an air

source. Therefore, the valve had to be mechanically restrained in the open position.

Craftsmen left the valve in the open position with the handwheel disengaged; plant

procedures had been revised to require that the valve be locked in the open position.

However, this valve operator type was new to River Bend, and plant operators were not

familiar with the operation of the valve. Operators, therefore, locked the handwheel, but

did not engage the manual operator.

In summary, the following actions resulted in condensate and feedwater being

unavailable to respond following an accident:



Valve CNM-FCV200 was installed in a section of condensate pipe that handled

full system flow without redundancy.



The full-flow filtration system installation was not completed prior to normal plant

operation.



The motive force (instrument air) and controller for Valve CNM-FCV200 were not

installed.



The design of Valve CNM-FCV200 was new to plant operators and they had not

received training on the operation of the valve.



Craftsmen left Valve CNM-FCV200 in the open position with the manual

mechanism not engaged. Operators later locked the handwheel in the open

position but did not engage the manual mechanism. This left the valve in a

condition that packing and actuator piston friction were the only things keeping

the valve open.



Normal feedwater flow oscillations, following a reactor trip, resulted in the valve

closing and being held closed with system differential pressure. This resulted in

a loss of all condensate flow.



Upon loss of all condensate flow, the feedwater pumps tripped on loss of suction.

C.

Significance Determination Basis



Reactor Inspection for IE, MS, B cornerstones

1.

Phase 1 screening logic, results, and assumptions

In accordance with Inspection Manual Chapter 0612, Appendix B, Issue

Disposition Screening, the inspectors determined that the finding was more than

minor because the issue was associated with the configuration control of

operating equipment alignment. The failure to properly lock open

Valve CNM-FCV200 resulted in the loss of condensate and feedwater flow to the

reactor vessel. Therefore, this performance deficiency affected the mitigating

-3-

systems cornerstone objective to ensure the availability, reliability, and capability

of systems that respond to initiating events to prevent undesirable

consequences.

In accordance with Inspection Manual Chapter 0609, Appendix A, Significance

Determination of Reactor Inspection Findings for At-Power Situations, the

inspectors determined that this issue affected high pressure primary injection

systems, involved mitigating systems, did not affect fire protection defense-in-

depth, and did not affect the safety of a shutdown reactor. Therefore, the

mitigating systems column was followed. The following questions were

answered:

Is the finding a design qualification deficiency confirmed not to result in loss of

function per GL 91-18? No.

Does the finding represent an actual loss of safety function of a system? Yes,

the main feedwater system.

Therefore, Phase 1 directed that a Phase 2 estimation be completed.

2.

Phase 2 Risk Estimation

In accordance with Inspection Manual Chapter 0609, Appendix A, the inspectors

conducted a Phase 2 estimation using the Risk-Informed Inspection Notebook

for River Bend Station, Unit 1, Revision 1. The dominant affected accident

sequences are provided in Table 1. The inspectors assumed that the plant

conversion system and control rod drive hydraulics were unavailable to respond

to accidents.

The Phase 2 estimation resulted in an estimated White finding. The

performance deficiency existed for significantly less than the 365 days assumed

in the notebook and licensee analysts stated that the Phase 2 worksheets were

overly conservative for analyzing a loss of control rod drive hydraulics.

Therefore, the analyst determined that the finding should be evaluated using the

Phase 3 process.

3.

Phase 3 Analysis

Internal Initiating Events:

The following techniques were used in this evaluation.

a.

The analyst quantified the internal risk using the INEEL Standardized

Plant Analysis Risk Model for River Bend Station, Revision 3i. Rather

than attempt to model the loss of short-term availability of the control rod

drive hydraulics system, the analyst quantified the model with a loss of

condensate and feedwater. The model was then quantified with the

-4-

control rod drive system also unavailable. The resulting quantification

indicated an increase over the baseline core damage frequency between

4.0 x 10-6 and 6.4 x 10-6 over a 126-day exposure.

b.

The licensee developed a model for analyzing the internal risk associated

with the performance deficiency using a modified version of their

Revision 3 PRA model. The licensee revised the model by setting the

frequency of a loss of all feedwater initiating event to the frequency of a

normal trip. Additionally, the model was changed to indicate a loss of

short-term cooling from the control rod drive system, while providing for

long-term recovery of the control rod drive system following the cavitation

event, provided that high pressure core spray (HPCS) and reactor core

isolation cooling (RCIC) had been available.

The analyst reviewed the licensees modified model in detail during a site

visit on January 9, 2003. Several errors in modeling and/or imprecise

assumptions were detected and changed during this visit. Based on this

review, the analyst concluded that the revised model was adequate for

evaluating the performance deficiency and that the assumptions used by

the licensee were reasonable. Therefore, the analyst determined that this

result was the best estimate of the internal risk associated with the failure

to ensure that Valve CNM-FCV200 remained in the open position during

power operations.

The resulting increase over the baseline core damage frequency was

7.7 x 10-7 over a 125-day period.

NOTE: The licensee used 125 days in their analysis, while the analyst

used 126 days. The actual time from entering Mode 2 following the

maintenance outage and the September 18 reactor scram was 126 days,

5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The analyst determined by hand calculation that the difference

of 1 day exposure time does not impact the results of the evaluation.

c.

The following influential assumptions were made:



Valve CNM-FCV200, if not fixed in the open position, would have

failed shut during any at-power initiating event resulting in, or that

should have resulted in, a scram.



This condition existed prior to plant restart on May 15, 2002, until

the reactor trip on September 18, 2002.



Operators were not familiar with the valve type and had not been

trained on the design of the valve. Therefore, it is assumed that

any operator could have made a similar error in locking the valve

in position.

-5-



The forces holding the valve open (the packing resistance and the

actuator friction) would not have changed appreciably in 4 months.

Therefore, the exposure time for this condition was 126 days.



Valve CNM-FCV200 failing closed results in the loss of all

condensate and feedwater flow to the reactor pressure vessel.



No recovery credit should be given for the feedwater or

condensate systems. Because the full-flow filtration system

modification was incomplete, no indication of the

Valve CNM-FCV200 position was available in the main control

room. Additionally, plant operators visually inspecting the

condensate system for indications of system abnormalities would

have observed a valve in the locked open position. It should be

noted as additional supporting evidence that the operators did not

determine the cause of system failure during their response to the

event on September 18, 2002.



The control rod drive hydraulic system would not be functional for

the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of a transient because, during the event, the

pump cavitated for a significant period of time (approximately

70 minutes) while provided high temperature suction water. The

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> corresponds to the long-term cooling function of the

system, given that another system has provided cooling water to

the reactor until that time.

Reactor water cleanup flowing backwards through the feedwater

and condensate systems, combined with extraction steam heating

of the isolated systems until the turbine tripped, resulted in

excessive control rod drive suction temperatures.

Prior to the installation of Valve CNM-FCV200, a loss of

condensate to the feedwater pump suction would have resulted in

the long-cycle recirculation pathway remaining closed. However,

because Valve CNM-FCV200 went closed, this bypassed normal

system logic and the recirculation path opened when condensate

system flow was lost. Therefore, reactor water cleanup system

flow would have continued to pump forward to the reactor through

the feedwater injection lines.

There are the following two possible event progressions:

(1)

All flow, with the exception of control rod drive system flow,

is lost early in the event.

-6-

In this case, reactor vessel level would decrease rapidly

and the reactor water cleanup system would automatically

isolate on a low level signal.

In this scenario, reactor water cleanup would not cause

high temperatures in the control rod drive system suction.

However, in this case, control rod drive hydraulics would

not provide sufficient flow to the core. These sequences

are already accounted for in the licensees baseline model,

and would not affect the change in core damage

frequency.

(2)

Feedwater provides flow to the vessel for a short period of

time, as occurred on September 18, and either the HPCS

or RCIC systems are available for a short period of time.

In this case, the reactor water cleanup system would

remain in service and respond as observed on

September 18. In accordance with the emergency

operating procedures, control room operators would

maximize CRD flow. Maximizing flow requires starting a

second pump and increasing both pumps flow rates.

These sequences would result in cavitation of the pumps

and a loss of control rod drive system flow in the short term

(less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). This loss of short-term control rod

drive flow results in a change from the baseline risk and

was modeled in the licensees revised PRA.

The following calculations were performed and the results of all model

runs are documented in Table 3:



The analyst used the SPAR model to quantify the internal change

in risk for a loss of feedwater; a loss of condensate and feedwater;

and a loss of condensate, feedwater, and control rod drive

hydraulics. The latter is the closest to actual circumstances, while

the other runs provide indication of the sensitivity for lesser

system failures.

The SPAR model provides a basic event designating the

probability that all the pumps in a system will fail to run within the

same mission time. This basic event represents the common

cause failure rate for the pumps. For each of the three systems,

the analyst set this common cause failure rate to 1.0 using a

logical TRUE house event. The model was then quantified.

-7-



The analyst requested that the licensee use their model of record

to analyze the internal risk associated with a loss of all main

feedwater and the control rod drive system. Designated as

Licensees R3.0" in Table 3, this result provided a validation of

the SPAR model and indicated the upper bound for internal risk as

quantified by the licensees model. Finally, this result shows the

sensitivity of the results to the modeling of long-term recovery of

the control rod drive system. The dominant accident sequences

for this analysis are provided in Table 2.

External Initiating Events:

The analyst used the following methods for determining the change in risk from

external events. The change in risk from a loss of feedwater during a fire was

determined to be between 8.2 x 10-7 and 2.1 x 10-6 for the 126-day period. The

methods used are documented below:

Fire:

a.

The analyst used the River Bend IPEEE to estimate the change in risk

resulting from external events. Although the feedwater system is not

considered a safe shutdown system in the licensees IPEEE, feedwater

was used to screen out 18 fire areas that had been previously modeled

as greater than 1 x 10-6 /yr CDF.

The licensee reanalyzed each of these fire areas by using the developed

fire scenario and quantifying their internal PRA model with fire damaged

equipment taken out of service. Without crediting feedwater, each of

these scenarios resulted in a core damage frequency of less than

1 x 10-6/yr CDF. These would have screened out in the IPEEE; however,

the numbers indicated that feedwater was important to these scenarios.

At the analysts request, the licensee requantified each of the fire

scenarios giving credit for feedwater at its nominal failure rate. The

analyst determined that this represented the baseline fire risk for the

18 areas. As documented in Table 4, the inspector subtracted this

baseline from the licensees analyzed risk without crediting feedwater.

The change in risk upon a loss of feedwater for these 18 fire areas was

calculated to be 8.16 x 10-7 for the 126-day period.

2.36 x 10

-6/yr * (126/365)yrs exposure = 8.2 x 10

-7

b.

In the second method, the analyst assumed, qualitatively, that feedwater

was as important to external events as it is to internal events. The CDF

was divided by the licensees baseline CDF to quantify the importance.

This importance was then multiplied by the licensees external events

baseline to provide a quantitative result.

-8-

1.035 x 10-5 (case) - 8.110 x 10-6 (baseline) = 2.24 x 10-6

2.24 x 10-6 ÷ 8.110 x 10-6 = 27.6%

2.25 x 10-5 /yr (external baseline) * .276 * [125/365]yrs

= 2.1 x 10-6 CDF

c.

Finally, the analyst noted that this analysis only included 18 fire areas.

Many other fire areas in the plant would normally be mitigated using the

condensate and feedwater systems. However, the licensee does not have

these areas modeled or assessed. Therefore, qualitatively, it can be

assumed that the risk calculated in paragraph a. represents the lower

bound.

Seismic, Winds, Floods, and Other External Events:

The licensee does not model these events in their PRA or IPEEE. However, the

analyst noted that River Bend Station was susceptible to these external events,

particularly high winds and flooding. Additionally, being a versatile system,

feedwater should be available to provide core cooling in all accident scenarios

except secondary line breaks and a loss of offsite power. The most probable

external event scenarios would also result in a loss of offsite power. In these

events, feedwater would not have been available regardless of the performance

deficiency. Therefore, these other external events were determined, qualitatively,

to impact the change in risk for this finding, but were not assumed to increase the

overall risk by greater than one order of magnitude.

Quantitative Bounds:

To determine the range of possible outcomes, the analyst added the highest

result from the internal review and the highest result from the external review.

The lower bound of the range was the licensees revised internal risk result,

assuming that a negligible result in external events approaches zero

quantitatively. These bounding valves are documented in Table 3.

Sensitivity of Results:

While the results of this evaluation are definitely sensitive to the first four

assumptions documented in Section C.3.c, they are based on observed physical

conditions during the September 18, 2002 event. Also, they are conservative in

that they result in the higher risk significance, and the licensee does not dispute

them. Therefore, a sensitivity analysis was not performed on these assumptions.

-9-

Case 1:

The licensees assumption that control rod drive hydraulics would be available for

long-term cooling is a best estimate assumption. However, should the operators

have maximized CRD flow in accordance with emergency operating procedures

while the suction temperature was above 300F, there would have been a high

likelihood of permanent pump damage. Therefore, the SPAR and licensees

models were quantified with control rod drive inoperable for short- and long-term

cooling. The licensees model is sensitive to this assumption in that the 1 x 10-6

threshold is crossed if CRD flow is not available.

Case 2:

Several methods were used to qualitatively assess the risk from external events

caused by the performance deficiency. The two methods used by the analyst

indicated values near that of the internal events model results. However,

assuming that the fire risk associated with a loss of feedwater is zero clearly has

an impact on the analysis. The analyst believes that the licensees approach is

invalid.

Results and Preliminary Color:

The calculated CDF analysis results, including both internal and external

assessments, fall in a range of 7.7 x 10-7 to 8.4 x 10-6. The analysts best

estimate judgment was 1.6 x 10-6. This used the licensees revised model results

combined with the qualitative estimate of the external risk using the licensees

IPEEE fire areas and an analysis quantified with the licensees internal events

PRA model. Therefore, the preliminary analysis indicates that the finding is of low

to moderate risk significance (White).

-10-

Table 1

Phase 2 Dominant Accident Sequences

Initiating Event

Sequence

Contribution

Transients (Reactor Trip)

TRANS-PCS-RCIC-CHR-LICRD

9

TRANS-PCS-RCIC-HPCS-DEP

7

Loss of Reactor Plant

Component Cooling Water

TCCP-PCS-RCIC-CHR

9

TCCP-PCS-RCIC-HPCS-DEP

9

Loss of 120 Vdc Emergency

Division I

TDCI-PCS-CHR

6

TDCI-PCS-HPCS-LPI

8

TDCI-PCS-HPCS-DEP

8

Loss of 120 Vdc Emergency

Division II

TDCII-PCS-CHR-LDEP

8

TDCII-PCS-RCIC-CHR

7

-11-

Table 2

Phase 3 Dominant Accident Sequences

Model

Initiating Event

Sequence

Contribution

SPAR 3i

Transients

(Reactor Trip)

HPCS, SRV, OPR-LPI

2.3 x 10-6

HPCS, ADS, RCIC

8.8 x 10-7

Loss of Vital Medium

Voltage Bus

Div II Vital DC

5.8 x 10-7

Loss of Offsite Power

RCIC, SSW-CF, NOREC-1H

2.1 x 10-7

Licensees

Revised

Transients

(Loss of Feedwater)

ADS, HPCS, RCIC

3.1 x 10-7

Loss of Normal Service

Water

SSW, NORECOVERY

2.3 x 10-7

-12-

Table 3

Analysis Results

Model Used

Assumptions

Exposure

CDF

SPAR

Feedwater Inoperable

126

3.9 x 10-6

Feedwater/Condensate

126

4.0 x 10-6

Feedwater/Condensate/Contr

ol Rod Drive

126

6.4 x 10-6

Licensees R3.0

Feedwater/Control Rod Drive

125

3.9 x 10-6

Licensees Revised*

Feedwater Initiating Event

Loss of Short-Term CRD

125

7.7 x 10-7

External IPEEE*

Feedwater Importance to 18

Named Fire Areas

126

8.2 x 10-7

External Qualitative

Feedwater Importance the

same in external events as

internal

126

2.1 x 10-6

Licensees External

Feedwater not important

125

0

Total CDF

(External + Internal)

Highest

126

8.4 x 10-6

Total CDF

(External + Internal)

Lowest

125

7.7 x 10-7

Total CDF

(External + Internal)

Analysts Best Estimate

126

1.6 x 10-6

  • The designated quantities were used in determining the analysts best estimate.

-13-

Table 4

External Events (Internal Fire)

Fire Area

Fire Affected Components

Case

(Feedwater

Failed)

Baseline

(Feedwater

at Nominal)

CDF/year

AB-2/Z-1

HPCS pump and MOVs

5.64E-08

4.64E-11

5.65E-08

C13A

A Standby, Normal Service Water

3.55E-10

1.55E-11

3.70E-10

C13B

B Standby, Normal Service Water

3.55E-10

1.55E-11

3.70E-10

C18

Div I DC, Normal Service Water

4.92E-07

3.80E-09

4.96E-07

C19

Div II DC, Normal Service Water

4.74E-07

3.56E-09

4.78E-07

C20

Div III AC, HPCS Battery

9.77E-09

1.34E-10

9.91E-09

C21

Div III AC, Div III DC

7.53E-09

1.12E-10

7.64E-09

C22

Div III AC, HPCS

2.33E-08

1.38E-10

2.34E-08

C23

B Battery Charger, Inverter

1.04E-08

1.02E-09

1.14E-08

C26

A Battery Charger, Inverter

1.40E-08

1.04E-09

1.50E-08

DG1

Div II AC, D/G, 4160 Switchgear,

Normal Service Water

1.61E-07

1.61E-09

1.63E-07

DG2

Div III AC, HPCS, Normal Service

Water

2.39E-09

4.64E-11

2.44E-09

DG3

Div I AC, 4160 Switchgear, HPCS,

LPCS, RHR A, RCIC, Normal

Service Water

3.90E-07

4.51E-09

3.94E-07

DG-5/Z-1

Div III AC, DC, D/G

3.51E-07

2.80E-09

3.54E-07

DG-5/Z-2

Div III AC, DC, D/G

2.83E-07

2.18E-09

2.86E-07

PH-01/Z-1

A Standby Service Water

2.24E-08

2.47E-08

4.71E-08

PH-01/Z-2

A Standby Service Water

1.92E-09

6.80E-10

2.60E-09

PH-02/Z-1

B Standby Service Water

7.40E-09

4.28E-09

1.17E-08

PH-02/Z-2

B Standby Service Water

3.17E-09

1.93E-09

5.09E-09

TOTAL

2.36E-06