ML110550323

Response to Request for Additional Information Regarding License Amendment Request to Revise the Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis

ML110550323
Person / Time
Site:	Palo Verde
Issue date:	02/11/2011
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06321-DCM/DFS, TAC ME4596, TAC ME4597, TAC ME4598
Download: ML110550323 (63)

Text

10 CFR 50.90 AA subsidiaryof Pinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-06321 -DCM/DFS February 11,2011 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Response to Request for Additional Information Regarding License Amendment Request to Revise the Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis (TAC NOS. ME4596, ME4597, and ME4598)

By letter no. 102-06244, dated August 27, 2010 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML102510161), Arizona Public Service Company (APS), submitted a request to revise the methodology in the feedwater line break with loss of offsite power and single failure event (FWLB/LOP/SF) analysis summarized in the Palo Verde Nuclear Generating Station (PVNGS) Updated Final Safety Analysis Report (UFSAR). The enclosures to this letter contain the responses to the NRC request for additional information, dated December 21, 2010 (ADAMS Accession No. ML103500510).

No commitments are being made to the NRC by this letter. Should you need further information regarding this response, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.

I declare under penalty of perjury that the foregoing is true and correct.

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Sincerely, DCM/RAS/DFS/gat A member of the STARS (Strategic Teaming and Resource Sharing) Alliance ca away comanc e Pea D a o canyon ýa o verde San Onofre South exas 0 wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding License Amendment Request to Revise the Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis Page 2

Enclosures:

1. Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise the Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis (FWLB/LOP/SF)

2. Palo Verde Time Critical Action Program cc: E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Senior Project Manager L. K. Gibson NRC NRR Project Manager M. A. Brown NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

T. Morales Arizona Radiation Regulatory Agency (ARRA)

Enclosure 1 Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise the Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis (FWLB/LOP/SF)

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLBILOPISF Analysis

==

Introduction:==

By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. MLI102510161) (Reference 1), Arizona Public Service Company (APS) submitted a license amendment request (LAR) to revise the methodology in the feedwater line break with loss of offsite power and single failure event (FWLB/LOP/SF) analysis summarized in the Palo Verde Nuclear Generating Station (PVNGS) Updated Final Safety Analysis Report (UFSAR). The LAR would change the credited operator action time from 30 minutes to 20 minutes.

By letter dated December 21, 2010 (ADAMS Accession No. ML103500510) (Reference 2), the NRC requested additional information. The NRC requested information and corresponding APS responses are provided as follows:

NRC Request 1:

The LAR states that the current PVNGS emergency operating procedures (EOPs) contain explicit directions to the operators to ensure that the plant is placed in a stable, safe condition following an FWLB event. Opening of the atmospheric dump valve (ADV) that is connected to the unaffected steam generator (SG) is in the EOPs for standard post trip actions (40EP-9EO01), excess steam demand (40EP-9EO05), loss of all feedwater (40EP-9EO06), and LOP/loss of forced circulation events (40EP-9EO07).

Please identify the FWLB EOP that directs the opening of this ADV as one of the variable methods.

APS Response:

PVNGS does not have a separate Emergency Operating Procedure (EOP) solely for responding to a Feedwater Line Break (FWLB) event. However, the EOP that directs the mitigation of a FWLB event is procedure 40EP-9EO05, "Excess Steam Demand."

The PVNGS EOP procedures are identified by the use of the designation (EP) in the procedure number.

Following a reactor trip, operators would initially enter procedure 40EP-9EO01, "Standard Post Trip Actions," which instructs operators to utilize ADVs to maintain the RCS heat removal safety function. Procedure 40EP-9EO01 then directs operators, based on the symptoms, to proceed to procedure 40EP-9EO05, "Excess Steam Demand," and identify the most affected steam generator. Procedure 40EP-9EO05 also instructs the operators to utilize ADVs to maintain RCS temperature by feeding and steaming of the intact steam generators (SGs).

NRC Request 2:

The licensee stated that the assumed operator action of opening an ADV is not mandated by the EOPs. Ifan operating crew decides to use alternate methods, please explain ifthe time duration of the various action sequences will be less than or equal to opening an ADV.

1

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLBILOP/SF Analysis APS Response:

This statement was noting that opening an ADV is not mandated by EOPs as the only action in response to a trip and/or FWLB to maintain the RCS heat removal. Depending on plant system availability, operators could also choose to maintain RCS heat removal using the steam by-pass control system (SBCS) if off-site power is available. For the limiting FWLB scenario, the analysis considers a loss of off-site power and does not credit SBCS when evaluating the event. Hence, the only operator action and its timing credited in this event is opening of an ADV.

NRC Request 3:

The table in Insert C of the Enclosure to the letter dated August 27, 2010, indicates that the operators will open the ADV, at 20 minutes, to 10 percent of its full throat area.

From this, it is inferred that the intent is to maintain the shell-side water level by relieving only the steam that is generated by boiling off the incoming 650 gallons per minute of auxiliary feedwater flow.

a. Please show that there is a stable SG water level indication available to the operators;

b. Please discuss the effect, if any, upon SG water level indication caused by the FWLB-induced hostile environment in the region of the intact SG;

c. Please confirm that the ADV flow area can be controlled to 10; and

d. Please confirm that, given the LOP, there is a reliable and sufficient source of power to move the ADV, continually, to maintain the desired relief rate, for at least 10 minutes.

APS Response:

The utilization of ADVs after a FWLB event is primarily to establish and maintain RCS heat removal, rather than maintaining SG level. Prior to the operators taking action to cool down the plant, the secondary system peak pressure would be limited by the MSSVs, which have sufficient capacity to relieve steam generated by RCS heat sources. However, plant operators would take action to cool down and depressurize the plant by feeding the steam generators with auxiliary feedwater (AFW) flow and by releasing steam through the ADVs rather than rely on the MSSVs.

During the event, the PVNGS design automatically isolates flow to the SGs on a main steam isolation signal (MSIS), and the engineered safety features actuation system (ESFAS) will divert the full AFW flow to the intact SG (i. e., AFW delta-p lockout).

These automatic actuations will control RCS heat removal and maintain inventory in the intact SG until the operators take manual control of feeding and steaming of the intact SG.

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Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis

a. As described in UFSAR, Section 7.5, "Safety-Related Display Instrumentation,"

there are four wide-range and four narrow-range level indicators per SG in the control room which are available to the operators to monitor conditions in the steam generating systems and safety-related process systems, throughout all operating conditions of the plant. These instruments ensure that the operators have adequate information available for performing actions important to plant safety during and following design basis events. Although the FWLB analysis demonstrates that the SG level is expected to exceed the narrow-range level instrumentation, the four safety-grade wide-range level indicators for the intact SG will still be available to the operators.

b. The level and differential pressure transmitters and associated equipment that supply input signals to the control room are environmentally qualified (EQ) for the post-FWLB induced hostile environment in the region of the intact SG.

Therefore, the FWLB-induced hostile environment will not adversely affect the SG level indication.

c. To maintain heat removal and/or control RCS cooldown, after an ADV is open, the operators can manipulate the throat area (i. e., the cross-sectional flow area) of the ADV(s) from the control room from zero to 100 percent by adjusting a thumbwheel. However, for the FWLB analysis the ADV throat area is conservatively assumed to be left at 10 percent throughout the transient.

d. As described in UFSAR Section 8.3.2, each of the two (Class 1 E) batteries has sufficient capacity to independently supply the required station loads during the FWLB event for at least two hours. In addition, as described in UFSAR Section 3.2.2.4, the backup safety grade nitrogen accumulator for each ADV is sized to ensure continued ADV operation for at least 13.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Therefore, reliable and sufficient sources of power or motive force are available to ensure the capability of the ADVs to maintain any desired relief rate far beyond 10 minutes.

NRC Request 4:

Please provide an evaluation to show that the 20 minutes includes the time allowed for indication and recognition, diagnosis, operator action, and system response. Include all documentation required by American National Standards Institute/American Nuclear Society (ANSI/ANS)-58.8, 'Time Response Design Criteria for Nuclear Safety Related Operator Actions' (i. e., the required operator action and the manipulations that make up the action, the indications that prompt the operator(s), and the feedback by which the operator verifies that the action succeeded or failed). Also, please provide event analysis chart(s) showing the assumed time interval estimates including time to indication, time to diagnose, time to complete the action, process time until success or failure would be recognized, and safety margin assumed, if any. Information provided in response to this request for additional information should provide evidence that PVNGS operators are highly likely (95 percent confidence or higher) to be capable of performing 3

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis the required actions in the expected control room environment within the assumed time constraints of the analysis.

APS Response:

The response to this request has been combined with the response to NRC Request 5 below.

NRC Request 5:

Please provide any available empirical human performance data, such as timed simulator training scenarios, that are available to derive time intervals that could justify crediting the 20-minute assumption. The NRC staff notes that, in accordance with ANSI/ANS-58.8, such empirical evaluation should be designed to yield results at a 95 percent confidence level. Information provided in response to this request for additional information should provide evidence that PVNGS operators are highly likely (95 percent confidence or higher) to be capable of performing the required actions in the expected control room environment within the assumed time constraints of the analysis.

APS Response for 4 and 5:

The timing of the operator action was selected based on the guidance and requirements of ANSI/ANS-58.8-1984. The data and selected Time Test Values (TTV), demonstrating a 95 percent confidence level, that are provided and justified in the ANSI/ANS-58.8-1984, Appendix, were also used. The application of criteria defined in Section 6 of the standard was utilized to evaluate the nuclear safety related automatic and manual actions, and associated time. Figure 1 (page 8) illustrates the discrete time points for the event. The following sections provide the details of the evaluation performed for FWLB, and describe the discrete time points provided in Figure 1:

Time for completion of nuclear safety function (t,):

ANSI/ANS-58.8-1984 defines this time as: "The time at which a particular nuclear safety function must be completed to prevent a design requirement from being exceeded."

This time is determined by examining the event behavior, in accordance with ANSI/ANS-58.8-1984, Section 5.2. The PVNGS analysis examined the event behavior with the most adverse initial and transient conditions and determined that the nuclear safety function (i. e., PSV operability for RCS pressure relief) would be exceeded at 26.5 minutes after the event initiation.

Time Test 1 and Time Marqin Complete (tm_):

ANSI/ANS-58.8-1984, Section 5.0, provides the required time tests and their allowed values. Time Test I is used to establish a conservative time interval that shall elapse from the design basis event indication until operator action may be considered for operator initiation of nuclear safety function, (t, - te). During this interval, all nuclear safety functions shall have been initiated by automatic protection systems. This interval is lengthened as the severity of the operator stress increases, the event frequency decreases, and the familiarity of the operator decreases. This allows a longer time 4

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis margin for an operator to recover from initial stress, evaluate the event, and identify required actions. This time interval also allows the operator to ensure the correct accomplishment of the nuclear safety functions by monitoring for proper automatic initiation of the functions and initiating backups to those automatic functions. Per Table 1 of ANSI/ANS-58.8-1984, the minimum test margin, (tin - te), is 20 minutes for a FWLB+LOP+SF which is a Limiting Fault Event for PVNGS.

At PVNGS, immediately following a FWLB, operators would receive various alarms indicating the event. The time from the initiation of the event to the alarm indications does vary depending on the input to the alarm. An almost immediate (within one second) alarm from the trip of feedwater pumps on overspeed is expected to be the earliest indication. In addition, for a FWLB inside containment, within approximately two to three seconds, alarms would initiate on containment conditions (e.g., high containment humidity, and containment temperature, which would alert the operators of the energy release to the containment). There are other control room alarms and indications, such as high containment pressure pre-trip alarm, pressurizer narrow (and wide) range high pressure alarms, etc., available to the operators in less than 10 seconds from the initiation of the FWLB event. Based on guidance in ANSI/ANS-58.8-1984, the earliest time at which operator action can be considered in the design evaluation (tin) is 20 minutes plus the one second alarm delay from event initiation to the feedwater pump trip alarm. In the PVNGS analysis, the earliest time plus the alarm delay was modeled to be 20 minutes.

Verification of Automatic Functions:

ANSI/ANS-58.8-1984, Section 6.4 requires that all nuclear safety functions that must be initiated during the Time Test 1 time margin to prevent exceeding design requirements shall be initiated by automatic protection systems. The following automatic initiations of the nuclear safety functions and other automatic actuations occur within approximately 30-40 seconds following the FWLB:

• Reactor trip on high pressurizer pressure (HPPT) and low steam generator level (LSGLT). It should be noted that the analytical methodology requires HPPT to coincide with LSGLT which is delayed until the affected SG is depleted of its liquid inventory.

" Engineered safety function actuation system (ESFAS) actuations: Safety injection actuation signal (SIAS), containment isolation actuation signal (CIAS),

main steam isolation signal (MSIS), and containment spray actuation signal (CSAS)

• Pressurizer safety valve (PSV) opening

• ESFAS actuation: Auxiliary feedwater actuation signal (AFAS)

• Turbine trip (followed by a loss of offsite power)

• Main steam safety valve (MSSV) opening

• Main steam isolation valve (MSIV) closure 5

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis AFW delta-p lockout The listed automatic protection systems are credited to initiate and prevent exceeding design requirements during Time Test 1.

Time Test 2 and Latest Time to Initiate Operator Action (t):

Time Test 2 is applied to each action under consideration for operator initiation, and represents a conservative time delay that shall be allowed for completion of each nuclear safety-related operator action. Time Test 2 includes a fixed and a variable time portion. The fixed portion of operator action time delay includes time for the receipt of a very simple indication or alarm that identifies the initial need for the action and additional time to verify the need for the action and identify the action required. The variable portion is added to allow a minimum of one minute for each discrete manipulation (e.g.

opening a valve).

As stated in ANSI/ANS-58.8-1984, Section 5.4, the fixed portion of the time delay may be eliminated if the Time Test 2 starts immediately after the time margin of Time Test 1 since it can be assumed that the operator actions are already identified. Included in the 20-minute Time Test 1 value is allowance for the operators to ensure the correct accomplishment of nuclear-safety functions by monitoring the automatic initiation of associated functions. This Time Test 1 value also considers the time it takes for operators to initiate manual backup actions to maintain heat removal, if required. The manual action taken in the analysis is primarily based on initiating back up to an automatic function which the operators are trained on specifically. The operators are trained to prevent cycling of MSSVs by opening ADVs, regardless of the initiating event.

The automatic opening and cycling of MSSVs are determined from the event behavior to be around 38 seconds after FWLB event initiation which would indicate the need for ADV opening very early in the Time Test 1 interval. Additionally, opening of ADVs do not require any action outside the control room. Thus, the fixed portion of the Time Test 2 is eliminated in the PVNGS evaluation. Based on ANSI/ANS-58.8-1984, the variable portion of Time Test 2 is taken as one minute which meets a 95 percent confidence level for a single manipulation, i.e., time for opening the ADV, and time for verification that the action controlled by the manipulation has been initiated (e.g., monitoring decreasing SG pressure).

For the ADVs, the single manipulation includes energizing the permissive solenoids and dialing the thumbwheel above the permissive switch used for the initial valve position.

That single manipulation is performed in the control room, on the same board. Although the equipment response and process time would be implicit in this Time Test 2 value since the verification of ADV opening is required, an additional one minute is conservatively added to bound the 10-20 seconds of equipment and process time.

Thus, the operator action time delay (tc-t1 ) of one minute and the equipment time delay (ti-tc) of one minute are used in the PVNGS evaluation. Based on the ANSI/ANS-58.8-1984, Section 6.5 these time delays shall be subtracted from the latest time that the nuclear safety function can be completed, ti. As determined from the event behavior above, the tj value is 26.5 minutes, resulting in the latest time for operator action (ti) of 24.5 minutes to ensure that the PSV design limit is not exceeded.

6

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis Evaluation Results and Conservatism:

The assumed 20-minute action time in the PVNGS analysis meets the requirements of ANSI/ANS-58.8-1984 for time allowed for indication, recognition, diagnosis, and planning of actions. Using the 20-minute action time plus the two minutes allowed for the operator action time delay and the equipment and process time delay, there is an additional "Range for Operator Action" margin (tc-tm) of at least 4.5 minutes.

During a FWLB event, the opening of an ADV is a backup response to the automatic safety related function of the MSSVs. As a result, the identification of this ADV action does not require complete diagnosis of the FWLB event. The action of opening the ADV is identified and performed per the Standard Post Trip Actions EOP, prior to entering the event specific EOP. Thus, the 20 minutes allowed by ANSI/ANS-58.8-1984 for indication, recognition, diagnosis, and planning of the action, is conservative.

As discussed in the APS response to NRC Request # 6 below, the actual observed time of action in the simulator scenarios performed were all less than five minutes from FWLB event initiation until the ADVs were opened. As shown in Figure 1, using less than five minutes as the "Complete Action Actual (tin 1 )," the time margin tested for the range for operator action (tc-tmi) would be more than 20.5 minutes.

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Enclosure 1 Response to RAI Regarding LAR to Revise the FWLBILOP/SF Analysis Figure 1. Description of Time Points TimeTest I Time Test 2 Complete I Action 6

Actual tml< 5 in Range for Operator Action = 4.5 in (Analysis)

Range for Operator Action Tested6 > 20.5 m

1. Trip of feedwater pumps on overspeed due to the break in the feedwater line. Also, in a very short time (2-3 seconds) alarms on the containment conditions.

2. MSSV opening alerting operators to open ADV to prevent cycling of MSSVs

3. Time Test 1: Time Margin (20 min) determined by ANSI/ANS-58.8-1984 for a limiting fault event (includes Time Test 2, Fixed Portion, in accordance with the Section 5.4 of the Standard)

4. Time Test 2, Variable Portion: Time (1 min) determined by ANSI/ANS-58.8-1984 (vs. actual 20-30 seconds operator action time delay)

S. One minute assumed conservatively although the operators will have indication that action is successful (e.g., decreasing SG pressure within 10-20 seconds)

6. Based on the Simulator verification performed by three different operation crew (see APS Response to Question 6) 8

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis NRC Request 6:

Is there any empirical human performance data, such as timed simulator training scenarios, available to derive time intervals that could justify crediting the twenty minute assumption? In accordance with ANSI/ANS-58.8, such an empirical evaluation should be designed to yield results at a 95% confidence level.

APS Response:

Although ANSI/ANS-58.8-1984, Section 9 permits exceptions, the LAR did not request any exceptions to the conservative Time Test Values. Thus, no new independent database or less conservative operator action times, based on new task analyses, were derived. However, PVNGS did conduct the FWLB event scenario with three different operating crews to validate the margin available for the operator action assumed in the analysis. The following table provides the results:

Crew Time to Open ADVs (min:sec) 1 04:00 II 03:15 III 02:03 NRC Request 7:

Please describe or provide a copy of the administrative procedure controlling the Palo Verde Time Critical Action Program.

APS Response:

The current revision of procedure 40DP-9ZZ04, "Time Critical Action (TCA) Program," is provided in Enclosure 2. The list of specific Chapter 15 analysis time critical actions can be found on Page 7 of Appendix D. As stated in Reference 1, once this amendment is approved the 20 minute operator action completion time will be added to the list of Chapter 15 analysis time critical actions in the Palo Verde Time Critical Action Program.

NRC Request 8:

The licensee stated in its submittal, "If an error were to occur for any reason there is ample indication of plant status available to the operators to ensure timely recovery."

Please provide the basis for this statement. Please state how the recovery time was estimated or determined. Also, please explain how there can be sufficient time available to recover if the diagnosis takes the full 20 minutes available.

9

Enclosure 1 Response to RAI Regarding LAR to Revise the FWLB/LOPISF Analysis APS Response:

The LAR summarizes the evaluation of the three identified operator errors. That summary concludes: "None of the potential operator errors are considered credible; therefore, error recovery is not a concern. If an error were to occur for any reason there is ample indication of plant status available to the operators to ensure timely recovery."

The referenced portion of this statement was intended to reiterate that many plant indications are available to the operator for verification of the proper action taken. It was not implying that there is any credible error. As stated in the submittal dated August 27, 2010 (Reference 1), there are no credible operator errors for this event; therefore, there was no estimated error recovery time required to be determined.

References:

1. APS letter number 102-06099, "Request for Operating License Amendment -

Revision of Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis," dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102510161)

2. NRC letter dated December 21, 2010, "Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Request for Additional Information Regarding License Amendment Request to Revise the Feedwater Line Break With Loss of Offsite Power and Single Failure Analysis (TAC NOS. ME4596, ME4597, AND ME4598)

(ADAMS Accession No. ML103500510)"

3. ANSI/ANS-58.8-1984, "Time Response Design Criteria for Nuclear Safety Related Operator Actions" 10

Enclosure 2 Response to RAI Regarding LAR to Revise the FWLB/LOP/SF Analysis Enclosure 2 Palo Verde Time Critical Action Program

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 1 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Procedure Preparer: Carol Fuccillo Procedure Owner: Randy Merryman Procedure Usage Requirements Sections

" The user reviews the procedure, as needed before using it to perform the task.

• The user may complete the task from memory, however Information Use: the user still is responsible for performing the activity in ALL accordance with the procedure.

" Administrative procedures are considered Information Use unless otherwise designated within the procedure.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 2 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 CONTENTS SECTION PAGE 1.0 PURPO SE AND SCO PE ............................................................................................... 5 1.1 P u rp o s e ............................................................................................................................. 5 1.2 Scope ................................................................................................................................. 5 2.0 RESPO NSIBILITIES ....................................................................................................... 5 2.1 Operations Standards Section Leader ......................................................................... 5 2.2 Operations ......................................................................................................................... 6 2 .3 T ra in in g .............................................................................................................................. 6 2.4 Operations Standards .................................................................................................. 6 3.0 DEFINITIO NS ...................................................................................................................... 7 4.0 INSTRUCTIO NS .......................................................................................................... 8 4.1 TCA Sources ............................................................................................................ 8 4.2 TCA General Requirem ents ........................................................................................ 8 4.3 TCA Validation ........................................................................................................... 10 4.3.1 Reasons for Validating TCAs ........................................................................... 10 4.3.2 Validation Methods ........................................................................................... 10 4.3.3 Validation O bjectives ........................................................................................ 11 4.3.4 Validation Aspects ........................................................................................... 12 4.3.5 Validation Process ........................................................................................... 14 4.3.6 Conduct of Validation ......... *........................... ...... 18 4.3.7 Non-Personnel Validation Aspects .................................................................... 19 4.3.8 Evaluation of TCA Validation .......................................................................... 21

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 3 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 SECTION PAGE 4.4 Program Documentation ............................................................................................. 22 4.5 Program changes / updates ........................................................................................ 23 5 .0 R E F ER E NC ES .................................................................................................................. 23 5.1 Implementing References ........................................................................................... 23 5.2 Developmental References ........................................................................................ 24

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 4 of 46 Revision Time Critical Action (TCA) Program 40DP9ZZO4 5 APPENDICES APPENDIX PAGE Appendix A - TCA Evaluation Briefing .................................................................................. 25 Appendix B - TCA Package Cover Page ................................................................................ 26 Appendix C - Options to Improve TCA Response Time ........................................................ 27 Appendix D - Tim e Critical Actions Catalog ........................................................................... 28 Appendix E - Manual Component Manipulation Times .......................................................... 38 Appendix F - Manual Manipulated / Timed Component List .................................................. 40

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 5 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1 This program provides the following:

" A means to ensure that the Time Critical Actions (TCAs) within the scope as defined in Section 4.1, TCA Sources, can be accomplished by plant personnel.

• A means to document periodic validation of credited action items.

" A means to ensure that changes to the plant or to procedures or protocols do not invalidate credited action times.

1.1.2 TCAs are documented in a specific manner to enable the plant to have a firm basis for output documents that rely on accurate records of referenced TCAs.

1.1.3 This procedure supports the implementation of the Operations Program within the Operate the Plant Program Area.

1.2 Scope 1.2.1 This program applies only to those TCAs that are delineated in Section 4.1, TCA Sources. TCAs are those actions required to be performed by Operations to mitigate an event as credited by safety analysis (such as UFSAR, Fire Protection Program, PRA Human Reliability Analysis, Shutdown Risk Assessments, and Engineering Calculations).

2.0 RESPONSIBILITIES 2.1 Operations Standards Section Leader 2.1.1 Implements and maintains the TCA program.

2.1.2 Maintains current TCA validation records by maintaining validation paperwork and related documentation within the department files for at least five (5) years.

2.1.3 Organizes and coordinates periodic validation of the TCA catalog. Refer to Appendix D - Time Critical Actions Catalog.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 6 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 2.2 Operations 2.2.1 Ensures minimum shift staffing is sufficient to ensure that TCAs can be performed within the required times.

2.2.2 Unit 1 only - Ensures the minimum shift staffing is sufficient to ensure that SBOG operation can be performed within the required time.

2.3 Training 2.3.1 Ensure personnel qualified in areas where TCAs are performed are trained and current in aspects relating to TCAs.

2.3.2 Support simulator validation of TCAs when required.

2.4 Operations Standards 2.4.1 Maintain a list of TCAs, and update the list as TCAs are added, deleted or modified.

2.4.2 Review changes to procedures, communications standards, procedure usage protocols, and other human performance protocols to determine impact on ability to meet TCAs.

2.4.3 Implement and document the validation of the ability to meet TCAs by completing the TCA Validation package for each identified TCA.

2.4.4 Consider the impact on related TCAs when revising procedures.

2.4.5 Require TCA validation if any TCA may be adversely impacted by a procedure change.

2.4.6 Ensure the impact of procedure revisions are review by the appropriate department for new or existing TCAs.

2.4.7 Inform Operations and Training of changes or revisions that create new TCAs.

2.4.8 Periodically benchmark other facilities per 01 DP-0AP1 6, PVNGS Self-Assessment and Benchmarking, to assess the TCA process to current industry standards.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 7 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 3.0 DEFINITIONS 3.1 Time Critical Action (TCA) - A manual action or series of actions that must be completed within a specified time to meet plant licensing basis. A change in the required completion time is considered to be a change to the TCA.

3.2 Validation - Performance of a time critical action on the simulator or by in-plant walkthrough, or both, to ensure the action can be performed within the required time using the applicable procedures, including all required human performance protocols. To the extent possible, the validation will include all assumptions used in the analysis for the action being validated.

3.3 Simulator Validation - A validation method, using the simulator, for new procedures, or procedure changes, that impact the sequence or logic of steps associated with plant systems or components that could increase the chance of a plant trip or transient.

3.4 Walkthrough Validation - A validation method where procedure performance is simulated by walking through the procedure steps at the locations specified in the procedure.

3.5 Minimum Shift Staffing - A validation method where procedure performance is simulated by walking through the procedure steps at the locations specified in the procedure.

3.6 SSC - System, Structure, or Component 3.7 AO - Auxiliary Operator

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 8 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.0 INSTRUCTIONS 4.1 TCA Sources 4.1.1 TCAs included within the scope of this program are listed in Appendix D - Time Critical Actions Catalog.

4.1.2 Sources of TCAs include the following:

" UFSAR

" Technical Specifications

• Station Blackout Analysis

• Licensing Commitments

" Appendix R Analysis

" At-Power PRA Study for Human Reliability Analysis

" 70DP-ORA01, Shutdown Risk Assessments 4.1.3 TCAs may be exempted from periodic validation and other program elements if both of the following are performed and documented by a cross discipline review panel (Operations, Engineering, PRA, etc.):

4.1.3.1 The TCA is determined to be of low risk significance, or 4.1.3.2 The margin between the expected performance time and required performance time is more than 200 percent.

4.1.4 Equipment used to meet the exempted TCA shall be verified on a periodic basis to be capable of meeting its credited TCA function.

4.2 TCA General Requirements 4.2.1 TCA evaluation shall include an analysis of the adequacy of the information available to the performer, the location of the devices to be manipulated and the time available for the performer to complete the action.

4.2.2 The minimum complement of plant personnel shall be maintained on site such that TCAs can be completed within the required times specified in the applicable analyses.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 9 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.2.3 Locations outside the Control Room, including ingress and egress routes, that are required for access for performance of TCAs, shall adequately protect personnel from the environmental or radiological conditions caused by the event, or the application of personal protective equipment shall be included in the TCA.

4.2.4 Adequate lighting and communication methods shall be available for locations outside the Control Room, including ingress and egress routes, which are required for access for performance of TCAs.

4.2.5 Records of actual operating time for plant equipment used to satisfy a TCA, including valve stroke times for remotely and locally operated valves, shall be maintained.

4.2.5.1 Where it is not possible to obtain a stroke time for the specific valve to be operated, the justification for not stroke timing shall be documented, and a known stroke time for a similar valve may be used. Actual stroking of the valves credited in the analysis is strongly preferred to identify difficulties with valves. The exception to use a similar valve should only be applied in unusual situations.

4.2.6 Appendix R (that is, 40AO-9ZZ19, Control Room Fire) TCAs are to be performed on a triennial basis, prior to the Triennial Fire Inspection. A PVAR shall be written to document the requirement to perform an Appendix R TCA validation prior to the next Triennial Fire Inspection.

4.2.7 Station Blackout TCAs (that is, 40EP-9EO08, Blackout, and 40EP-9EO10, Standard Appendices, Appendix 53 & 80) are to be performed in conjunction with the performance of 40ST-9GT06, Station Blackout Generator #1 Timed Test and 40ST-9GT07, Station Blackout Generator #2 Timed Test.

4.2.8 For all Non-Appendix R (that is, 40AO-9ZZ19, Control Room Fire) TCAs, a PVAR shall be written to document the requirement to perform a TCA validation within five (5) years of the completion of the previous TCA validation.

4.2.9 Validation of new or revised TCAs should receive a sufficient number of performances, typically by three (3) different performers (or crews), in order to provide reasonable assurance that the TCA can be completed within the required time.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 10 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3 TCA Validation 4.3.1 Reasons for Validating TCAs 4.3.1.1 TCAs are initially validated to determine whether design assumptions for operations personnel are able to be performed within the specified time constraints.

4.3.1.2 TCA performance must be periodically validated to ensure that changes in plant equipment configuration, procedures, shift staffing, or staff knowledge is sufficient/adequate to support/not inhibit successful completion of tasks within the specified time constraints.

4.3.1.3 Conditions that could prompt validation or re-validation of one or more TCAs include, but are not limited to, the following:

• Procedure changes

" Engineering request due to plant modification, design change, revised analyses, PRA results, etc.

" Change or proposed change in plant protocol such as human performance procedures or standards.

" Periodic validation at a frequency that ensures the continued ability to meet TCAs, not to exceed five (5) years. This includes verifying the ability of locally operated equipment, tools, keys, flashlights or other devices or supplies to perform their required TCA function.

Periodic validation is a valuable tool for detecting an unexpected challenge to TCA completion time, which may occur due to the aggregate of procedure and protocol changes and equipment modifications over time.

• Operations management request

" Degrading trend in TCA completion time 4.3.2 Validation Methods 4.3.2.1 TCAs that have required completion times such that simulator scenario or in-plant walkthrough validation is feasible shall be validated on the simulator or by walkthrough, controlled by a TCA Validation package.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 11 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.2.2 TCAs that have required completion times such that simulator or in-plant walkthrough validation is not feasible shall be validated using alternate means. This should include a combination of simulator validation for such portions (ifany) for which the simulator is useful, in-plant walkthrough for applicable portions (ifany), and reasonable engineering judgment to waive those portions that are not satisfied by simulator or in-plant walkthrough.

a. The basis for waiving all, or any portion, of a TCA validation should be documented. This provision should not be used as a routine validation convenience in lieu of other alternatives that appropriately validate TCA completion times 4.3.2.3 Applicable training records such as simulator scenarios, JPM performance may be used to document periodic validation of TCA completion times, provided that such validation is consistent with the TCA Validation section of the TCA Program.

4.3.3 Validation Objectives 4.3.3.1 Ensure the times are met as specified in the plant licensing basis.

4.3.3.2 Demonstrate that the language, level of information, sequencing and number of tasks in the procedure is compatible with the minimum staffing, qualification, training and experience of plant personnel.

4.3.3.3 Verify lighting, component labeling, accessibility of equipment, tools, keys, flashlights and other devices or supplies are adequate for successful completion of the TCA.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 12 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.4 Validation Aspects 4.3.4.1 There are three major parts of the TCA program:

a. Design TCA identification of requirements: This is typically an Engineering function and is performed by Engineering. Part of the output of a Design Basis Review will be manual actions that are time limited (TCAs). When new TCAs are identified, or existing TCAs are identified as requiring updating, Engineering should notify, as a minimum, Operations and Operations Standards.

b. Equipment operation times: This is a validation that the individual components within the TCA are able to be operated with identified methods and within assumed times. These are the recorded measured times for individual manual operation of SSCs upon which the task validations are based. The SSCs, identified in Appendix E -

Manual Component Manipulation Times, should be periodically inspected and cycled to ensure time assumptions are valid.

1) Operations and Operations Standards shall be responsible to populate Appendix E - Manual Component Manipulation Times, with manually operated SSCs required to support identified TCAs.

2) Operations shall perform manipulation of the SSCs listed in Appendix F - Manual Manipulated / Timed Component List to establish the required time to operate each SSC.

3) The SSCs listed in Appendix E - Manual Component Manipulation Times, should be re-validated over a period of five (5) years. Deficiencies identified should be promptly corrected.

c. TCA task evaluation: This is the comprehensive validation that a TCA task can be performed within the design time period, including all performer tasks, such as briefings, notifications, travel. This should include those personnel necessary to evaluate and perform the TCA. The team should include a combination of the following, appropriate to the TCA validation being performed.

1) Team Leader: The validation team leader possesses a level of knowledge commensurate with the task being validated, including the relation of the task to the TCA requirements.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 13 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5

2) TCA performer(s) - The TCA performers include only the minimum staffing required by the TCA analysis. The qualifications of the performers should be typical of the level of experience and training of personnel expected to perform the actions during an actual event.

3) Observers - one observer will be required to time the actions of each of the performers if a group of task performers is required (such as a Control Room crew).

4) Optional personnel - Depending on the reason for validation (such as procedure changes, plant modifications), or the need for additional expertise, other personnel representing Training, Engineering, PRA, Site Procedures Standards or other groups of interest may be desired for observing or validating the TCA.

5) Training support - Training personnel, with input from other groups as needed, develop simulator scenarios, JPM scenarios or other appropriate evaluation methods consistent with the TCAs, including initial conditions, assumed equipment or system availability or failures, and other conditions associated with the TCA, to the extent possible.

6) Simulator validation - the most effective method of testing Control Room procedures to ensure the assumed time lines can be accomplished.

7) In-plant walkthrough validation - the most effective method for local actions required for a TCA, or when simulator modeling constraints prevent effective validation using the simulator.

8) A combination of simulator and in-plant walkthrough validation is most effective for time lines which include actions both in the Control Room and in the plant.

9) Special equipment, tools, keys, flashlights or other devices or supplies that are required to support the TCA are readily available.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 14 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 NOTE Evaluators record required information but do not interfere with, distract or inappropriately prompt the performers during the execution of the TCA validation.

4.3.4.2 Validation of new or revised TCAs should include a briefing of the validation team by the Team Leader. This briefing includes the following:

The purpose of the validation.

" Discussion of the TCAs being validated.

" Content and purpose of revised actions or time requirements.

" Performer responsibilities.

" Evaluator responsibilities.

4.3.4.3 Periodic or unannounced TCAs Validations are performed without briefing the performers on the specifics of the TCA. This restriction is intended to avoid coaching or preconditioning of the TCA performers, and is not meant to exclude other plant-required aspects of pre-job briefs such as safety, ALARA, protected equipment.

4.3.5 Validation Process 4.3.5.1 The Team Leader shall prepare the validation package by completing the applicable fields in Appendix A - TCA Evaluation Briefing. If multiple Appendices will be performed during the evaluation, document the performer that is assigned to perform each Appendix that is being evaluated.

4.3.5.2 The Team Leader shall ensure that potentially impacted workgroups/departments are given sufficient notice of the evaluation date, time and resource requirements such that the evaluation can be performed with limited impact to daily plant activities.

4.3.5.3 The Team Leader or preparer shall review the TCA to ensure that all SSCs found in the TCA have baseline times established (listed in supporting calculations, such as 13-MC-FP-0316), or ensure that the SSCs are tested prior to TCA final calculation (Refer to 4.3.7.1).

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 15 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.5.4 For walkthrough validations, on the day of the evaluation, the Team Leader shall interface with the Shift Manager, RP, Security, etc., as to the suitability of conducting the evaluation with regard to impact to on-going or plant activities.

4.3.5.5 Starting Point

a. The evaluation shall start at the most likely or most limiting place of origin of the evaluated participant. For Operations personnel, this may be the Control Room or the Auxiliary Operator (AO) work station. Ifthe AO needs to meet with the Control Room Supervisor (CRS) / Shift Manager (SM) or other supervisor, travel to that location shall be included in the timed session.

4.3.5.6 Briefing

a. The Team Leader shall brief the evaluated participant(s) on the expected performance of the task, such as those actions and methods that the participant would use during actual performance of the task without supervision or observers. Use Appendix A - TCA Evaluation Briefing to perform the briefing. Additional detail should be entered onto the Appendix page for retention.

4.3.5.7 Evaluation commencement

a. The Team Leader shall read any initial conditions from the scenario description that will give the evaluated participant sufficient information to recognize the event at hand, procedures needed, communications required, etc., to get started in the performance of the evaluation.

1) Ifthere are lead-in instructions to make the task realistic, it is appropriate to start several steps ahead in the procedure as long as the evaluation team understands where the actual starting point of the task is ("time zero").

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 16 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.5.8 Performance of the evaluation

a. Once the evaluated participant acknowledges the initiating queues, the scenario begins and the team shall note the clock time that each instruction is started and completed.

1) If a valve is to be operated (or similar task is performed) that takes an extended period of time, the Team Leader shall note the time that the participant arrives at the component and states the intended operation. At that time, the Team Leader shall respond that the component is in its intended position. The "Time to Operate" or to perform that specific action shall be added into the total elapsed time following completion of the task evaluation. The team shall also take notes of any issues observed that may inhibit the completion of the TCA.

4.3.5.9 Termination of the evaluation

a. At the completion of the task, the Team Leader shall collect the notes from the evaluation team. The team shall assist the evaluated participant in restoring any used support equipment.

4.3.5.10 Determination of Elapsed Time for a TCA (for TCAs involving predecessor TCAs and/or assumed times):

a. Establish "Time Zero."

b. Add any assumed times for the performance of specific steps (for example, one minute is added for communication with the Shift Manager, one minute is added for CRS performance of 40AO-9ZZ1 9, Control Room Fire, Appendix Z).

c. Note the time at which the predecessor action is completed (for example, the successor TCA is commenced).

d. Add any assumed times for component manipulations, as documented in Appendix F - Manual Manipulated / Timed Component List under Time to Operate.

e. Calculate the total elapsed time for completion of the TCA.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 17 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.5.11 Review and closure:

a. The Team Leader compares the notes gathered from the team and determines if the required times were met. Any observations of obstructions or inhibitors that resulted from plant conditions (plant activities, support group actions, material condition, etc.), or procedure deficiencies that lead to degradation of the task performance, shall be documented in the notes. PVARs shall be originated to document required corrective actions and the SM / CRS shall be apprised of any plant issues noted.

4.3.5.12 Completion of Documentation:

a. The Team Leader completes the remaining fields of Appendix B -

TCA Package Cover Page, then assembles Appendix A - TCA Evaluation Briefing, Appendix B - TCA Package Cover Page, the marked-up procedure / Appendix pages, Appendix D - Time Critical Actions Catalog pages for TCAs that were evaluated, and any additional documentation used to calculate actual TCA completion times.

4.3.5.13 Operations and other associated departments shall be notified of the results of the evaluation.

4.3.5.14 Processing package:

a. Store the current TCA validation records and related documentation within the department files and in an online folder for at least five (5) years.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 18 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.6 Conduct of Validation 4.3.6.1 Validation on simulator

a. Performers take their positions in the simulator control room.

b. Briefing is performed on initial conditions and team member responsibilities, including record of time data.

c. Evaluation team is positioned so as not to interfere with or distract performers or inhibit traffic paths.

d. Copies of applicable procedures and related support documents are available for use consistent with availability in the actual Control Room.

e. The simulated event is executed according to the predetermined scenario.

f. For periodic or unannounced validation, the scenario should continue until the TCA is completed. Ifthe time requirement has been exceeded, the scenario should be continued to aid in determined required changes to accomplish the TCA within the required time. The Team Leader determines when there is no benefit to continuing the scenario.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 19 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.6.2 Validation by Walkthrough

a. The Team Leader will instruct the performer to perform the procedure or sections of the procedure consistent with the method of notification expected during an actual event, per guidance of Appendix A - TCA Evaluation Briefing. Termination criteria and cues should be included in this briefing.

b. If the performer must obtain a procedure to perform the TCA, a verified current copy of the procedure should be pre-staged at the location where the performer would be expected to obtain it.

c. Performers begin validation at a location where the performer may reasonably be expected to be, based on the event in progress.

d. Evaluation team members are stationed at locations appropriate for the TCA.

e. Performers simulate the actions required by the applicable procedures by performing the following:

1) Obtain required equipment such as keys, ladders, tools, spool pieces, and place where required by the procedure.

2) Locate the designated equipment.

3) Simulate using the equipment.

4) Locate and read required instrumentation.

5) Simulate communications necessary to perform the TCA.

4.3.7 Non-Personnel Validation Aspects 4.3.7.1 Equipment operating times (validated plant performance data)

a. The "Time to Operate" valves for plant equipment listed in Appendix F - Manual Manipulated / Timed Component List should be used during evaluations.

b. Where it is not possible to obtain a stroke time for the specific valve to be operated or for a similar valve, an appropriate estimate of stroke time may be used based on plant surveillance times or use of a stroke time from a similar component. This deviation shall be noted in the evaluation package notes.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 20 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.7.2 Ingress / egress routes

a. Pre-determined routes are used to ensure adequate protection from environmental conditions caused by the initiating event for the time ad route required for ingress, TCA performance, and egress.

4.3.7.3 Time keeping

a. Designated team members record scenario start time, completion of tasks important to the TCA, and the time of completion of the TCA.

Calibrated time instruments are not required, but personal watches should be in synch with the simulator clock during simulator evaluations, or synchronized with the Team Leader during field evaluations.

4.3.7.4 Human performance protocols

a. TCA validation includes the use of all current plant human performance protocols and standards for the tasks and procedures being performed.

b. Standards may include, but may not be limited to, the following:

• Communication standards

• Procedure use and adherence standards

• Briefing requirements

• Placekeeping requirements Verification techniques such as self checking, peer checking, independent verification, and concurrent verification Personal Protective Equipment requirements.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 21 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.7.5 Evaluation conclusion

a. The evaluation shall be terminated based on change in plant status (emergency occurs).

b. Upon reaching the termination criteria (conclusion of task), the Team Leader is responsible to ensure that all tools, ladders, procedures, and consumable materials are properly stored or disposed of before leaving the evaluation site.

c. Team members shall have a predetermined meeting site and time to review observations and finalize conclusions.

4.3.8 Evaluation of TCA Validation 4.3.8.1 If the TCA is completed in a shorter duration than 80 percent of the TCA required time, then the TCA is considered valid, providing adequate assurance that the TCA can be reliably performed.

4.3.8.2 If the TCA is completed within 80 percent to 100 percent of the required time, then the following shall be performed:

a. Consider additional validations of the TCA using other performers.

b. Evaluate for a degrading trend in TCA completion time.

c. Generate a PVAR for an Engineering review to determine methods of reducing the actual performance time or possibly eliminating the TCA.

4.3.8.3 If the TCA is completed in a duration greater than 100 percent of the required time, then generate a PVAR for an Engineering review to determine methods of reducing the actual performance time or possibly eliminating the TCA.

4.3.8.4 If, during the performance of periodic or unannounced validation, a single shift crew (or individual) fails to meet the required time, then the following shall be performed:

a. Remediation and retesting of the crew (or individual) per the plant training program.

b. Consider performing additional validations of the TCA using other performers.

c. Evaluate for a degrading trend in TCA completion time.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 22 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.3.8.5 If, during the performance of periodic or unannounced validation, more than one shift crew (or individual) fails to meet the required time, evaluate the ability to meet the plant licensing basis associated with the TCA. In addition, consider whether actions may be taken to improve the TCA response time. Refer to Appendix C - Options to Improve TCA Response Time, for options for improving TCA response time.

4.4 Program Documentation 4.4.1 A list of all TCAs shall be maintained in Appendix D - Time Critical Actions Catalog. The list should contain the following as a minimum:

• TCA source document

• Required action

" Required time limits

• Validation method (simulator, in-plant walkthrough, or combination)

" Procedure that performs the required TCA 4.4.2 The periodic inventory of equipment, tools, keys, flashlights and other devices and supplies required to accomplish TCAs should be retained in plant records.

(This periodic inventory is performed by the Fire Department per 14FT-9FP06, Fire Equipment Locker and Emergency Equipment Cabinet Inspection.)

4.4.3 A record of cross-discipline review for those TCAs that are determined to be exempted from periodic validation or other program elements as permitted in Section 4.1, TCA Sources.

4.4.4 A record of time validation (or waiver) for each TCA shall be maintained.

4.4.5 A record of TCA SSC operating times, including valve stroke times for remotely or locally operated valves, is found in the support calculations. A baseline evaluation of each listed SSC may be performed during the initial roll-out of this program. The measured component times for the basis testing and subsequent testing for post-maintenance or other timed tests shall be documented in Appendix E - Manual Component Manipulation Times.

4.4.6 Store the program documentation records and related documentation within the department files and in an online folder for at least five (5) years.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 23 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 4.5 Program changes / updates 4.5.1 Changes to the TCAs in procedures will require review and updating of this program procedure as necessary to ensure that the procedure is current.

4.5.2 Changes to assumptions made in supporting calculations shall be reviewed for impact on TCAs. Changes to TCAs will need to be reviewed for necessity of re-evaluation.

4.5.3 Changes to this program will require stakeholders of the program (such as performers, supervisors, trainers) to be part of the review and comment process.

4.5.4 Changes to this program will require timely notification of all stakeholders for internal training and qualification purposes.

4.5.5 The Operations Standards Section Leader or designee will have approval authority for changes to this program procedure.

5.0 REFERENCES

5.1 Implementing References 5.1.1 41AL-1 ES2A, Safety Equipment Status System Panel ESA-UA-2A Alarm Responses 5.1.2 41AL-1ES2B, Safety Equipment Status System Panel ESB-UA-2B Alarm Responses 5.1.3 40AL-9RK2C, Panel B02C Alarm Responses 5.1.4 40AL-9RK2D, Panel B02D Alarm Responses 5.1.5 40AL-9RK3A, Panel B03A Alarm Responses 5.1.6 41AL-1 RK5A, Panel B05A Alarm Responses 5.1.7 40AO-9ZZ01, Emergency Boration 5.1.8 40AO-9ZZ02, Excessive RCS Leak rate 5.1.9 40AO-9ZZ03, Loss of Cooling Water 5.1.10 40AO-9ZZ04, Reactor Coolant Pump Emergencies 5.1.11 40AO-9ZZ11, CEA Malfunctions

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 24 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 5.1.12 40AO-9ZZ17, Inadvertent PPS-ESFAS Actuations 5.1.13 40AO-9ZZ1 9, Control Room Fire 5.1.14 40EP-9EO01, Standard Post Trip Actions 5.1.15 40EP-9EO02, Reactor Trip 5.1.16 40EP-9EO03, Loss of Coolant Accident 5.1.17 40EP-9EO04, Steam Generator Tube Rupture 5.1.18 40EP-9EO05, Excess Steam Demand 5.1.19 40EP-9EO06, Loss of All Feedwater 5.1.20 40EP-9EO07, Loss of Offsite Power / Loss of Forced Circulation 5.1.21 40EP-9EO08, Blackout 5.1.22 40EP-9EO09, Functional Recovery 5.1.23 40EP-9EO10, Standard Appendices 5.1.24 40EP-9EO11, Lower Mode Functional Recovery 5.1.25 40OP-9CH01, CVCS Normal Operations 5.1.26 40OP-9EW01, Essential Cooling Water System (EW) Train A 5.1.27 40OP-9EW02, Essential Cooling Water System (EW) Train B 5.1.28 40OP-9ZZ01, Cold Shutdown To Hot Standby Mode 5 to Mode 3 5.1.29 40OP-9ZZ03, Reactor Startup 5.1.30 74RM-9EF41, Radiation Monitoring System Alarm Response 5.2 Developmental References 5.2.1 Developmental References are in the Basis Document.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 25 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix A Page 1 of 1 Appendix A - TCA Evaluation Briefing A.1 The following briefing notes should be used to ensure the evaluated performer understands the expectations of this evaluated TCA.

All normal human performance tools are to be used per Conduct of Shift, ODs, etc., such as two minute drills and STAR.

The only interaction between the evaluator and evaluated shall be the giving and receiving of queues pertaining to the conduct of the task.

Consumable emergency equipment, such as flashlights, shall not be used; noninventoried equipment shall be supplied. Ifa ladder is expected to be used, the ladder can be taken from its emergency storage location and returned to the storage location at the conclusion of the evaluation.

Entry requirements into the RCA are to be strictly followed.

All plant safety expectations are applicable at all times.

No actual equipment manipulations should occur in performance of the evaluation.

Ifa real plant emergency occurs the TCA Evaluation will be terminated and the participant shall perform expected actions (area evacuation or muster at an Assembly Area).

A.2 The briefing shall end with the Team Leader asking the performer if there are any questions about the conduct of the task.

A.3 Briefing Notes:

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 26 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix B Page 1 of 1 Appendix B - TCA Package Cover Page FIGURE 1 - TCA PACKAGE COVER PAGE Time Critical Action Validation Package Validation Desamiption (Procedure Section J Appendi. I TCA Numbee.s)):

Team Members: Performers:

Validation Daw: Performance Me*hod:

(circle mothod.s use i Simulator / Field Walkdown Ev..alrion Resu]ts:

Corrective Actions Taken if required),

Package Prepared BY: Package Reviewed By: Completion Date:

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 27 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 1 5 Appendix C Page 1 of 1 Appendix C - Options to Improve TCA Response Time 0.1 Options for improving response times include, but may not be limited to, the following:

" Modifying human performance protocol requirements. For example, excessive communications, briefings, or other requirements extend the time required to perform a procedure.

" Reducing level of detail in procedure steps. For example, if instrument identification number and control board locations are listed in the procedure for commonly used instruments, it will take longer to read and perform each step than if the commonly used instrument numbers and/or the associated control board locations are not written in the procedure.

" Changing step sequence such that more important actions are performed earlier in the procedure.

" Modifying procedure usage to increase the use of procedure handoffs, attachments, enclosures, etc.

• Modifying equipment such that fewer manual or local actions are required.

Reanalyzing the TCA in order to modify the TCA required time such that the performer can achieve the required completion time using existing plant procedures and protocols.

Obtaining an amendment to the plant licensing basis.

Appendix D - Time Critical Actions Catalog G)

Validation Procedure Performing Source Document Cn TCA Action Time Limit Method Organization (other info) C)

-:i a-13-MC-FP-318 TCA-1 Initiate MSIS 90 seconds Simulator 40AO-9ZZ19 Ops (40A0-9ZZ19, CD Section 3.0) 0 ADV 13-MC-FP-318 0 TCA-2 Disconnects to 5 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, LOCAL Section 3.0) 0) 13-MC-FP-318 0

CHB-UV-515 20 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, Section 3.0) 0 0 S13-MC-FP-318 17 TCA-4 Establish AFW 45 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, z

-Flow to S/Gs Section 3.0) 13-MC-FP-318 0 (a

TCA-5 Trip AFA-P01 16 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, Section 3.0)

X W

13-MC-FP-318 TCA-6 Injection 60 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, Section 3.0)

Determine RCS 13-MC-FP-318 TCA-7 Boron 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, concentration Section 3.0) 13-MC-FP-318 PKB-D2221 7.5 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, Appendix A) 0)

Open specified 13-MC-FP-318 0 3:

TCA-9 breakers on 7.5 minutes Walkdown 40AO-9ZZ1 9 Ops (40A0-9ZZ1 9, CD CD PKA-D21 Appendix A) 02 Open specified 13-MC-FP-318 0~

TCA-10 breakers on 10 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, N N

PKA-D21 Appendix A) 0 RSP disconnect 13-MC-FP-318 TCA-11 switches in 10 minutes Walkdown 40AO-9ZZ19 Ops (40A0-9ZZ19, -0 LOCAL Appendix A) --L 4N.

TA- 13-C00-2000- 0)

TCA-12 Disable all RCP 10 minutes Walkdown 40AO-9ZZ19 Ops 004Appendix (40AO-9ZZ19, C) X SBreakers B) M'*

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info) 14 minutes G)

(3 pumps Cn Disable running) 13-MC-FP-318 TCA-13 CHA-POI & 22 minutes Walkdown 40A0-9ZZ19 Ops (40A0-9ZZ19, --4 CHE-P01 (2 pumps Appendix B) running) CD 44 minutes (1 pump running) 13-MC-FP-318 1-1 TCA-14 Disable NCP breakers 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ1 Appendix B)9, .0*

0 13-MC-FP-318 CD m TCA-15 Disable breakersCD 30 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix B) 13-MC-FP-318 0 0a TCA-16 Disable EDP breakers 30 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix B) w-2.6 minutes 13-MC-FP-318 3u TCA-17 Start SP Pump B (DG15fully loaded) minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, (DG unloaded) Appendix C/DIE)

TA-13-COO-2000- 0 TCA-18 Start AF 45 minutes 004(40AO-9ZZ1 9, M Appendix C/D/E) 0 13-MC-FP-318 TCA-19 Start EC 40 minutes (40AO-9ZZ1 9, Appendix C/D/E) X 13-MC-FP-318 Z TCA-20 Start EW 35 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix C/D/E) 01 Ensure 13-MC-FP-318 CD TCA-21 CHB-P01 is 30 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, :3 running Appendix C/D/E)

Close 13-MC-FP-318 (D TCA-22 DGB-V064 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, DGB-V064__Appendix C/D/E) (C) 13-MC-FP-318 Nl, TCA-23 Pump CS Disable B 12 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, CD N- (0 Pump____Appendix F) N) 13-MC-FP-318 0 TCA-24 Disable CS 12 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Pump A Appendix F) C0

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info) 13-MC-FP-318 G)

AFN-P01 16 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Z TCA-25__AFN-P01_ Appendix F) C Open breakers 90 minutes 'PCR 13-MC-FP-318 __I 0 TCA-26 for NC/EW 90 Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ1 9, 3 I-Cross-tie valves 3510485) Appendix F) CD M Open HJ 13-MC-FP-318 TCA-27 dampers disconnect 45 (DSminutes 01-06) Walkdown 4OAO-9ZZ19 Ops (40A0-9ZZ19, Appendix F) 0 switches S13-MC-FP-318 0 TCA-28 Start Fans (HJB-Z04) Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, 0 Appendix F) Ill Ensure 13-MC-FP-318 TCA-29 PKA-4102 &

PKA-D2110 are 90 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, 0

3-closed Appendix F) "0 13-MC-FP-318 Co m TCA-30 Makeup 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix F) 2 0

TCA-31Open S13-MC-FP-318 TCA-31 CHE-HV-536 30 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, 0 Appendix G) 22 minutes X0 (2 charging 13-MC-FP-318 TCA-32 Close pumps running) Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, CHN-UV-501 44 minutes Appendix G)

(1 charging pump running)

Open disconnect 13-MC-FP-318 -D 0 TCA-33 switches on 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, CD

-u ZAN-C01 Appendix G)

C)

Open disconnect 13-MC-FP-318 N TCA-34 switches on 60 minutes Walkdown 40AO-9ZZ1 9 Ops (40AO-9ZZ1 9, N ZAN-C02 Appendix G) 0 22 minutes co CD (2 charging Close pumps running) 13-MC-FP-318 CD TCA-35 CHN-V183 44 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, (1 charging Appendix G) 0 pump running) 0 cn.

TCA Action Time Limit Validation Method Procedure Performing Organization Source Document (other info)

Isolate makeup 13-MC-FP-318 CO)

TCA-36 to EW B Surge 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Tank Appendix G) 13-MC-FP-318 TCA-37 Open breakerfor 120 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, I-SIA-UV-672Appendix G) (D m Disable CT 13-MC-FP-318 TCA-38 Pump A 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ1 9, Appendix G) 0 Ensure flow to 13-MC-FP-318 TCA-39 RC Sample 90 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Cooler Appendix G)

Ensure 13-MC-FP-318 (2, TCA-40 SIA-UV-672 is 120 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, -I closed Appendix G) W Ensure 13-MC-FP-318 3 X TCA-41 SIB-UV-671 is 120 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, closed Appendix G) R 13-MC-FP-318 0 TCA-42 Open breakers 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, on PHB-M34H) Z TCA3 breakers Open 13-MC-FP-318 TCA-43 on PHB-M36 120 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix H) 0 13-MC-FP-318 TCA-44 NHN-M1903 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, NHN-M1903__ Appendix H) 13-MC-FP-318 TCA-45 Open SSN-V819 90 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix H) 0 TCA-46Open 13-MC-FP-318 TCA-46 CHB-HV-255 60 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, Appendix H) (b N -U CD IN Ensure 13-MC-FP-318 0.- 0)

(40AO-9ZZ1 CC)

TCA-47 EWA-UV-65 EWA-UV-145 and 90 minutes (PCR 3510485) Walkdown 40AO-9ZZ19 Ops Appendix H)9, 0 CD are closed C)

Close 90 minutes (PCR 13-MC-FP-318 4%

3510485) 40AO-9ZZ1 9 Ops (40AO-9ZZ1H)9, 0 TCA-48 NCN-UV-99 NN-V9 35104Appendix Walkdown C)

TCA Action Time Limit Validation Procedure Performing Source Document "0 Method Organization (other info)

Z 13-MC-FP-318 C,,

TCA-49 Cross Connect 90minutes(PCR Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, EW and NC 3510485) Appendix H) Z C

13-MC-FP-318 0 TCA-50 SSB-UV-200 90 minutes Walkdown 40AO-9ZZ19 Ops (40AO-9ZZ19, -17 SSB-UV-200__Appendix H) CD m SBO Analysis - 0 UFSAR 8.3.1.1.10 0 TCA-51 Energize 60 minutes Simulator and 40EP-9EO08 Ops (40EP-9E010, PBA-S03 Walkdown Standard CD Appendices 53 & -c

80) 0 Z Note The following Time Critical Actions (TCA-52 through TCA-68) are associated with UFSAR / Safety Analysis events and PRA analysis mI as noted.

13-MC-SI-0230 - I-UFSAR 6.3.2-3 item Stop the ECCS 40EP-9EO03 17 TCA-52 pumps of RAS on failure valves to 7 minutes Simulator 40EP-9EO09 4xAL-xES2A Ops (4xAL-xES2A open 4xAL-xES2B window ES2AO4A 4xAL-xES2B window ES2B04A)

Initiate an RCS Leak rate following receipt 60 minutes JPM 74RM-9EF41 Ops UFSAR 5.2.5.3.3 TCA-53 of high alarm or 40AO-9ZZ02 z increasing trend on RU-1 Reduce power or 40AO-9ZZ03 I--

isolate cooling 40AO-9ZZ04 UFSAR 5.4.1.3 CD TCA-54 water and 30 minutes Simulator 40AO-9ZZ1 7 Ops question 5A.23 0 shutdown RCP 40OP-9EW01 (NRC Question (0 on loss of NC to 40OP-9EW02 440.87)

RCPs 0 IN N

Place H2 40EP-9EO03 0 (31 TCA-55 Analyzers 30 minutes Simulator 40EP-9EO05 Ops UFSAR 6.2.5.2.1 inservice following LOCA 4OEP-9E009 cc CD Co

-0 Isolate leak in SI 40AL-9RK2C Ops UFSAR 6.3.1.4.C.3 CDI TCA-56 pump room 30 minutes Simulator 40AL-9RK2D UFSAR 7.6.2.1.3.3 0

C)4

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info)

UFSAR 6.2.3.7, GO) 6.3.3.4.1 and cn TCA-57 Realign HPSI for hot and cold leg 120-180 minutes Simulator 40EP-9EO03 40EP-9EO09 Ops 6.3.3.4.4 and Table 6.3.2-3 (item 21) a injection (Std App 100) 1HLI-33HR-OP-CD 2HR CRAI 3343684 UFSAR Question 0 CO) 40EP-9EO02 6A.46 (NRC 40EP-9EO03 Question 440.25)

SIAS manual 40EP-9EO04 0-4 reset is not 40EP-9EO05 UFSAR 6.3.1.4.1.1: 0 TCA-58 permitted for 10 10 minutes Simulator 40EP-9EO06 Ops A SIAS will not be minutes 40EP-9EO07 reset unless the following LOCA 40EP-9EO09 operator has 40EP-9EO10 determined that conditions warrant this action.

0 Take appropriate 40AO-9ZZ03 cc Tactin topropitet 40AO-9ZZ04 3D TCA-59 action the RCP to on protect loss 30 minutes Simulator 40AO-9ZZ171 40OP-9EW0 Ops UFSAR 7.6.2.1.3.1 of NC to an RCP 40OP-9EW02 0

UFSAR 8.3.1.1.10 TCA-60 WClass 1E bus 40ST-9GT06 40EP-9EO08 Ops PRA NS-B062, Power one 4.16 60 minutes 40ST-9GT07 AGTFAILSTRT-2HR 0 with one SBOG CRAI 3343684 Note: Z The 30 minute time limit is specifically associated with the boration flow path with CHN-V164 (BAMP filter bypass). The 15 minute limit is associated with all boration flowpaths).

40AO-9ZZ01 CD 0 4xAL-xRK5A CD

=1 0,-u 40AL-9RK3A 40EP-9EO01 40EP-9EO03 UFSAR 9.3.4.4.2 N CD Commence 15 minutes Simulator 40EP9E004 (LCO 3.1.2) N 0 W-TCA-61 emergency 40EP-9EO05 Ops CRAI 3425589Calc 0 boration (modes 30 minutes Walkdown 40EP-9EO06 13-MC-CH-0208 40EP-9EO08 50.59 E-10-0003 CD 40EP-9EO09 (0 (A) 40EP-9EO10 oD *0 0 C(

400 P-9ZZ01 U)<

40OP-9ZZ03

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info) z Note:

Cn The following Time Critical Action (TCA-62) is associated with UFSAR 15.4.3 and assumes a 15 minute (900 seconds) required z action; however, LCO 3.1.5 and referenced COLR requires a more limiting action for power reduction within 10 minutes. a Reduce power if TCA-62 dropped CEA is 10 minutes Simulator 40AO-9ZZ11 Ops 3.1.5) CD not realigned 0 Terminate 15 minutes 40AL-9RK3A CA TCA-63 inadvertent (modes 1-5) Simulator 40OP-9CH01 Ops UFSAR 15.4.6 boron dilution 40AO-9ZZ01 Terminate 30 minutes 40AL-9RK3A 0 TCA-64 inadvertent (mode 6) Simulator 40OP-9CH01 Ops UFSAR 15.4.6 Tn boron dilution 40AO-9ZZ01 UFSAR 15.6.2 0U Note - alarms are:

Isolate Letdown 40AL-9RK3A 1) Letdown heat z

0 (letdown line 40EP-9EO03 exchanger high exit TCA-65 break) following 10 minutes Simulator 40EP-9EO09 Ops temp receipt of 3 40AO-9ZZ02 2) Letdown line low 3U alarms press

3) Letdown line Rad Monitor low flow 0

(SGTR+LOP)

Affected SG isolated 40EP-9EO04 Ops UFSAR Table z TCA-66 (Hot leg target 70 minutes Simulator 40EP-9EO09 15.6.3-1 temperature reached)

(SGTR+LOP

+SF) 40EP-9EO04 Ops UFSAR 15.6.3.3.2.E Affected SG 46 minutes Simulator 40EP-9EO09 and Table 15.6.3-3 0 z tubes covered. -u 40AO-9ZZ03 Crosstie EW to 40A-9ZZ1 7 N N

CD TCA-68 supplyloads priority NC 10 minutes Simulator 40OP-9EWO1 Ops UFSAR 18.1l.K.3.25 CD 40OP-9EW02

-rh 0~

Operator Aid X

Note: 4-u The following Time Critical Actions (TCA-69 through TCA-83) are associated with PRA for all risk significant operator time critical C)

CD 0) actions where the significance is defined as a Risk Achievement Worth (RAW) that increases the risk factor by greater than or equal to 1.3) 0 M.

TCA Action Time Limit Validation Method Procedure Performing Organization Source Document (other info) z"0 13-NS-B062, Z cn 0)

Align AFN from 1AFN-NOMFW-HR a 40EP-9EO02 (exchanges with Z

the Control C TCA-69 Room following 75 minutes Simulator 40EP-9EO01 Ops 13-NS-C054 Main Feed Pump 1AFN-NOMFW-FHR 0 trip [post fire]) r-CD CRAI 3343684 0

Direct an AO to the MSSS for manual control 40EP-9EO06 13-NS-B062 TCA-70 of FWIVs 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> JPM (Std App 43) Ops 1AF-FWIV-2HR Cn following loss of CRAI 3343684 IA and N2 backup.

Equalize RCS -I with pressure ofafceSG40EP-9EO04 13-NS-B062, 0 Z 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Simulator 40P9O4Ops 1 SG-DPRSE-ST-S-P EST TC-1 affected SG TCA-71 pressure prior to 40EP-9EO09 2HR cc)

Wu m 0

overfill (single CRAI 3343684 tube rupture). 3I Locally align AFA-P01 after 40EP-9EO06 13-NS-B062, 1AFA-TCA-72 recoverable start 75 minutes Simulator (Std App 40) Ops NOMFW-HL zZ failure (MFW CRAI 3343684 0 unavailable) 13-NS-B062, 1AFN-TCA-73 Align AFN (MFW available) 300 minutes Simulator 40EP-9EO02 40EP-9EO01 Ops MFW-HR CRAI 3343684 a0 Z

Isolate RWT 13-NS-B062, C TCA-74 following small 3.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Simulator 40EP-9EO03 Ops 4RWT-RAS-S-2HR break LOCA CRAI 3343684 r-z Initiate 13-NS-B062, emergency 1EMBORAT-SROD-TCA-75 boration with 10 minutes Simulator 40EP-9EO09 Ops HR stuck CEAs CRAI 3343684 N 1>

(ATWS) CD N Align AFN to 40EP-9EO06 13-NS-B062, 1AFN- 00 0 Co TCA-76 backup control 75 minutes Simulator (Std App 41) Ops CPWR-HL "h unavailable) 40EP-9EO09 CRAI 3343684 (0

Isolate SG for 13-NS-B062, 1SG- C) 0)

TCA-77 SGTR - single 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Simulator 40EP-9EO04 Ops OVRFL-ST- 2HR tube CRAI 3343684 01

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info)

Z Depressurize SG G) and supply 40EP-9EO06 13-NS-B062, Cn TCA-78 alternate water 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Simulator (Std App 44) Ops 1ALFW-MWF-HR Z source (Loss of 40EP-9EO09 CRAI 3343684 C All Feedwater) H 0i-2 Initiate a CD cooldown and C~)

equalize RCS 13-NS-B062, 1SG- ~1

0 TCA-79 with pressure of 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Simulator 40EP-9EO04 Ops DPRSE-MT-2HR C) affected SG CRAI 3343684 0)

(SGTR -multiple tubes) 0 0

Depressurize / 13-NS-B062, 1RC- Cn TCA-80 cooldown RCS 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> Simulator 40EP-9EO03 Ops SBLOCA-L-2HR after SBLOCA CRAI 3343684 0 Z Align LPSI for 13-NS-B062, TCA-81 SDC (SGTR w/1 0-tube 6.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Simulator 40EP-9EO04 (Std. App 23) Ops 4SDCPROC-OP-2HR

-u

-I 0

rupture, SLOCA CRAI 3343684 (0 z

~1 or SLB) CRAI_3343684 0) 171 Cooldown / 13-NS-B062, 1SG- 2 0 I-TCA-82 depressurize with 3 tubesSG 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Simulator 40EP-9EO04 Ops OVRFL-MT- 2HR CRAI 3343684 ruptured 0 X

Locally align 13-NS-C054, Z AFA after 1AFA-NOMFW-FHL TCA-83 recovered start 75 minutes JPM 40EP-9EO06 (exchanges with 13-failure (MFW (Std App 40) NSB062, unavailable - 1AFA-NOMFW-HL) post fire) CRAI 3343684 V Notify the V 0 z Containment CD C Coordinator for 70DP-0RA01, =3 ,-u containment 40EP-9E011 Shutdown Risk X TCA-84 equipment hatch 5 minutes Simulator (Std App 249) Ops Assessments 0 N closure following CRDR 3395762 N loss of Shutdown 0) cooling with the CD RCS breached.

(0)

CD 0 (0) 0 CD h

-h 0 01 C 0

TCA Action Time Limit Validation Procedure Performing Source Document Method Organization (other info)

Isolate NC system TC-5 from a snlue40AO-9ZZ04 40EP-9EO03 13-JC-NC-0200 (supports UFSAR TCA-85 single RCP HP 16.67 minutes Simulator 40A-9ZZ0 Ops9.2.2.2.9 seal cooler tube 40AO-9ZZ02 9.2.2.2.9) C leak (double 40AL-9RK4A CRAI 3478703 3 ended shear) I-CD

'ii 0

0) 0)

C) 0 x

-l 17, CD 0 0,-P 0 x h N0 N

N 0

0 (D

CD 0 0 0) 0 5l.

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 38 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix E Page 1 of 2 Appendix E - Manual Component Manipulation Times NOTE This appendix provides a place to record cycle times for components listed in calculation 13-MC-FP-0316, Appendix A, Manual Actions List, Time to Operate column.

E.1 List the component EQID in the EQID column.

E.2 List the component nomenclature in the SSC Description column E.3 From Appendix F - Manual Manipulated / Timed Component List, determine the required final condition of the component from the Cycle Position column, and insert into the Required Manipulation column. (Ifa valve is required to be stroked both open and closed, list each cycle individually.)

E.4 From Appendix F - Manual Manipulated / Timed Component List, determine the required time for the component manipulation from the Time to Operate column and insert this value into the Calc Time to Operate column.

E.5 Note the "As Found" position in the As Found Position column.

E.6 Perform the Required Manipulation and note the actual cycle time.

E.7 Record the actual cycle time in the Cycle Time column and record the date performed.

E.8 Place the component in the "As Found" position.

E.9 Perform Independent Verification per 02DP-OZZ01, Verification of Plant Activities.

E.10 If the actual Cycle Time is less than the required Calc Time to Operate value, then no action is required. If the Cycle Time is greater than the required Calc Time to Operate value, then corrective action should be pursued, including consideration of component rework and updating the calculation.

E.11 Store current records and related documentation in the department files and in an online folder for at least five (5) years.

(Sample) z z

a

=i 3

CD CO) 0 0

CD 3 z z

CD 0

N N

CD CD 0 (0

N)

(0 ;0 GA) 5<.

X*

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 40 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 1 of 7 Appendix F - Manual Manipulated / Timed Component List F.1 This is a list of the components identified in Calculation 13-MC-FP-0316, 10CFR50 Appendix R Manual Action Feasibility, Appendix A, Manual Actions List, and their associated Cycle Position and Time to Operate.

EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE NCN-V049 RC SAMPLE COOLER AX-9 INLET Open 1 minute NCN-V054 RC SAMPLE COOLER AX-9 OUTLET Open 1 minute DGA-VO04 JACKET HEADER WATER MAKEUP ISOLATION Open / Close 1 minute JACKET WATER MAKEUP DGA-V024 FROM CONDENSATE Ensure Open 1 minute TRANSFER DGA-V058 JACKET HEADER WATER BACKUPMAKEUP FILL Open 1 minute DGA-V063 JACKET WATER MAKEUP Ensure Open 1 minute SUPPLY VALVE DGA-V013 JACKET WATER MAKEUP HDR ISOLATION Open / Close 1 minute JACKET WATER MAKEUP DGA-V025 FROM CONDENSATE Ensure Open 1 minute TRANSFER DGB-V059 JACKET BACK WATERUPMAKEUP FILL HDR Open 1 minute DGB-V064 JACKET WATER MAKEUP Ensure Open 1 minute SUPPLY VALVE FPN-V925 HOSE STATION RACK ASSEMBLY

1. 108 ISOLHOSE Open 1 minute B

CLASS 4160V SWGR CUBICLE Manually charge PBB-S04B FEEDER FROM DIESEL GEN B spring and close 1.5 minutes breaker AUX FEEDPUMP AFA-POA AFA-HV-32 FLOW CONTROL VALVE TO Close 5 minutes S/G #1 AUX FEEDPUMP AFA-P01 AFA-UV-37 FEED ISOLATION VALVE TO Close 5 minutes S/G #2 AUX FEEDPUMP AFB-P01 AFA-HV-31 FLOW Close 5 minutes CONTROL VALVE TO S/G #2 AFB-UV-34 AUX FEEDFEEDPUMP ISO VLV TOAFB-P01 S/G #1 Close 5 minutes

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 41 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 2 of 7 EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE AUX FEEDPUMP AFB-P01 AFB-UV-35 FEED ISOLATION VALVE TO Close 5 minutes S/G #2 AUX FEEDPUMP AFA-P01 AFC-HV-33 FLOW CONTROL VALVE TO Close 5 minutes S/G #2 AUX FEEDPUMP AFA-P01 AFC-UV-36 FEED ISOLATION VALVE TO Close 5 minutes S/G #1 CHB-HV-255 SEAL INJECTION CONTAINMENT ISOLATION Open 2 minutes CHB-HV-530 RWT TO TRAIN 'B' SI PUMPS Open 15 minutes SUCTION CHE-HV-536 GRAVITY TO CHARGING FEEDSUCTION PUMPS Open 3 minutes CHB-V319 CHARGING PUMP 2 SUCTION Close / Open 1 minute ISOLATION CHB-V327 SI TIETRAIN 'B' SUCTION TO CHARGING VALVE HEADER Open 1 minute CHB-V756 CHARGING PUMP SUCTION Open 1 minute CROSS-CONNECT CHN-UV-501 VCT OUTLET Close 3 minutes CHA-V316 CHARGING PUMP 1 SUCTION Close 1 minute ISOLATION CHA-V755 CHARGING PUMP SUCTION Open 1 minute CROSS-CONNECT EWA-UV-145 NC SUPPLY ISOLATION VALVE Close 15 minutes (EW TO NC X-TIE)

Close 15 minutes EWA-UV-65 VALVERETURN NCWS (EW TO ISOLATION NC X-TIE)

EWB-HCV-146 (EW TOISOLATION NC SUPPLY NC X-TIE)VALVE .Open / Close 3 minutes EWB-HCV-66 VALVERETURN NCWS (EW TO ISOLATION NC X-TIE) Open / Close 3 minutes NCA-UV-402 ISOLATION SUPPLY NC CONTAINMENT Open 5 minutes NCA-UV-401 NC CONTAINMENT SUPPLY Open 5 minutes ISOLATION NCA-UV-99 ISOL VLV NCWS RETURN Close 5 minutes RCE-UV-430 RCP "IA" CONTROLLED BLEEDOFF ISOL VALVE Close 2 minutes RCE-UV-431 RCP "lB" CONTROLLED BLEEDOFF ISOL VALVE Close 2 minutes RCE-HV-432 RCP "2A"CONTROLLED Close 2 minutes RBLEEDOFF ISOL VALVE

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 42 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Append',x F Page 3 of 7 EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE RCE-HV-433 RCP "2B" CONTROLLED BLEEDOFF ISOL VALVE Close 2 minutes SGA-HCV-179 SGB-HV-179 EQUALIZING ACTUATOR VALVE Unlock & Open 1 minute SGA-HV-179 STEAM GENERATOR ATMOSPHERIC DUMP#2 VALVE LINE 2 Open / Close 4 minutes ADV-179 ACCUMULATOR SGE-V337 SGA-X01B LP NITROGEN Unlock & Close 1 minute ISOLATION VALVE SGN-V349 INSTRUMENT SGN-F03A BYPASS AIR FILTER VALVE Ensure Closed 1 minute SGN-V966 INSTRUMENT SGN-F03A AIR FILTER OUTLET VALVE Close 1 minute SGA-HCV-184 SGA-HV-184 ACTUATOR Unlock & Open 1 minute EQUALIZING VALVE SGA-HV-184 STEAM GENERATOR #1 LINE 1 ATMOSPHERIC DUMP VALVE Open / Close 4 minutes ADV-184 ACCUMULATOR SGE-V342 SGA-X01A LP NITROGEN Unlock & Close 1 minute ISOLATION VALVE SGA-UV-134 S/G AUX#1FEEDSTEAM PUMPSUPPLY AFA-P01TO Close 3 minutes SGA-UV-138 SAUX

/ G #2 STEAM FEED PUMP SUPPLY AFA-P01 TO Close 3 minutes ADV-184 ACCUMULATOR SGB-HCV-178 SGA-X01A LP NITROGEN Unlock & Open 1 minute ISOLATION VALVE SGB-HV-1 78 STEAM GENERATOR ATMOSPHERIC DUMP#1VALVE LINE 2 Open / Close 4 minutes ADV-178 ACCUMULATOR SGE-V354 SGB-X01B LP NITROGEN Unlock & Close 1 minute ISOLATION VALVE SGN-V353 INSTRUMENT SGN-F02A BYPASS AIR FILTER VALVE Ensure Closed 1 minute SGN-V964 INSTRUMENT AIR FILTER Close 1 minute SGN-F02A OUTLET VALVE SGB-HCV-185 SGB-HV-185 EQUALIZING ACTUATOR VALVE Unlock & Open 1 minute SGB-HV-185 STEAM GENERATOR ATMOSPHERIC DUMP#2 VALVE LINE 1 Open I Close 4 minutes SGE-V363 ACCUMULATOR SGB-X01A Unlock & Close 1 minute ISOLATION VALVE SIA-UV-634 SIT "'IA"OUTLET VALVE TO RC Close 15 minutes LOOP "1A" SIA-UV-644 SIT "1B" OUTLET VALVE TO RC Close 15 minutes LOOP "1B1" 1

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 43 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 4 of 7 EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE SIA-UV-672 CNTMT TO SPRAY SPRAY A DISCHARGE HEADER 1 VALVE Close 15 minutes SIB-HV-307 LPSI TO SDHXVALVE'B' BYPASS Throttle 25 minutes SIB-HV-658 SDHX 'B' OUTLET2A/2BTO RC LOOP Throttle 5 minutes SIB-HV-689 CS PUMP 'B' DISCH

'B' TO SDHX Close 15 minutes SIB-HV-690 SD CLG LOOP 'B' WARMUP Open! Close 15 minutes BYPASS VALVE SIB-HV-692 LPSI PUMP 'B' SUCTION VALVE (RWT) Close 15 minutes SIB-HV-693 CNTMT SPRAY TO SDHX 'B' Close! Open 15 minutes BYPASS VALVE SIB-HV-694 LPSI TO CS XTIE TRAIN 'B' Open 15 minutes SIB-HV-695 LPSI/CS TO SDHX 'B' X-TIE Close 15 minutes SIB-HV-696 CS "B"CROSSCONNECT Open 15 minutes SIB-UV-614 SIT "2A" OUTLET VALVE TO Close 15 minutes LOOP "2A" SIB-UV-624 SIT "2B" OUTLET VALVE TO Close 15 minutes LOOP "2B" SIB-UV-615 LPSI 'B' TO RC LOOP 2A Open 15 minutes SIB-UV-625 LPSI 'B' TO RC LOOP 2B Open 15 minutes SIB-UV-652 B TRAIN FROMSDCRCSUCTION LOOP 2VALVE Open 15 minutes SIB-UV-656 S/DISOLATION CLG CONTAINMENT LOOP 2 Open 15 minutes SIB-UV-668 LPSI "B"TO THE ISOLATION RWT VALVE Close 1 minute SIB-UV-671 CS PUMP "B" FLOW CONTROL VALVE Close 15 minutes SIC-UV-653 SHUTDOWN COOLING LOOP 1 SUCTION FROM VALVE Open 15 minutes AFA-K0l AUXILIARY PUMP TURBINE FEEDWATER GOVERNOR Trip Aux FW Pump Turbine 12 seconds AFA-HV-54 AUX FEEDPUMP AFA-P01 TRIP Close / Open 5 minutes

& THROTTLE VALVE AFA-V084 AFN-PI-020 ROOT VALVE Open 1 minute AFN-PI-20 AFN-PI-20 INSTRUMENT Inst. Isol. ISOLATION Open 1 minute (un-numbered)

CLASS 1E 480 VAC PGA-L31C4 LOADCENTER FOR Open & Rack Out 1 minute CHARGING PUMP 1

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 44 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 5 of 7 CYCLE TIME TO EQID DESCRIPTION POSITION OPERATE CLASS 1E 480 VAC PGB-L32C4 LOADCENTER FOR Open & Rack Out 1 minute CHARGING PUMP 2 CLASS 1E 480 VAC PGA-L35C3 LOADCENTER SOURCE ALTERNATE TO TRANSFER SW Open & Rack Out 1 minute FOR CHARGING PUMP 3 PGB-L36C2 480 VAC LC CUBICLE FOR Open & Rack Out 1 minute PUMP CHE-P01 CTA-V056 CNDS SPLY ISOL TK ATO ECW EXP Ensure Open 1 minute ECA-V040 EXP TANK LEVEL CONT VLV Close 1 minute OUTLET ISOLATION ESSENTIAL CHILLED WATER ECA-V166 EXPANSION TANK BACKUP Open 1 minute FILL CONNECTION ECA-V174 EXPANSION CONTROL VALVE LEVEL TANKBYPASS Open / Close 1 minute FPN-V595 HOSE STATION RACK ASSEMBLY

1. 86 ISOL HOSE Open 1 minute CTB-V057 CNDS SPLY ISOL TK BTO ECW EXP Ensure Open 1 minute ECB-V061 EXPANSION TANK LEVEL Ensure Open 1 minute CONTROL VALVE INLET EXPANSION CONTROL VALVE TANKOUTLET LEVEL Close 1 minute ECB-V062 ECB-V175 EXPANSION TANK LEVEL Open / Close 1 minute CONTROL VALVE BYPASS ECW EXPANSION TANK ECB-V545 ECB-TO1 BACKUP FILL Open 1 minute CONNECTION FPN-V596 RACK ASSEMBLY HOSE STATION #87 ISOL HOSE Open 1 minute EWA-V104 FILL LINE REG. UPSTRM Ensure Open 1 minute ISOLATION VALVE EWA-V105 FILL LINE REG DOWNSTREAM Close 1 minute ISOLATION VALVE EWA-V150 EW 'A' SURGE TANK ISOLATION SUPPLY FM (CT) Open 1 minute

_pen_1_minute EWA-V181 SURGE TANK FILL LINE REG DRAIN Open 1 minute EWA-V222 SURGE TANKBYPASS REGULATOR 'A' FILL Open / Close 1 minute FPN-V548 HOSE BACK ASSEMBLY HOSE Open 1 minute STATION #39 ISOL EWB-V108 FILLISOLATION LINE REG.VALVE UPSTRM Ensure Open 1 minute

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 45 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 6 of 7 EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE EWB-V109 FILL LINE REG. DOWNSTREAM ISOLATION VALVE Close 1 minute EWB-V152 EW 'B' SURGE TANK SUPPLY Open 1 minute ISOLATION FM (CT) Open_1_minute EWB-V185 SURGE TANKISOL FILL LINE DRAIN VALVE Open 1 minute EWB-V225 SURGE TANK BYPASS REGULATOR 'B' FILL Open / Close 1 minute FPN-V547 HOSE RACK ASSEMBLY HOSE Open 1 minute STATION #38 ISOL CLASS 1E 480 VAC PGA-L35C4 LOADCENTER FOR CONTROL Open & Rack Out 1 minute ROOM ESSENTIAL AHU CLASS 1E 480 VAC PGB-L34C3 LOADCENTER FOR CONTROL Open & Rack Out 1 minute ROOM ESSENTIAL AHU CLASS 1E 480 VAC PGB-L32E3 LOADCENTER PRESSURIZER BACKUP FOR Open & Rack Out 1 minute HEATERS BANK CLASS 1E 480 VAC PGA-L33D4 LOADCENTERBACKUP PRESSURIZER FOR Open & Rack Out 1 minute HEATERS CUBICLE FOR PRESSURIZER NGN-L11C4 BACKUP HEATERS BANK Open & Rack Out 1 minute RCE-B02 CUBICLE FOR PRESSURIZER NGN-L11C2 BACKUP HEATERS DIST Open & Rack Out 1 minute PANEL RCN-DO1 CUBICLE FOR PRESSURIZER NGN-L11C3 BACKUP HEATERS DIST Open & Rack Out 1 minute PANEL RCN-D03 CUBICLE FOR NGN-L12C4 PROPORTIONAL HEATERS Open & Rack Out 1 minute BANK RCE-B05 CUBICLE FOR PRESSURIZER NGN-L12C2 BACKUP HEATERS DIST Open & Rack Out 1 minute PANEL RCN-D02 CUBICLE FOR PRESSURIZER NGN-L12C3 BACKUP HEATERS DIST Open & Rack Out 1 minute PANEL RCN-D04 AFA-V006 AUX FEEDPUMP AFA-P01 CST Close / Open 5 minutes SUCTION ISOLATION VALVE AUX FEEDPUMP AFA-P01 Unlock & Open / 5 minutes AFA-V058 RMWT SUCTION ISOLATION Close VALVE

PVNGS NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 46 of 46 Revision Time Critical Action (TCA) Program 40DP-9ZZ04 5 Appendix F Page 7 of 7 EQID DESCRIPTION CYCLE TIME TO POSITION OPERATE AFB-V021 AUX SUCTION FEEDPUMP AFB-P01 ISOL VALVE CST close / Open 5 minutes AFB-V028 AFB-P01 ISOLATION HEADER RMWT SUCTION VALVE Unlock Open &

/ Close 5 minutes CHN-V183 CHN-FSH-250 OUTLET Close 1 minute DGB-V013 JACKET WATER MAKEUP HDR ISOLATION Ensure Close 1 minute JACKET WATER MAKEUP DGB-V025 FROM CONDENSATE Close 1 minute TRANSFER DGB-V064 JACKET WATER MAKEUP Close 1 minute SUPPLY VALVE SSN-V819 SSN-HV-0015 BYPASS VALVE Open / Close 1 minute

ELECTRONIC PROCEDURE CHANGE RECORD ProcedureNo: 4CDP-9ZZ04 Revision No: 005 Category: I 2013 Tite ME CRITICAL ACTION (TCA) PROGRAM Procedure Action: MAJOR MINOR [a lDMIN. CORRECTION NEW SUPERSEDED CANCE L NAD Review Required? YES NO 0 Env Screening Req? YES NO0 Expedited? YES NC MRL Update? YES NO 0 Full Basis Check? YES NO 0L evel of Use: INFORMATION EOP? YES NO 0 PRG Concurrence Req? YES NO0 I0CFR50.59/72.48 REQ? YES NO 0 50.59172.48 DOCI APPROVALS Digitally signed by Bird, Gerard Fuccillo, Caro FDigitally N signed byCzP2403)

Fuccillo, Carol Bird, Gerard A(Z06304)

DN: cn=Bird, Gerard A(Z06304)

(ZP2403) DN: cn=Fuccillo, Carol 1 ZP2403)

Date: 2010.12.15 12:21:43 Reason: I have reviewed this dcument

-07'00' Date: 2010.12.15 12:41:53 -07'00' PREPARER - SIGNATURE DENOTES THAT DOCUMENT IS IQR REVIEWER - SIGNATURE DENOTES REVIEW READY FOR REVIEW AND APPROVAL AND PREPARER IS COMPLETION AND QUALIFIED IN SWMS AS IQR REVIEWER QUALIFIED IN SWMS AS PROCEDURE PREPARER NAD REVIEWER - (IF REQUIRED) PRG CONCURRENCE - (IF REQUIRED) - SIGNATURE DENOTES PRG CONCURS WITH REVIEWER Digitally signed by Myers, Mark Myers, Mark D(Z70391)

DN: cn=Myers, Mark D(Z70391)

Reason: I am approving [his document 1/7/2011 D(Z70391) signing for Randy Merryman Date: 2010.12.16 08:49:42 -07'00' EFFECTIVE DATE/TIME OWNER / DESIGNEE - DIGITALSIGNATURE SECURES DOCUMENT FOR TRANSMITTAL AND USE ccilo, Digitally signed

.ao:..,ooo~~ooy by Fuccillo, Carol nFci0,Crl(ZP2403)

ON:cn=Fuccillo, Carol (ZP2403)

~~DN (ZP2403) Reason: Effective date change only.

Date: 2010.1 2.16 09:28:58 -07'00'

In support of the PVNGS Nuclear Administrative and Technical Manual (NATM) Procedure Replacement Project, procedure 40DP-9ZZ04, Time Critical Action Program, has been reformatted to comply with FrameMaker 9 Structured format for Administrative Procedures. The following PCRs have been incorporated:

PCR 3510485 - Time Critical Action changed from 60 minutes to 90 minutes. Changed NHMN-1 903 to de-energize NCN-UV-99 to L35D2 to de-energize MCC M-19.

PCR 3511080 -. Removed references that do not meet criteria of permanent or non-permanent quality records Identifed in ANSI N45.2.9-1974 (or EPRI NP-5653). - * . . - , -, , -

M RE~

aEG EVQAWA 1 Applicability Determination performed by FUCCILLO*CAROL 1.1/30/2010

.The*, changes are administrative innature and.d: not establish an expanded definition 0for alter the design of the facility , nor do they alter

.hemetld of'opeirating or controling the faIty;therefor deiiinoagulat t D L17 Ar - -. furtherhrfgulatoryreview is not required Per 93DP:L17 stepý 2.1.3.

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