ML20236U139
| ML20236U139 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/20/1987 |
| From: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20236T959 | List: |
| References | |
| EOP-POM-248, NUDOCS 8712020309 | |
| Download: ML20236U139 (331) | |
Text
{{#Wiki_filter:' L COPY al . 1 l l RANCHO SECO. EMERGENCY OPERATING PROCEDURE TECHNICAL BASIS
. i for EOP POM-248 1
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i Prepared by: Procedures V Projects Superintendent i Reviewed by: [ /4/M Enager, Nucliear' Operations Dept. j Approved b r _- u_ ll 3D!D i
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Director, Operations & Maintenance 8712020309 871120 2 PDR ADOCK 050 F
,, TABLE OF CONTENTS PREFACE Introduction I-1 Background I-1 E0P Status I-1.
Format I-1 E0P Table of Contents I-3 s CONTENT COMPARISON , III (Note: .Section numbering and titles correspond to the TBD) III. Diagnosis and Mitigation l General Approach Overview / Entry Conditions; . III.A-1 A. B. Loss of Adequate Subcooling Margin III.B-1: ) C. Lack of Adequate Primary to Secondary . I Heat Transfer. . III.C-1 1 D. Excessive Primary to Secondary Heat Transfer - III.D ' E. Steam Generator Tube Rupture III.E-1 F. Inadequate Core Cooling III.F i G. Cooldown Methods III.G-1 l IV. Equipment Operation s A. RC Pumps IV.A-l' B. HPI/ LIP /DHRS/CF Operation IV.B-1 C. MFW/AFW System Operation . IV.C-1 D. Incore Therm 6 couples IV.D-1 E. High Point Vents IV.E-1 F. Containment Systems IV.F-1 j G. Reactor Vessel Pressure / Temperature Limits IV.G-1 . V. Specific Rules ; l A. HPI/ LIP Specific Rules -V.A-1 ! B MFW/AFV Specific Rules V.B-1 3 C. RCP specific Rules .V.C-1 ' i l
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i merem . . - , 3 _ _ _ _ - _ _ _ _ . _ . . _ _ _ _. _ . _ _ . . .,_.L., _ _ _ . _ . _ _
LOGIC COMPARISON FC-1 TBD Figure III.A.1 and E.01 Immediate Actions , E.02 V. ital Systems Status Verification FC III.A-1 I
- TBD Figure III.B-1 and E.03 Loss of Subcooling FC III.B-1 J
- TBD F1 8 ure III.C-1 and E.04 Loss of Heat Transfer FC III C-1 TBD Figure III.D-1 and E.05 Excessive Heat Transfer FC III.D-1
- TBD Figure III.E-1 and E.06 OTSG Tube Rupture FC III E-1' TBD Figure EV.F-2 and E.07 Inadequate Core Cooling FC III.F-1 l
C00LDOWN PROCEDURE COMPARISON CP-1
" Comparison of E0P Exit Conditipns to CP Entrance Conditions CP-2
' CP 101 CP-4 CP 102 CP-21
- CP 103 CF-24 CP 104 CI-38 CP 105 CP-47 1
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I INTRODUCTION i l This is the originsl Rancho Seco Emergency Operating Procedure i Technical Basis (RS-EOP-TB) prepared per the EOP Writers Guide l AP 2.24. l l BACKGROUND I 1 i The symptom based E0Ps were written and issued in April 1985 based on the Rancho Seco specific ATOG (ATOG). In September the l 5 B&W generic document " Emergency Operating Procedures Technical l Basis Document" (TBD) was issued which replaced _the site specific ) ATOGs prepared for each B&W utility. The TBD follows the same j basic symptom approach of the site ATOGs and includes improve-ments. developed since the site specific ATOGs were issued the 1982/1983 time. I EOP STATUS j 1 Implementation of the TBD improvements into the EOPs is being j done in a phased approach, coordinated with training and plant i operational status to assure operatot familiarity with the pro- { cedures when the plant is operating, This document demonstrates q the degree to which the procedures implement the TBD and provides the justification for TBD actions which are not implemented. A schedule (pre or post-startup) is provided for TBD actions not yet implemented. The post startup schedule is outside the scope of this document. The E0Ps, except the cooldown procedures (cps), implement the TBD unless otherwise noted in this report. The cps are based on the ATOG cps but have been revised to incorporate some TBD actions i necessary to complement TBD improvements made to the E procedures. i The E0Ps on which this basis is written are those of manual change P0M-248 dated October 1, 1987. The index showing the ! revision numbers is attached. The TBD to which this basis is ) written is B&W document 74-1152414-00 approved September'3,.1985. The ATOG to wnich the cps are compared is B&W document 74-1127469-01 , approved March 6, 1984. FORMAT Each TBD section is compared to the E0Ps with differences identi-fied. Additionally, the TBD diagnosis and mitigation section flow charts are compared to the E0P flow charts with differences identified. . i I-I i
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L________________________________ _ _ _ _ _ . _ - - _ _ . _ _ - _ - _ - _ _ _ _ _ _ - --- - - J
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l l l i i The E0P cps so closely follow the ATOG' cps that flow chart l comparisons are not made, rather a step by step. comparison is presented with differences justified. To assure the cps ) interface properly with the E procedures, a comparison'of E procedure exit conditions is made to the CP entrance conditions. 1 I l l l l 1 l j I 1 ; i D 5 l l l I-2 l
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TABLE'0F' CONTENTS POM-248 PLANT.0PERAT10NS~- EMERGENCY PROCEDURES ~ 10-01_3, - ,
' S, EMERGENCY PROCEDURES IMMEDIATE ACTIONS. Rev. 2 06-19c87-E.01 Rev. 5- 10-87.
.E.02 VITAL' SYSTEM STATUS VERIFICATION Rey. . 3 L07-10-87 .
E.03 LOSS OF SUBC00LI:4G' E.04' LOSS OF HEAT TRANSFER Rev. 7 07-10 a E.05 EXCESSIVE HEAT TRANSFER Rev, 9 07-10-87' i E.06 SGTR - Rev. 7 ' 07-10-87c Rev..:5 06-19-87: E.07 ICC , l CP.101 A LARGE LOCA HAS OCCURRED AND THE CORE FLOOD TANK.IS Rev. 4~ 06-19-87 l EMPTYING CP.102 NORMAL COOLDOWN
, Rev, 2 '06-22-87 ;
Rev.- 4 ,06-22-87 i TRANSIENT TERMINATION FOLLOWING AN OCCURRENCE THAT-CP.103 LEAVES THE RCS SATURATED WITH OTSG(S) REMOVING HEAT' , j CP.104 ~ TRANSIENT TERMINATION FOLLOWIAG AN OCCURRENCE THAT Rev. ' 4. 07-10-87 LEAVES THE RCS BEING COOLED 8Y HPI COOLING
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CP.105 TRANSIENT TERMINATION FOLLOWING AN OCCURRENCE THAT MAY Rev. ..3 06-22-87 i l REQUIRE PRESSURIZER RECOVERY SOLID PLANT CDCLDOWN WITH OTSG REMOVING HEAT AND RCS SUBC00 LED i RULE 1 INITIATION OF HPI Rev. l' 18-87 Biennial. 05-21-87 q
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RULE 2 CONTROL HPI Rev.- 3 06-22-87 RULE 3 AUXILIARY FEEDWATER l Rev. : 3 06-22-87 , RULE 4 OTSG LEVEL SETPOINT Rev. - 2 02-18-87 Bienniai- 05-21-87 RULE 6 REACTOR. VESSEL PRESSURIZED THERMAL SHOCK (PTS) -Rev. 2 06-19-87 CONSIDERATIONS
- Dj.LETEDPROCEDURES RULE 5 LPI CONTROL . Deleted 18-67 :
RULE 7 RB HYDROGEN MONITOR Deleted- 02-18 RULE 8 LOSS OF ICS POWER - CONTROL OF AF9 VALVES, TEVs-AND'ADVs Deleted 02-18-87 RULE 9 EMERGENCY B0 RATION Deleted. 02-18-87 I-3
-: _ --.A..-- _.-_-_---_____J _
I CONTENT CONPARISON i This section compares the text of the TBD (Section III, IV, JV) and E0Ps by performing a side by side presentation of the TBD octions ind EDP step numbers. The TBD is written in paragraph form, thus the listed TBD actions are paraphrases of the actual TBD text. The E0P steps implementing'the TBD-action are listed. Differences ae numbered and explained at the end of each section. The comparison sections are numbered to correspond t.o the TBD numbering system. [ l t l l l l l l l 1 i l 111-1 i
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TBD Chapter: III.A
~l TBD Section(s) 21: ENTRY CONDITIONS l
This section defines the conditions for which the E0Ps will be used. 1 E0P STEPS j TBD ACTIONS i 2.1.1 Condition Existing for Reactor Trip
- Trip has occurred . E.01 Step 2.0 1
) . Trip should have occurred . E.01 Step 2.0 l 1 2.12 Shutdown Required for SGTR '
)
. SGTR forced Shutdown . E.01 Step 1.0 l required . E.06 Whole Procedure
. SGTR causes a trip or . E.01 Stip 1.0, 2.0, heat transfer upset or 3.0 j if SGTR results from these, perform 2.2 - 2.6 + AP.23.06: SGTR is lowest first. priority.
. Refer to analysis of flowchart j III.A-1 difference #1. $
1 l 1 l l 96 III.A-1
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-TBD ACTIONS 'EOP STEPS.
<i E.01 Step 3.0L 2.1.3- ' Upsets in Heat 1Transfei above cold shutdown- .,
.- l Perform Applicable 1TB0 Sections-
. Discussion #1-I E.01lInformation Page.E.01 '
def.ines1 unexpected transients J DISCUSSION:-
- 1. The TBD does not specify.which parts of.the guidelines ~are applicable when above; cold shutdown-(and presumably below someLunspecified condition). ~ The. initial conditions are soivaried (RCS: pressure,-
temperature,'MFP. status .etc.):that!defini.tive-guidance cannot--be; written for all initial conditions'. . Operator training and knowledge of initial' conditions allow the operator to determine if- the intentL of a particular step is met. Refer to analysis 1of Flowchart III.A-1 , Difference #1. 1 DIFFERENCES: None 9 III.A-2
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TBD Chapter: III.A: TB0 Section(s)_2.2/3.1: REACTIVITY CONTROLLED? These sections treat ATWStandLassure proper shutdown margin. TBD ACTIONS E0P STEPS !
. Maintain MFW if power not ' .~ E 01 Step 2.1.1 decreasing - E.02 Step 1.0,1.1
. Borate RCS ,
. E 02 Step-1.5, 1.4.3
. Trip manually - E.01 Step 2.1, E.02 Step 1.2
. Open Breakers . E.02 Steps 1.3, 1.4.2
. Drive Rods . E.02 Step 1.5
. Borate if power is decreasing .' E.02 Step 1.5
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but all rods not in DISCUSSION: . E.02 Step 1 actions for obtaining inward rod motion for ATWS events are arranged in the order most likely.to result in fastest negative reactivity addition (rod insertion) taking into account breaker location and time to reach them. DIFFERENCES: None III.A-3
l' l'80 Chapter: III.A .. TBD Section(s) 2.3/3.2: SECONDARY INVENTORY AND PRESSURE CONTROLLED? The major important actions to assure proper inventory and pressure ' control are checked. l TBD
Reference:
V.B E0P STEPS TBD ACTIONS
. Turbine stop valves closed . E.02 Step 2.0 i
. Feedwater running back .
. E.02 Step 3.0
. Verify proper actuation of:
. Steam line break equipment . E.02 Step 5.0, 5.3
. AFW
- E.02 Step 3.4, 4.3.3,.11.0
. Proper Secondary Pressure . E.02 Step 5.0 Control !
o Proper Aux Staam Flow - E.02 Step 5.2.3 Abnormal Aux steam header pressure would indicate abnormal steam flows.
. Check for minor steam leaks . E.02 Step 5.2 such as leaking MSSVs.
. MFW Pump Trip may be required . E.02 Step 4.0 to avoid OTSG overfill, then start AFW/ check control.
. Ensure Feedwater to both OTSGs. . E.02 Step 4.0 DIFFERENCES: None
) III.A-4
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- . I TOO Ch?.oter: III.A
(' \ TBD Section(s) 2.4/3.3: PRIMARY INVENTORY AND PRESSURE CONTROLLE07 , 4 This section assures proper RCS-inventory and pressure is controlled. I 1 I TBD ACTIONS E0P STEPS
. Verify MU and Letdown properly - E.02 Step 6.0 controlled.
. E.02 Step '.0
. Verify auto actions if SFAS - E.02 Step 8.0, 9.0 initiates.
- Dif ference #1
. Ensure RCS inventory and . E.02 Step 7.0, 8.0 pressure are being properly controlled.
DIFFERENCES: None
- 1. E.02 Step 8.1.1 directs the operators to immediately take manuc1 control and open RCP seal return valves SFV-24004 and SFV-24014. ,
This action also appears throughout the E0Ps whenever HPI is initiated. Although this may be a desireable action to prevent having to secure RCPs due to seal deterioration, a justification for this action is not available. > ACTION: Revise E0Ps to delete the steps requiring the operator to reopen RCP seal return valves. IMPLEMENTATION: Pre Startup III.A-5
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TBD Chapter: III.A ( . TBD Section(s) 2.5: PLANT ELECTRICAL POWER CONTROLLED 7: This .section assures proper electric power control;so the.EOPs;can be; performed. TBD ACTIONS. E0P STEPS-E.02, Step 2.0 -
. Output Breakers . Tripped .
. Instrument' Power is ON. . E 02 Steps,12.0,-13.0 CAUTION
- prior to Step'1.0
. Use valid. instruments
- Restore power rapidly . Discussion #1'
.. Electrical Loads Properly' .. . E.02 Step _10.0-Maintained
. LOOP - Check emergency power . E.02' Step.10.0 started and supplied. Restore off-site power quickly . AP.23.06, Enc 1 8.3, Step.4.2
. Discussion #1
. . Dif f erence.'#1 - .
-1 DISCUSSION:
- 1. Restoration of power after LOOP and loss'of instrument power'is to be-done per TBD as-quickly as possible. The E0Ps E.02. Steps 10 0,12.0, 13.0 call for the plant 'to be stabilized .before . restoring power. This is done because manpower must not be' diverted f rom stabilizing the ' plant
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and assuring core cooling to restore instrument'or of fsite power. Core l protection can be assured without offsite. power and with only one train 1 of emergency power. If adequate manpower is available, AP.23.06 allows' l 1 performing applicable casualty procedures (i.e.. restoration of power) . concurrent with the E0Ps. E.01 and E.02:can;be carried'out with loss' of- i off site power. The only. equipment affact in E.01/E.02.is 1oss'of main ! feed pumps, RCPs, TBV capability.(loss of vacuum)'and loss of letdown .j (due to high temperature / loss of.CCW); however, EFIC/AFW/ADVs provide j i backup control and natural. circulation. Loss of. letdown' improves post ! trip pressurizes and response. > l III.A-6 g 1
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.i DISCUSSIONS (Continued) --
Additionally, studies have shown that E.01 and E.02 can be conducted ! properly a) without NNI power, b) without ICS power, c) with loss of_ any
. single electrical bus.
REFERENCES:
- a. SMUD to NRC letter GCA 87-040'(Andognini to Miraglia) June 2, 1987;
Subject:
Rancho Seco Nuclear Generating Station. Effects of the. December 26, 1985 Overcooling Event, Reply to l Request for' Additional Information.
- b. B'& W Report 51-1109097-00 "Re-Review 'of' P,lant Instrumentation
- and Control for IE Bulletin 79-27 DIFFERENCES:
1.' The TBD requires checking that the emergency power supplies-(diesels) s have started. E0Ps do not check they have started but do check-in E.02 Step 10.0 that the diesel busses are. energized. A{ diesel failing to ' start would result in a de-energized bus. E0Ps thus fully implement the TBD requirement. J l i
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TBD Chapter: III.A ["' TBD Section(s) 2.6: SYMPTOMS OF UPSETS IN HEAT TRANSFER EXIST? A., This section branches to other applicable TBD sections for overcooling, undercooking, or loss of SCM. : TBD ACTIONS E0P STEPS
. Loss of SCM
. E.02 Step 14 !
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. Loss of heat transfer . E.02 Step 15
. Excessive heat transfer : E.02 Step 16 i
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j DIFFERENCES: None l
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1 ( t e III.A-8 ( l
1 TB0 Chapter: III.A 7, TBD Section(sF 2.7: 'SGTR? This section branches'to T80 SGTR section and discusses recognition.
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of SGTR. TBD ACTIONS E0P STEPS-
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.. SGTR7'
. E.02_ Step 17.0
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Steam Line Rad Monitor . Guideline 4
. Air Ejector Monitors: . 'E.06 Step'1.0 .
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. SG Level Increases' - Refer'to' Analysis'of.
TBD III.E.2.1.1, 01fference #1-
. FW Flow Mismatches-
- Secondary System Chemistry
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TBD Chapter: III.A ,
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TBD Section(s) 2.8: VERIFY STABLE PLANT CONDITIONS Verification of stable plant condition is checked. TBD ACTIONS E0P STEPS
. Checks for problems not . E.02 Step 18.0 manifested as heat transfer upsets.
. Continuous monitoring of heat - Difference #1 transfer DIFFERENCES
- 1. No step is necessary to require monitoring of heat transfer conditions; this is done at all times, stressed in similar training by conducting scenarios which have sequential. equipment failures and symptoms which initially mask others.
Action: Revise AP23.06 to include TBD guidance for continuous monitoring for upsets. Implementation: Post Startup. Justification: This is a procedural enhancement to complement existing training. l i 1 i i l l i l 10
- III . A-10
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TBD Chapter: III.B :
/" TBD Section(s) 2.1/3.1: IDENTIFICATION OF LACr 0F SCM The RCS P/T relationship will indicate when a loss of SCM occurs.
i TBD ACTIONS E0P STEPS
. Loss of SCM is best' . E.02 Step 14 identified'by use of the P/T relationship .- E.02 Guideline:1
. E.02 Figure on Page E.02-14
. E.03 Figure' on Page E.03-1
- ' Operator Training DISCUSSION: ,
E.02 Step 14 directs the operator to the proper procedure E.03 " Loss of SUBC00 LING." DIFFERENCES: None
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I l i V III.B-1
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TBD Chapter: III.B' .{ TBD Section 2.2: TRIPS RCPs-All RCPs must be tripped immediately for a loss of SCM. Chapter IV.A.2.1 states that if the RCPs are not tripped within a 2 minutes ' timef rame, then reduce the number of running pump .to one per loop. I TBD
Reference:
IV.A E0P STEPS TBD ACTIONS Trip all RCPs . E.03 Step 1.0 - l
- Reduce to .1 pump / loop
- E.03 Step 1.1 DISCUSSION:
If for some reason the RCPs are not tripped within two minutes, then the TBD direction is to leave two RCPs running even though pump damage is possible. DIFFERENCES: None l i l I I III.B-2 l
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.. i TBD Chapter:
III.B TBD Section(s) 2.3/3.2: -CONTROL RCS' INVENTORY ) RCS inventory is contro11ed'by maximizing HPI flow and. isolating
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.l possible sources of RCS leaks. 1 i
E0P STEPS TBD ACTIONS i
. E.03 Step 2.0 j
- Start HPI/MU
. E.03 Step 2.0 (Rules 1 and 2) I
. Maximize HPI/LPI \
Loss of SCM~ caused by - E.03 Step 5.0'
=
l excessive overcooling?
. Refer to analysis of-Control HPI flow chart III.B-l.'
j difference 5-
. E.03 Step 6.0
. LOCA (Isolate Leaks) . No RV head: vent installed at.
Rancho Secoj ] l
. Caused by Loss of FW, Initiate . E.03 Step 2.0, 12.0 HPI Flow - Refer to analysis of T80 III.C.2.2/3.2 1
I DIFFERENCES: None l I 16 I III.B-3 l - _ _ _ . _ _ _ - _ ~ - _ _ _ _ _ _ _ - - - _ - _ - _
1 TBD Chapter: III.B' l
- i TBD Section(s) 7.4/3.3: NAINTAIN PROPER OTSG LEVELS
( When a loss of SCM exists, OTSG 1evels must-be increased to the loss
'of SCM setpoint in OTSGs which can hold pressure. ,
TBD
REFERENCE:
- III.D. IV.C. III.C TBD ACTIONS E0P STEPS
- Raise 0TSG 1evel in. pressurized . E.03 Step 3.0 OTSG(s) to " loss of SCM setpoint" . Rule 3, Step 3 and 4-
' A. . Excessive Overcooling has e E.03 Step'5.0 -l Occurred
. Refer to analysis'of TBD.III.D .
and IV.C e
. Control OTSG feeding and pressure B. -
LOCA has Occurred . E.03 Step 3.0, 12.0
- Increase OTSG 1evels to . E.04 Step 8 loss of SCM setpoint except for larger LOCAs - . Refer to' analysis of TBD Where RCS continually III.C.2.7/3.5 depressurize below SG l
pressure C. . Loss of Feedwater has . E.03 Step 12.0 Occurred.
. Refer to analysis of TBD
. Control OTSG 1evel when III.C.2.7/3.5 FW restored DIFFERENCES: None i
I I I . 'B-4 1 1
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.TBD Chapter: ' III.B' ; _. :
TBD Section(si'2.5: SUBC00 LING MARGIN RESTORE 0? Further actions will. depend on whether or not SCM is' regained. TBD ACTIONS E0P STEPS
. SCM Restored? . E.03 Step 7,0' 01FFERENCES: None ,
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.i III.B-5
TBD Chaoter: III.B . . . [~ TBD Section(s) 2.6/3.4: REESTABLISH NORMAL PLANT CONTROL This Section assumes that SCM has. been regained and returns plant components / systems to normal. ,, TBD ACTIONS EOP STEPS 1
- Throttle HPI - E.03 Step 14 .
-l
. Avoid PTS . E.03 Step'14
. Restart RCPs .. E.03 Step 16,15 ,
If' secondary side heat transfer . Loss of SCM after loss of- -) pri-sec heat transfer may is not possible (i.e., loss of FW) then only 1 RCP should be occur when HPI cooling is started initiated. 1 RCP is run'if FW is not available. Refer to analysis of TBD III.C.2.3/3.3, ! 2.7/3.5, and TBD IV.A.2.3
- Difference #1
( l Reestablish PZR Spray . E.03 Step 19 j (' .
. FW Available . E.03 Step 18 l l
E.03 Step 21, 5, 20 '
. Monitor for other symptoms .
I
- If SCM is restored during . Rule 2 Step 3 l treatment of lack of heat transfer, loss of SCM actions . E.04 Step 17.0 may be stopped
. Rule 3
. Rule 4-
. Plant Cooldown required? - E.03 Steps 9,10,11, 21, 22 III.B-6 l
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DIFFERENCES: -.
- 1. The E0Ps do not always start just one RCP if SCM was first lost, then FW was found not to be available (LOCA which depressurizes RCS with concurrent loss of FW). 'In the first case, one RCP is run.
If the i operator determines that heat transfer (i.e., FW) is lost before SCM is ! required, then E.03 Step 12.0 goes to E.04 which, with no FW available, ' gets to Step 5.0 which in 5.2.5 will result in running the RCP when SCM is regained. In the second case, two RCPs are initially started, then reduced to one If the operator { if heat input raises RCS temperature / pressure. determines that heat transfer (i.e. FW) is lost af ter SCM is reg &ined (or if FW is actually lost after SCM is regained) then E.03 Steps 7.0 and 13-16 start one RCP per loop. When the loss of FW/ heat transfer is f noted E.04 Step 20 goes to E.04. If running two RCPs adds excessive heat which cannot be removed through the LOCA, the RCS will heatup and E.04 Step 2.0 then pressurize, eventually reaching the EMOV setpoint. i goes to Step 5.0 which at 5.2.5 reduces running RCPs to one. The net result is that in either case only one RCP is run if needed to limit RCS heat input. ACTION: l Revise E.03 Step 16 to only start one RCP if no FW is available. 1 IMPLEMENTATION: j ( Post Restart JUSTIFICATION: The E0Ps currently limit RCP heat input by running only one RCP if the LOCA is not large enough to remove all heat, however, a period of two { l RCP operation may occur. The TBD guidance to run only one RCP is not mandatory, thus two RCP operation is allowed. j l ! k i l E' III 8-7
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._. _ lk TBD Chapter: III.B. .;
TBD Sectionis) 2.7: SUPERHEATED?L Loss of SCM may be the prelude to Superheated (ICC) conditions;.in the Core. This'section checks for indications of superheatLand then' - i, branches to the proper actions. , q E0P STEPS 1 TBD ACTIONS
. Superheated? . E.03. Step 8 t DIFFERENCES: None l .
l i III.B-8 _ . . . _ . _ I. _. J
q TBD Chapter: III.B .. TBD Section(s) 2.8/3.5: HEAT TRANSFER IN ONE OR BOTH OTSGs This section is a detailed discussion of the various combinations of SG heat removal and LOCA heat removal. The operator actions are to use the available OTSGs if LOCA cooling is insufficient. TBD ACTIONS E0P STEPS
- Heat transfer in one or both - E.03 Step 11, 12 I SGs, continue a saturated cooldown per TBD 3.6 . Difference #1
)
. Continue efforts to restore . Difference #3 heat transfer to the SG
{ without' heat transfer i ) . Make SGs available as a heat . E.03 Steps 9, 10. (CFT emptying sink if RCS depressurizes and cooldown rate >100*F/hr below SG pressure indicate RCS is cooling on the break and OTSGs are not required. CP.101 and 104 are branched from E.03 Steps 9 and 10 and use OTSGs as a heat sink 1 as needed.)
- E.03 Step 3 (establishes OTSG as a heat sink if needed) i i
. Restore SG cooling if RCS - E.03 Step 9 branches to CP.101 i l '
pressure and temperature ' stabilize or begin to increase . CP.101 Step 4.0 along the saturation curve i
. CP.104 Step 7
- Difference #2 l DIFFERENCES:
l 1. TBD indicates if primary to secondary heat transfer exists in at least one OTSG, then a saturated cooldown can be performed while attempts are made to restore heat transfer to the one without heat transfer. E.03, Step 12.0 branches to E.04 , Loss of Heat Transfer, if one OTSG has lost ' heat transfer. E.04 has been designed for required actions should heat transfer be lost to both OTSGs, not a single OTSG. III.B-9 - _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - a
s q DIFFERENCES (Continued) aj r
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ACTION ] Revise E.03 Step 11 to allow branching to'CP.103 if heat transfer exists in either OTSG, i.e., "If primary to secondary heat transfer exists in either OTSG then go to CP.103."' Revise Step 12.0 toi"Go to E.04" and revise the STATUS after Step 12 to delete. reference to OTSG cooling and revise the status after Step 11 to refer to cooling with one or both SGs. IMPLEMENTATION: Pre-Startup , 3 1 a
- 2. If RCS pressure and temperature stabilize or increase along the saturation curve af ter going to CP.104, . Step 7 will not provide proper action. The operator will go to Step 8 which branches to CP.103 Step' B which assumes the RCS continues to depressurize. j l
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ACTION . s Revise CP.104 Step 7 to include the case of a saturated cooldown.on OTSGs after initially not needing 0TSGs. Add 7.3, "The RCS is saturated' l ! and RCS pressure and temperature stabilize or. start to increase along the saturation curve THEN go.to Step 9.0. Status HPI cooling initially I provided core cooling but leak rate is now too' low and OTSG cooling is, required." ; 1 IMPLEMENTATION Pre-Startup ,
- 3. The TBD action to continue efforts .to restore heat transfer to the one i' SG without heat transfer when on natural ~ circulation is an enhancement over ATOG and is optional. This action mainly consists of RCP bumps l
since steam side conditions (SG 1evel/ pressure) have been established i earlier. This action in general has not been incorporated into E0Ps i (except in E.06 SGTR) because it is not clear it is warranted. l Simulator experience has shown that bumping pumps in the idle loop interrupts natural circulation for a time in the operating-loop. MIST tests have noted similar results. When additional information becomes l I available in future TBD revisions, this issue will be reconsidered. E.06 SGTR includes action to remove idle loop voids (Step 22) and to promote natural circulation (Step 16) because to aid prompt plant cooldown. i i III . 8-10 l l l i c___--_________-_____________-_____ _ - _ _ _ . _ _ _ _ _ _ - - - _ _ _ _ .. --_-.a
l l TBD Chapter: _[1I,8 TBD Section(s) 2.9/3.6: SATURATED C00LDOWN WITH SG(S) OTSG cooling The RCS is saturated and HPI is providing core cooling. will be cyclic. CFTs remain available. TB0
REFERENCE:
IIIC E0P STEPS ! TBD ACTIONS !
. E.03 Step 11.1 ;
. Saturated Cooldown
. CP.103 St'ep 1.1 j
. HPI Flow murt be maximum i
l
. Maintain OTSGs operable . CP.103 Step 1.2 i
. SCM may be restored . CP.103 Step 6.0 l j l l
l - Must maintain CFT isolation l open until:
. Sufficient LPI flow exists . CP.103 Steps 3.0,10 f
/
- SCM is restored (may close . Difference #1 CFT valves) ,
. Natural Cire blocksge may occur . CP.103 Steps 4.4, 5.0 l
- CP.104 (From CP.103 Step 5)
DIFFERENCES:
- 1. Starting f rom CP.103, if SCM is restored not all procedure flowpaths isolate the CFTs when allowable. CP.103 Steps 7 and 9 branch to CP.105 if SCM is restored. From there,
- a. Path 1 . CP.105 Steps 1, 2, 3, 4, 5 to
. CP.102 Steps 1, 2 to
. B.4 Section 5 or 6 - Both isolate CFTs T3 III.B-11
7-r: DIFFERENCES -(' Continued)- -- S. Path 2 . CP.105' Steps 1,. 2, 3, 4, 7, 8 to' (
.s ,
- B.4 Section 5 or'6'- Both' isolate CFTs
- c. .P,ath 3 . CP.105 Steps 1, 2, 3, 4, 7, 8 to ' -
. CP.103 Step 11 - END ,- No. CFT isolation -
d.- Path 4 . CP.105 Steps 1, 2. 3, . 4, . 7, 8.then the same as- paths 2 or 3 from step.8. , ACTION: Revise CP.105 to direct closure of CFT isolation valves:when SCM is l restored .if regained before CFTs dump, similar to CP.104 Step 6 . IMPLEMENTATION: Pre-Startup. (Failure to isolate CFT could prolong cooldown, which must be avoided for a SGTR which could be the initiating event.)
%b III .B-12 L__.-_--______________________________.______ _ _ _ _ _ _ _ _ J4
-- I q^
TBD Chapter: III.B' .__ l^ TBD Section(s) 2~ 10/3.5:
. RC CONTINUES TO COOL INO DEPRESSURIZE BELOW SGs
. If the'.RCS is cooling on HPI/ Break f' low, then continue. If-HPI/ Break flow is: not sufficient to provide core cooling; then OTSG heat
~
removal is: necessary. - TBD Sections 111.8.2.10/3.5 are fully analyzed earlier under. III.B.2.8/3.5.
't i
l l Ll J
.l i
- 'l
( .1 i 1 i i l
- i i
- III . B ,
S
TBD Chapter: III.B TBD Section(s) 2.11/3.7: COOLDOWN ON BREAK /HPI FLOW This section discusses a SBLOCA whdre Break /HPI Flow is sufficient to provide Core Cooling. OTSGs are not required for core cooling. TBD
REFERENCE:
IV.6 E0P STEPS TBD ACTIONS _
. OTSGs are NOT necessary E03 Step 9.and 10 1
. Cooling on break /HPI Flow E03 Step 9 and 10 branch to CP.101 and 104
- If the RCS reheats, OTSGs . Refer to analysis of TBD -
III,8.2.8/3.5. " Restore SG must be established as a heat sink. cooling if RCS' pressure and temperature stabilize or bagin to increase along the ; saturation curve." l l 1 DIFFERENCES: None l l 1 i i i l 1 l l III . 8-14 l
i Jy0 Chaoter: III.8
, TBD Section(s) 2.12- COWOITIONS ESTABLISHED FOR TRANSITION TO LPI/0HR-This~is a decision point checking for possible: change'in plant
i conditions during saturated cooldown before LPI or LPI/DHR cooling can be initiated,' i.e., the plant stabilizes above- the LPI: or LPI/0HR cut in pressure due to loss of saturated OTSG heat transfer or loss > i of adequate break-HPI cooling. To continue cooldown, OTSG heat 4
]
transfer must be restored. ;i 1 4 m E0P STEPS l TBD ACTIONS If on saturated cooldown, RCS . Discussion 41 'l
- 1 pressure / temperature cannot reach LPI-LPI/DHR cut in pressure, '
then restore heat transfer. SCM , ! may be regained. 1 DISCUSSION #1:
- 1. TBD Step 2.12 is a decision point that ' xamines e whether conditions 1are 3 established for DHR operation. If not, .the operator is directed back to - -i 1
l the.beginning of, the cooldown process in order to re-examine' plant l conditions and, if possible, take advantage of any: changes -in plant d I conditions that may provide for a-more normal cooldown. This aspect of ] ( continual surveillance ie, implemente6 philosophically ratherithan procedurally within the E0P's since it has a much broader application-than just the E0P's. Continual surveillance of plant / equipment ?, conditions during all aspects of plant operation is stressed during-initial operator training and is routinelyLreLinforced during simulator l training. In addition, procedure format used in the'EOP's, as well as -l d other plant procedures, indicates'to the operator that certain: procedure _ steps are not simply a ' snapshot' check of some specific' condition, but _ an item that may require future action if conditions change. l DIEEERENCES: None l s i j 1 i
\
l l 16 : ( III .B-15 l
TBD ChaDter: III.B i I TBD Section(s) 2.13 /3. B : INITIATE LPI/DHR COOLING t This section L rovides guidance regarding transition to LPI/DHR cooling and several factors for consideration on LPI/DHR cooling. I TBD
REFERENCE:
IV.B _
\
TE*, ACTI.ONS ,, E0P STEPS , l Verify proper operation when . Refer to ana'iysis of TBD { IV.8.3, IV.B.7. ! LPI actuated !
. LPI switch to RB Sump l
. HPI/LPI piggyback l
t j
. When RCS pressure decreases to LPI discharfle pressure
- should verify LPI flow - Difference #1
- May terminate HPI/LPI - CP.101 Step 6.0 {
piggyback when LPI flow - CP.103 Step 13.0 l, is adequate !
.' Close CFT isolation valves . Refer to analysis of TBD !
i when LPI flow is adequate IV.S.S.2.
- (
1 I
- With RCS saturated:
I
- Both LPI trains should . CP.101 Step 12.5 1 remain operating in . CP.103 Step 18.0 !
injection mode
. If SCM restored, one LPI may . Refer to analysis of TBD be switched to DHR mode. IV.B.4.2.1.
. If SCM is subsequently . Difference #2 lest, both LPI trains must be placed back in Injection mode.
k III .B-16 1 i l m.._
Tg0
REFERENCE:
IV.B , _ _ _ _ _ e TBD ACTIONS E0P STEPS
. Take actions to prevent . Refer to analysis of TBD Boron precipitation. IV.B.6.
. Periodically sample LPI . CP.101 Steps 12.8,12.9 (f rom 1 cSolent for pH and Boron CP.103 Step 20)-
after suction is transferred to RB sump.
. Shoula adjust' chemistry - Difference #3
> CP.101 Step 12.9 and preceding note.
l . If Boron is low, should . Difference #4 verify proper lineup to prevent precipitation.
- If Boron is low, check . CP.101 Step 12.8.1 f'or possiblo leaks into . Difference #4 RB that may be diluting RB sump water.
l .D_LFEERENCES
- 1. E0Ps do not specifically direct verification of LPI. flow when RCS pressure reaches LPI discharge pressure, rather, this is accomplished by training, particularly 522:lator exercises. Steps which close CFT 1 valves and which terminate HPI require checking LPI flow, thus the operator is aware of the need to check LPI flow and will look for it to start as RCS pressure drops as a prerequisite to CFT/HPI termination.
For the reasons noted and since this is not a mandatory action, it is ; not included in E0Ps.
- 2. With both LPI/0HR tystems operating (one in DHR mode) and SCM is lost, E0Ps (CP.103 Steps 16.0 and 19.5) do not place both systems in the LPI mode.
ACTION Revise CP.103 Step 18.6 to include a substep 18.6.1 to return the A DHR system'to LPI mode if SCM is lost. Revise CP.103 Step 19.0 to align both systems in LPI mode. IMPLEMENTATION Pre-Sta rtup II I . B-17 1
, i
.. 1, j
DIFFERENCES:- (Continued) r 3. Procedures do not explicitly direct addition of Boron to correct for low-Boron concentration,' however, .it is strongly implied. that proper Baron ll concentration must be maintained. Additionally, if Boron precipitation 1 j is suspected, careful consideration must be given to addition:of Boron, ; it should not be an automatic action. ACTION Revise CP.101. Step 12 to includs guidance regarding maintaining LPI l Boron concentration. ' IMPLEMENTATION y Post Startup , JUSTIFICATION . This is a procedural enhancement to strengthen the guidance for LPI' ] Boron control, . 4 .- Checking for proper anti Boron precipitation lineup' if. Boron concentration drops is an~ expected standard operator. response, thus is... 4 not specifically called'out. Operators are trained, particularly at the l simulator and classroom diagnostics training, to f ully investigate all I possible causes of unexpected' responses. tiso, Boron precipitation !
.would be slow and standard diagnostic investigations would be timely.
Note, however, that CP.101 Step 12.0.1 does explicitly direct the 3 operator to-look for possible leaks which may dilute the R8 Sump. In y] this case, it was considered prudent to be explicit because dilution could occur faster than Boron precipitation and'more rapid operator l investigation is warranted. I i l : III . B-18 ; E1.-____.________________. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
t-- i TBD Chapter: III.C ' - ...i
.l TBD Section(s) 2.1/3.1: IDENTIFICATION OF LACK OF ADE00 ATE /'
, _ PRIMARY TO SECONDARY HEAT TRANSFER-i TB0
REFERENCE:
II.B E0P STEPS-TBD' ACTIONS .1
. If inadequate heat' transfer . E.02 l
'l occurs,-the P-T. relationship . ' Step 15 .
provides the.most obvious' -Guideline 2-indication.
- E.04 Page E.04 (diagram). '
.I i
* ]
DIFFERENCES: None 1
'l
.l l
1 ( l 1
)
I i
' ;i l
' III.C-1 ,
i l
- 1. l 4' ________.______.______O
TBD Chapter: III.C TBD Section(s) 2.2/3.2: HPI COOLING REQUIRED? This section addresses the situation when HPI cooling is required, , the criteria for initiating it, and the use.of the EMOV during HPI .l. cooling. . t TB0
REFERENCE:
IV 8 h TBD ACTIONS E0P STE~PS k
- Operator continually monitors . E.04 Steps 2, 9, 15 ;
RC and SG conditions to . Rule 1
- determine if HPI cooling is required. I
\
/
. If feedwater is available and . E 03 Steps 1, 2, 3, 12 (loss of !
the RCS is saturated and no subcooling, no RCPs OTSG level, j l RCPs are operable, HPI no heat transfer, branches to 1 l I l cooling is required if primary E.04) to sec.ondary heat transfer is not established after making
- E.04 Steps 1, 4, 7,10,11, 5 i the SG a heat sink per (40-60* delta T chosen to TBD III.C.2.7. implement TBD requirement of
" About 50" . ) ;
- SG at ECC setpoint.
I - Refer to Analysis of Flowchart l TBD III.C-1, Difference l l l
- SG pressure reduced so that Tsat is less than incore T/c's by 50*F. ]
l
. FW is not available, HPI + E.04 Step 2 l cooling is required: Rule 1 l
- As soon as RC inventory l
starts to be lost (i.e., when EMOV opens at 2450 psig).
. RC pressure > RV P-T
. E.04 Steps 2, 9 limit or PTS limit.
- Continually monitor for . E.04 Step 2 ,
conditions to initiate i HPI cooling, i DIFFERENCES: None ( III.C-2 i j
.~ .
T!D Chaoter: IIf.C Tg') Section(s) 2.]/3,3: ESTABLISH HPI COOLING This section describes the actions to establish HPI cooling and operation of other plant equipment durfng HPI cooling such as RCPs and pressurizer heaters. - TBD
REFERENCE:
IV.G. V.A. III.G. IV.B TBD ACTIONS 'EOP STEPS
. Two HPI' pumps are started or . E.04 Step 5.2'and 5.2.2 SFAS 1 A/18 open the BW3T verified operating with- -
suction from the BWST at full suction valves flow for existing RC pressure . Rula 1 ,
. If no HPI pumps start, . . Caution prior to:E.04 Step 5.0.
do not open [EMOV). .
. Discussion 1 - If flow from only one . E 04 Steps'5.2.3, 5.2.4 HPI pump starts, then - (EMOV is always opened except the EMOV must be opened.- if no HPI/MU pumps start.) . The operator can open the . E.04 Steps 5.2.3, 5.2.3'.4,.2, EMOV immediately or he 4, 9, 11, 15. (If heat can let the increase in transfer is not restored, E.04 RC pressure to open the branches to Step' 5 to initiate
[EMOV). HPI cooling and open'the EMOV even if RC pressure has not reached the EMOV setpoint, thus giving -the' operator the option to open the EMOV)..
. If PTS is applicable, EMOV may . E.04 Steps 2, 9
.need to be opened to avoid PTS prior to reaching EMOV setpoint.
e i III.C-3
1 I
~
.e E0P STEPS.
TBD ACTIONS , g
. If the EMOV is not' opened. . E.04 Step 5.3 HPI. flow must not be
. Difference:1 throttled until incore T/C's .
i begin to cool down and SCM exists. .This supercedes - the HPI throttling criteria based solely on SCM. , l
. .I
. E.04 Step 5.2.5
. At least one RCP should be left running as long as SCM is maintained to provide thermal mixing.
. Only one RCP should be'used 3 to limit additional heat input.
. Turn off all PZR heaters. E.04 Step 5.2.6 DISCUSSION: ,
- 1. If HPI is initiated due to reaching the PTS limit or.RV cooldown P-T
' limit, then the EMOV Block Valite and the EMOV are opened, prior to initiating SFAS Channels 1A and 18 (E.04 Step 5.1). This sequence .
allows for the relief of RC pressure prior to providing HPI- cooling and ] thus prevents entry into the restricted P/T or PTS region. If HPI pumps j do not start, the caution will result:in the operator closing the EMOV. This sequence of opening the'EMOV before starting.HPI to avoid PTS or P/T is acceptable because of the reliability of the.HPI pumps, the l " installed spare" makeup pump, and the redundant means of stopping EMOV l ; flow (EMOV and block valve). See also Section IV.B.2.A.2.3.2 which i allows this action, ( 1 DIFFERENCE
- 1. The TBD does not clearly present the mandatory requirements for HPI throttling when on HPI cooling with the EMOV shut. Some statements .i indicate HPI cannot be throttled until incore T/C decrease Others indicate and indirectly SCM is that i
' restored (III.C.3.3.A.4, IV.B.2.A.2.3). throttling is permitted for PTS and RV P T by stating that.the direction not to throttle supercedes the HPI throttling criteria based '" solely on SCM": PTS and RV P-T are additional criteria for throttling above the SCM requirements (III.C.3.3.A.4). Even others explicitly require throttling HPI-to avoid PTS and RV P-T without adding a~ restriction regarding not cooling with the EMOV shut (V. Ail . A.4, -IV.G,. IV.B.2.A.2.3.1,IV.B.2.A.2.3.2.) III.C-a l
e t
'h..
DIFFERENCES: (Continued) __ i 1 All TBD sections considered togetherfand . based on a' pending revision to - fi~' the TBD which deletes the incore T/C criteria;(B&W Report, " Review.of. Sacramento' Municipal Utility' District's, Emergency Operating , j Procedures"), 'It is concluded that the technical requirementLis;to . , observeLthe~ PTS and RV.P-T limits'when on HPI cooling.even if the EMOV is closed. The dif ference with the'EOPs is 'that th'e"inco'r e decreasing criteria is included.(E.04 Step 5.3). 1 ACTION: 1 Delete-the~ criteria which requires decreasing incore T/C temperatures to l throttle HPI when the EMOV is closed. IMPLEMENTATION: Pre Startup.. l l l I l l o i
'l l
j III.C-5 l
]
9
[. ]
.1 a~ ._
I TBD Chapter: ~ III.C TBD'Section(s) 2.4: FW FLOW EXISTS?
,J-TBD ACTIONS 'h0PSTEPS
. ' Monitor control room indication . E.04 Steps'1, 7 .
1' for adequate FW flow and SG . AP.23.06 Enclosure 8.3 levels. (requires using alternate instruments during performance of E0Ps). DIFFERENCES: None 4 III.C-6
~~ ----~------_-__A. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
n J TBD Chaote'r: III.C TBD Section(s) 2.5/3.4: TAKE ACTIONS TO RESTORE FW FLOW
'f This section describes the various methods of restoring feedwater ,
flow. , TBD
REFERENCE:
IV.8. IV.C E0P STEPS TBD ACTIONS
- Initiate or verify automatic . E.04 Step 3.1 3 initiation of AFW.
- Establish appropriate SG . E.04 Step 7; Rule 3 and 4 level while preventing i
excessive overcooling and . Rule 3 and 4-l
- depressurization of'the l primary system. .
. Attempt to restore MFW flow. . E.04 Step 3.2
. If neither AFW nor MFW is - E.04 Step 3.2 j
available, then feed the SG(s) with an alternate source. I l
- FW must be carefully initiated . Refer to analysis of TBD into a dry OTSG. Section IV.C.
. Should' continue to investigate . Discussion #1 the cause of FW failure even if HPI cooling is required. i DISCUSSION: ,.
j 1, Continuing ef forts to establish FW is an automatic operator action i which does not require specific mention in the E0Ps. AP.23.06 Enclosure 8.3 use of COPS.Section 4.1 directs the operator to take ! action at any time withcut being restricted to wait for an E0P step-to direct the action. Simulator training encourages operators to i continually take efforts to investigate and restore failed equipment 'l to service, j l DIFFERENCES: NONE ; III.C-7 l i i e
TBD Chapter: ' TII.C :
~~
T8D Section(s) 2.6: FW FLOW RESTORE 0? ~
- This section addresses FW flow restoration and HPI cooling.
E0P STEPS T80 ACTIONS
. While attempting to restore E.04 Step 2,'9 FW,.the operator should
. continually determine if' HPI cooling is required.
. If FW flow is restored before- E.04 Steps 3, 7, 11
- HPI cooling is required, then actions should be.
taken to restore heat transfer. DIFFERENCES: None l T3 III.C-8 l - _ _ _ _ ___________.____.m______ ________._____.______m_._.___
1 e T80 Chapter: III.C ; i T_80 Sectiord s) 2.7/3.5:TO TAKE ACTIONS TO RESTORE PRIMARY SECONDARY HEAT TRANSFER l 1 TBD
REFERENCE:
III.B. IV.A. IV.C. IVsE ,, E0P STEPS q TBD ACTIONS Reduce SG pressure so that SG - E.04 Step 11.1
. .E.04 Step 12.1 Tsat - incore T/c's is about 50*F. ,
Maintain proper SG level. . E.04 Step 7; Rule 4 -; j If primary to secondary heat . E.04 Step 8 a l
. Difference #6 (CP.101 Step 4, transfer was lost because of CP.103, CP.104) continually decreasing RC pressure below secondary. i pressure, then cool by 1' LOCA/HPI flow. -!
'l
. RC subcooled with an operable . E 04 Step 12.2 RCP 1
- Start one RCP.
. If SCM is lost, trip
- E.03 Step 1.0
. AP.23.06 Enclosure 3.3, Step 4.3 the RCP.
. E.04 Step 12 (Information) !
. Should raise PZR level and increase SCM to limit . Difference #1 ,!
potential loss of SCM. I
. If only one SG has FW e Differenes #2 i
available, the first RCP - CP.103 Step 6.2 l
. E.04 Step 12.2.2 -i started should be in that loop. 1 1
l l t l
- III.C-9
~
~~l TBD ACTIONS E0P STEPS g- ,
t
- RC subcooled with no RCPs . Difference #7 E.04 Step 11.2 operable .
. Should open hot leg HPVs. . E.06 Step 22.
and maintain or increase RC pressure.
. Hot leg indication might . E.04 Step 11.4-be used when HPVs are . Difference #8 closed to confirm voids are eliminated. Indication may not be correct for awhile af ter closing HPVs.
- Lower SG pressure to . Step 11.2.2 create a RC to SG temperature difference o'f above 100*F
. Increase SG level to loss - Step 11.2.3 of SCM setpoint [AFW is preferred over MFW).
. RC is saturated with an operable RCP.
. EMOV may be opened when . Difference #3 RC pressure increases to . E.04 Steps 2, 9 EMOV setpoint to increase HPI flow but should be closed (1) when the temperature difference between incore T/c's and SG is about 50*F, or (2) during RCP bumps.
l l
- Bump one pump about every . E.04 Step 12.3 (Information) 15 minutes. Bumping an - Rule 1 ,
l RCP requires starting and - Difference #9 ! running the RCP until motor l cur. rent drops to normal. l Maintain as much HPI as I possible. l 1
- II I . C-10 l
L__-_--__. __ - _ _ . - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
I i l 1 TBD ACTIONS E0P STEPS j i
. If only one SG has-FW, . Difference #2 attempt to bump RCPs only ,
in that loop. . j l
. RCP NPSH nay be violated . Difference #4 but do not override j starting interlocks.
1
. If RCP bumps do not . E.04 Steps 13, .14,15 - a restore heat transfer, . Difference #5 i further lower SG pressure to create a RC.to SG temperature difference .
of about 100*F.
. Centinue to bump RCPs or establish HPI cooling.
- RC is saturated with no - E.04 Step 11 operable RCPs.
1
. Establish OTSG as a heat sink by maintaining a 50'F AT between l
incore T/c's and Tsat l and appropriate SG 1evel.
. Initiate HPI cooling.
1 DIFFERENCES: J l 1. The information for Step 12.0 on page E.04-10 discusses the potential j for a pressurizer outsurge during RCP bumping. This alerts to the , operator that int
- easing pressurizer level and SCM will limit the j potential loss of SCM when starting an RCP. The TBD information would j be a more direct reminder to the operators. However, the operators are trained, particularly on simulator exercises, to expect this response and will take appropriate actions to minimize the chance of a loss of SCM. If SCM is lost, the operator will recycle back to E.03, trip RCPs, then following the E0P logic will return to the steps to restore heat j
transfer. The E0Ps are thus valid as written. . i III.C-11 i l 1 L i
'l DIFFERENCES: (Continued) __
ACTION: 3 Revise information regarding RCP pump bumps to include the T80 enhancements.
- I I
IMPLEMENTATION: i Post startup. i JUSTIFICATION: This may be done post restart because, as noted above, the E0Ps are valid as written. q
- 2. The TBD guidance to start the RCP'in the loop with the one operable OTSG. 1 l
is f ound_ only in CP.103 (Step 6.2) . The.TBD information would enhance the E0P in E.04 Step 12.2.2. The operators are trained at the simulator- l during inadequate heat. transfer to attempt to maximize primary to- j secondary heat. transfer. The operators thus would be expected to start the RCP in the loop with the operable OTSG, for this obviously would be more effective in restoring heat transfer than starting the RCP in the loop with an inoperable OTSG. E.04 Step 12.2.2 has a preferred' starting i sequence which assumes both OTSGs are operable. If an RCP is started in- l the loop with an inoperable OTSG heat transfer will not be restored to I l the inoperable OTSG, alerting the operator that the action was not- I effective, whereupon the operator will start an RCP in the other loop. 1
/ Because the TBD guidance is desirable, not mandatory.and because the - E0Ps, as written, and training will result in restoring heat transfer, the E0Ps are acceptable as written.
ACTION: Revise E0Ps to start RCP in the loop with an operable OTSG. IMPLEMENTATION: 1 Post Startup JUSTIFICATION: , The E0Ps as written and training result in restoring heat transfer and the TBD guidance is desirable, not mandatory. II E.'C-12 k i t L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ __ _. . _ . _ _ _ , _ _ _ _ _ __._ _ _ . _ _ _ _ _
a u DIFFERENCES: (Continued) ,
- 3. The TBD action is to open the EMOV, thereby reducing RCS pressure and
("N increasing HPI flow. The TBD,.then has the operator close the EMOV in certain circumstances. This is an optional action when attempting to s i restore primary to secondary heat transfer. :The EOPs do not include l this optional action so operator efforts can be concentrated on restoring heat transfer without having to divert' attention to EMOV control. Not operating the EMOV minimizes the chance of failure.and~ j hold EMOV operation in reserve for times when its' operation is more ! critical (ie-HPI cooling). )
- 4. This refers to TBD III.C.3.5.C.
The E0Ps do not explicitly state not to override RCP interlocks whenever RCPs are started, rather state when. interlocks are'to be overridden 1 j (ICC), thus operators will not. override . interlocks at this point. j Explicit direction is not' required. RCP NPSH does not exist at this l I point because the RCS is saturated thus, it is not necessary to include j a discussion of RCP NPSH limits. The E0Ps thus conform to the intent of the TBO.
- 5. This step is permitted by ATOG. Running RCPs will couple the OTSGs to ')
the primary system, thus assuring OTSG heat transfer if feedwater is available. This action will also cool and contract the RCS, reducing RCS pressure which allows more HPI flow. This replaces lost RCS. inventory and may allow for the reestablishment of subcooling margin. Refer to ATOG Part II, Vol.1, Equipment Operation Section, for further justification for running RCPs in a saturated system after one hour. . 1 E.04 chose to maintain a 50*F temperature difference between the RCS and SG Tsat. rather than increasing the temperature difference to 100*F as- I suggested by the TBD. Since the RCP will continue to run and the SG~is ) established as a heat sink, HPI'will increase due to the reduced RCS pressure (as discussed above) and the initial'50'F temperature dif ference will provide a more than adequate thermal driving head. 1 ACTION: Consider implementing TBD III.C.3.4.C for guidance f or continued RCP bumps rather than continuous RCP operation (E.04 step 14) and l i increasing the RC/SG temper *.ture difference to 100*F. IMPLEMENTATION: Post startup. JUSTIFICATION: i Whether to run or bump RCPs is a judgement call. Either method is ; acceptable. , t
\ III .C-13 l-
DIFFERENCES: (Continued) ~ E.04 Step 8 (which branches. to CP 101. if CFTS ' dump) is . based on the ATOG (r t-6. Section III B Step 8 which uses CFTs emptying as indication that a large break LOCA has occurred and the break with HPI cooling will.be sufficient to remove, decay heat and OTSG cooling is not required. .The
' ATOG criteria is valid, however,; the TBD use of RC pressure below SG pressure is a refinement of the ATOG criteria. If OTSG. heat transfer is- !
needed after CF1s dump (i'.e., low RC pressure.has reduced heat transfer
~
-out the break), then Step 4 in CP.101 (branch 'f rom E 04 Step 8) branches' to CP.103 or CP.104 which restores heat transfer if needed. The E0P as_ '
3 written implements the intent:of the'.TBD to establish OTSG heat transfer i when.'needed, thus, is acceptable as is. Implementation of the T80 j guidance will reduce branching between E.04 and CP.101,103 and 104.. l ACTION: ] t i Include the TBD guidance for criteria when to establish OTSG . heat' transfer in E.04 Step 8. i 1 IMPLEMENTATION: J Post startup. JUSTIFICATION: 1 Post Startup implementation is acceptable because the present E0P is valid as noted above.
- 7. TBD indicates that RC pressure should be maintained or. increased to help l venting the hot legs. E0Ps do not include.the action to raise RC l pressure, but do require maintaining'RC pressure. Raising pressure is' l not required to vent the hot-legs thus the E0P is valid as written.
- i ACTION:
Revise steps which vent the hot legs when subcooled to maintain or 'I increase RC pressure. : I IMPLEMENTATION: Post Startup i JUSTIFICATION: As noted above, the E0P is valid as written and' the action to increase pressure is a non mandatory enhancement. ( I II . C-14
------a- . - - - - _ - -- - . __ _ _ _ _ _
a DIFFERENCES: (Continued)' '~
- 8. E0Ps do not explicitly require use of the' hot leg level . indicators '
because the plant condition on which the. operator. bases E0P' decisions is whether or not heat transfer is established, itot hot leg level. Use of the indication'is~ optional in the TBD to confirm that voids were vented-once the'HPVs are closed. Because'their use is discretionary and the. time 'for them to correctly indicate af ter closing the.HPVs.is not established, it is. appropriate not to explicitly require their.use in the E0Ps. They are available for use and operators.have received. training'on them. Based on the above, the E0P is considered to be correct in omitting a specific reference to the hot' leg level . indicators.
- 9. Refer'to Analysis of T80 Section IV.A.3.4. Difference 2.
.-l l
l III . C-15 !
. .J
.~
.TBD Chapter: III.C
~
TBD Section(s) 2.8: PRIMARY TO SECONDARY HEAT TRANSFER RESTORED i If adequate primary to secondary heat transfer is not restored, initiate HPI cooling. ! E0P STEPS T8D ACTIONS' i
. Continually determine if HPI . E.04 Steps 9, 2, 15 I i
cooling is required while attempting to restore . primary to secondary heat trans f er. DIFFERENCES: None l i
. l II I . C-16 T?> l 1
l 3
l 1
.. . ]
TB0 Chapter: III.C TBD Section(s) 2.9: ESTABLISH CONTROLLED DECAY HEAT REMOVAL WITH SG(s) 1 1 l TBD REFERE?lCE: 111.0. III.E. III.G - ! TBD ACTIONS E0P STEPS l
. Establish controlled decay . E.04 Step 16 heat removal.
RCS Subcooled
. Recover from HPI cooling . E.04 Step 17 !
i by (1) closing EMOV and C P .105 HPVs, (2) controlling j MU/HPI flo,w.
. Adjust heat removal by ;
adjusting TBVs and ADVs ! to maintain the RC temperature at present I
~
value or begin a controlled cooldown. l
. Draw a bubble in PZR if i necessary (i.e., one !
does not exist) or if l ' pos sible. RCS Saturated
. Recover from HPI cooling - E.04 Step 18 C P.103
. Cooldown with RC saturated using the SGs while HPI maintains RCS inventory.
Cooldown With Oniv One SG l
- Attempt to restore heat . CP.103 transfer to other SG, . Refer to Analysis of TBD III.B if possible (i.e., no . 2.8/3.5 Difference 3 steam leaks, SGTRs, etc.
DIFFERENCES: None i III.C-17 _-_- a
n, , W TBD Chanter: ~III.D
~~
TBD Section(s)' 2.1/3.1: t IDENTIFICATION OF' EXCESSIVE HEAT TRANSFER [. These sections refer.to use of the P/T. relationship:to identifyL excessive heat transfer.
'i
* 'I TBD ACTIONS E0P STEPS'
- Overcooling is bestfidentified' . . E.05 Typical P/T' Overcooling
~
l by use of the P/T relationship. . Trace Page.E.05-1~ .
- E.02 Guideline 3 1
- . Operator Training DIFFERENCES None l
- l. c l
i l l l' l l l l 53 111.0-1 \. . 1 *
-TBD Chapter- III.D i CONTROL PRESSURIZER LEVEL ^l TBD Section(s) 2.2: i j
This section provides for'use of makeup or HPI to control pressurizer level to avoid' emptying the pressurizer and requires control of. j HPI/MU flow to avoid PTS. E0P STEPS: TBD ACTIONS
. Increased Makeup Flow and'even '. E.05 Step 2.0 HPI should be used to prevent pressurizer level f rom . E.02 Step 7.0 (including going off scale low, information page). 'These steps are early in the ~EOPs thus-assuring early. initiation. ,
' = Control Pressurizer level. .- E.02 Step 6.0
. E.01 Step 2.3' These steps reduce letdown to.
~40 gpm which-helps reduce pressurizer level decrease.
l
. Control of HPI/MU flow . E.05 first CAUTION after Step required to not violate 1.0 PTS limit.
. E.05 CAUTION af ter Steps 6.0, 14.0. This caution controls RCS temperature to prevent going solid which would make RCS pressure control', thus avoidance of PTS, difficult.
. E.06 Steps 8.0,- 16.0 including
~
reference to' Rules 2 and 6.
. E.05 Steps 12.0, 27.0,: 42.0.
These steps provide' direction-to exit the PTS region if.it is violated.
. Rule 2 Step 2 DIFFERENCES: None L s. 111.0-2
1 l
- - ^
'l TBD Chapter: III.0 '
r TBD Section(s) 2.3/3.2: OVERC00 LING SG APPARENT 7 1
\
These sections provide guidance to identify the overcooling OTSG by ! i comparing SG and RC parameters and instructions to verify automatic system actions. . TBD ACTIONS E0P STEPS
- Compare SG and RC parameters . E.05 Step 3.0 (Information to identify overcooling OTSG. page'provides indications.)'
. Lowest & fastest decreasing TC - E~.05 Step 3.1
- is overcooling OTSG. (Information page)
. Check MFW Flow. Rate.
- E.05 Step 3.2 (Information page)
(also includes AFW Flow which may be causing overcooling) ; I l . Check OTSG 1evels. - E.05 Step 3.2- 1 (Information page) <
. Excessive MFW to one OTSG - E.05 Steps 3.4, 3.6
- affected OTSG may have (Information page)'
higher pressure than Difference No. 1. non-affected. l
. Verify Proper Automatic . E.02 Step 5.3 Actuations. (Information page) i l
l . Correct OTSG isolated. Discussion #1
. Overcooling is terminated.
1 DISCUSSION:
- 1. Steam line/ feed line isolation (EFIC) will occur early or late in an overcooling depending on cooldown rate and speed of operator action thus it is not possible to put a step to verify proper- EFIC actuation in all possible places. Verification of proper actuation is placed in E.02 Step 5.3, the first time in the E0Ps where OTSG pressure is checked. Operator training stresses verification of proper. actuation of any automatic system. ,
1 l l 111.0-5
1 3 i DIFFERENCES . .. .
- 1. TBD Section 3.2 indicates lthat for. overfeed to one OTSG its pressure i
' ( ~ ~'
may be above.tha unaffected OTSG. This phenomenon is not~ included in- d the E.05 Information Step 3.0 however, the indications are listed in i the most valid ordar. 'Taken together the indication listed will l result in identifying ~the overcooling OTSG. 1 ACTION: .! Upgrade E.05, Step 3.0, Information~ page to include overfeed OTSG pressure indications. ! i IMPLEMENTATION - Post Restart . -
]
f JUSTIFICATION As discussed above, the existing procedure is valid, this is an enhancement. l l , l l l l
\
l I i l 1 1 i i l l t ( $b 111.0-4
-.-_---aux---- --a_----
q' I
.'j TBD Chapter: III.D
(' ' TBD Section(s) 2.4 ISOLATE BOTH OTSGs
.)
This section defines " isolation" of OTSG's, tripping of feedwater - l
, pumps,. and verification of automatic system isolation actions.
TBD
REFERENCE:
TBD ACTIONS E09 STEPS-
- Isolation means to . E.05 Step 4.0 a
- Stop'all FW Flow i
. Stop Steam Flow such as:
. ADV
- TBV
- FW pumps l Trip MFW pumps if steam line - E.05 Step 1.0 Flooding is imminent Trips MFW/SFW to high level OTSG. .j
, . E.02 Step 4.0 )
. Close MFW valves for less . E.02 Step 5.3 (Instructions) 'i severe overfeeds. (See Chapter III.02.3, Discussion #1.
DIFFERENCES: None ,
.i I
l
!_ III.D-5
,i
TBD Chapter: III.D TBD Section(s) 2.5 ISOLATE THE OVERC00 LING OTSG ( 1 l This section repeats guidance from section 2.4 ISOLATE BOTH OTSG's. ] The repeat guidance is not listed below. It also provides general l guidance for taking increasingly more dramatic steps to isolate one j t or both OTSG's and to control the unisolated OTSG. 1 TBD
REFERENCE:
IV.C.4.1 1 E0P STEPS j TBD ACTIONS t 1
. FW Flow should be maintained . E.05 Step 15.0 to the unisolated OTSG and cooling established.
l
- Isolation should be a logical . E.02 Steps 3.0, 4.0, 5.0 {
progression of increasingly l drastic steps: . E.05 Steps 1.0, 4.0
. AP23.06 Steps 4.1, 4.7, 4.10 l Discussion #1
. TBV's ADV's Aux Steam . No MSIV's at Rancho Seco.
isolation before MSIVs
. Provisions for . E.02 Step 5.2.1 '
momentarily lowering OTSG pressure to seat MSSVs. I DIFFERENCES: l None DISCUSSION:
- 1. Progression of increasingly drastic steps to terminate overcooling is accomplished by the placement and sub step ordering of the noted E0P steps. In particular E.05 Step 1 assures that overcooling is terminated early enough to avoid PTS for events which may not actuate i EFIC MFW MS isolation. Additionally AP23.06 <lirects the operator to take immediate steps to correct observed equipment ma? functions l
without waiting to reach a step in the E0Ps which may correct that i problem. l
- e III.D-6 e
i i 2 i J TBD Chapter: III.0 j
/~ " T80 Section(s) 2.6/3.3 SG PRESSlJRES AND LEVELS HAVE STABILIZE 0 '
s These sections determine it the overcooling transient has been j terminated, i.e., was the fault isolable or nonisolable? - l l TBD
REFERENCE:
1 T80 ACTIONS , E0P STEPS _ j 1
. Have OTSG 1evels and pressures . E.05 Steps 5.0, 6.0 j stabilized? Difference #1 j i
1
. Overcooling OTSG's allowed to '
. E.05 Step 5.0 (Information); !
boil dry.
. Step 6.0 (Information) j
^
(
. E.0S Step'14- .
l { DIFFERENCE l l l The EOP steps check for continued depressurization and level decrease j 1 1. vice the TBD checking for level and pressures stabilized. By this i step in the E0Ps, feedwater has been terminated. (isolated or pumps j tripped) to the af fected 0TSG and steam side isolated. Thus, if i overcooling continues it is due to an unisolable steam leak and pressure and level will decrease. The E0P thus implements the TBD intent. I l 1 I l 1 l i ! III.0-7
l i i
\
'TBD Chapteri 111.0
-(' TBD Section(s) 2.7/3.A REESTABLISH HEAT TRANSFER TO ONE OR BOTH'SG(S) i These sections outline actions to reestablish heat transfer _via goal jl OTSG's control RCS temperature and to' avoid PTS. .
1 TBD
REFERENCE:
TB0 ACTIONS E0P STEPS i
. Reintroduce feedwater to . E.05 Step 7.0 available OTSG's .
4
. E.05 Step 15.0 i 1
i
. Use TBV's or ADV's to . E.05 Step 7.3 stabilize heat transfer. . E.05 Step 15.4 1 1
. Prevent PCS reheat and swell . E.05 CAUTION before Step 7.0, ,.
to maintain RCS within. _ Step 15.0. ) i pressure limits and prevent- .j filling the pressurizer. - i j
. Throttling HPI and opening . E.05 Steps 8.0, 16.0 EMOV, pressurizer vent may ,
be needed to prevent . Rule 2 Step 2.2 i repressurization. i Rule 6 Step 2.1.1
~
e l j i
. Operator must be alert that . E.05 Step 7.0.(Information) !
ove.rcooling may be reinitiated 1 when restoring heat transfer . E.05 Step 15.0 (Information) -l and take appropriate action. 1 DIFFERENCES None l l l 111.0-8 L--------.--_._________ ___._ __ ___ _ ___ ___ ,
TBD Chapter: II I ., D [" TBD Section(s) 2.8/3.5 TRICKLE FEED ONE OR BOTH SG(S) OR HP! COOLING These sections outline methods to use OTSG's for heat removal if both have unisolable faults. Use of HPI cooling is directed if OTSG's cannot be used. T_BD
REFERENCE:
TBD ACTIONS E0P STEPS
- Carefully control AFW flow rate . E.05 Step 25.0 to maintain RCS cooldown limits and match decay heat. . E.05 Step 37.0
- Do not trickle feed.0TSG with . E.05 Step 34.0 and " STATUS"
- rupture in RB if steam release after Step 34.0 is inappropriate.
. E.05 Step 37.0
. E.05 " STATUS" after Step 42.0
- E.06 Appendix A j
. Discussion #1 !
l . HPI cooling must be used if . E.05 Step 22.0 ! l trickle feed is not possible. l l . E.05 Steps 26.0 and 38.6 ' l
- j
. Consider quantity of available . Normal Procedure A.51 feedwater: switch to lower l quality feed or llPI cooling . Discussion #2 l may be necessary. l DISCUSSION:
- 1. Procedures prohibit steaming an OTSG to the reactor building in E.05 however E.06 (SGTR) does allow steaming if required for "other considerations." These other considerations cre the ones spelled out in E.06 for steaming an OTSG previously isolated for SGTR concerns, e.g.: to promote natural circulation, reduce SG 1evel, etc. There is no conflict between E.05 and E.06 because only one of these
' procedures can be used at a time (AP23.06). 11I.0-9
'W c
- g. - -l i ,
DISCUSS 10k~ (Continued) , ., l
/'." 2. A.51 Auxiliary, Feedwater System'Section 7.0 provides ' direction to switch to the site water supply system upon. low CST level;(3 feet at "l '
1
- Lo Lo Lo Alarm). :l Switch to HPI cooling is.not made because-of backup water from the 1
- site: water supply, .l DIFFERENCES:
.i. 'd
..Q
-1
.4 1
1 l l y a j
')
e ii e i u 73
\'. -- '
111.0-10 . i
)
1 1 m.. ,
.n I
T80 Chag,terf III.D ... 4 /*^ TBD Section(r) 2.9 VERIFY STABLE'Pt. ANT CONDITIONS Stable plant corditions and SGTR are checked by this section after
^
terminating the overcooling ar.d' establishing heat transfer.. E0P STEPS __ TBD ACTIONS E 05 Steps
. Verify stable conditions when - .
the. overcooling is terminated 8.0 Control HPI- '
.and! heat' transfer is restored. 9.0. *SCM .
11.0 SGTR-
. . Check for adequate SCM 13.0 LRCS P/T.
16.0 -Control HPI, j 4 Check for SGTR 18.0. SCM l 19.0 SGTR 31.0 SGTR
- ~39.0 -SCM 41.0; SGTR
.These steps check for stable plant conditions at appropriate locations in the procedure, e
SGTR verification with. . E.02 Guideline 4 steam rupture. Steam line rad monitor or an f
. Use steam line rad air ejector monitor is an monitors. indication.
. Ifbreakisupstreamofste5m REFER to Analysis
.line rad monitors, rad monitors III.E 2.1.1/3.1.1, Difference #1 may not indicate SGTR.
I E.02 Guideline 4' l l DIFFERENCES: J None. I l 4 I
~
' II I . D-11 l
I
.___.___.__-__.________._____j
a
~ .
TBD Chapter: III.E TBD Section(s) 2.1.1/3.1.1 IDENTIFICATION This section describes possible indications of a SGTR situation. TBD ACTIONS E0P STEPS ,
. Identify the affected SG(s) . E.06 Step 1
- 1) Indications A. Radiation alarms
- 1. Steam Lines . E.02 Guideline 4/E.06 Step 1.2
- 2. Condenser . E.02 Guideline 4 B. Primary Leak Rate . E.02 Guideline No. 4 ;
i I C. SG Samples . E.06 Step 1.1 D. Reduction in the steam outlet temperature. . E.06 Guideline No. #4 E. Anomalies in FW flow - See Difference #1 F. Anomalies in MSG Level after reactor shutdown. Dif ference #1: E.02, Cuideline 4 and E.06 Step 1.0 primarily rely on radiation monitoring response to provide indication of a SGTR situation. This method is cited in the TBD as the most rapid means of SGTR identification while at power. The TBD also cites several " backup methods." Of these, reduction in steam outlet temperature and anomalies in FW flows and/or SG 1evels after reactor shutdown are not specifically addressed in E.06. Steam temperature indication at Rancho Seco is sensed downstream of the TBV's and ADV's and so, does not provide accurate indication unless the turbine generator is in-service. FW flows and/or SG 1evels would only be useful for SGTR situations if the leak was f airly large. Although these indicators are not directly used in E.06 as methods of detection, they are employed by the operators due to training, particularly at the simulator where evaluating for a SGTR situation includes evaluating any unexpected differences between OTSG secondary side parameters. Guideline 4 of E.02 indicates there may be other valid indications of a SGTR than those specifically cited in the Guidelines and to not l delay in taking action per E.06 if other indications make it clear a SGTR has occurred. III.E-1
1 l l Difference'#1 (Continued) __ For a small RCS leak Casualty Procedure OP-C-3 directs'the' operator (
- to isolate.possible paths and look for possible leak. sources.
Following a steam line break and OTSG isolation a SGTR would.be ;
-indicated by (depending on steam rupture size and SGTR size) unexpected high/ increasing OTSG level or pressure,- or continued steam flow out the break from a supposedly dry OTSG. Failing to find 1
indications of RCS. leakage.into other systems (CCW etc.)f or into the reactor building _and noting the unexpected OTSG conditions, a SGTR'is l diagnosed. Note that if.the steam line. rupture is'in the reactor l building, identification of a SGTR is. moot. . With'the 0TSG isolated ! for the steam rupture, a SGTR is the same as other RCS break- ! locations in the reacter building. l E0Ps do not explicitly include the TED concern.that if a steam line-I break is upstream of the steam line radiation' monitors, the monitors may be ineffective in indicating an SGTR, However, Casualty Procedures OP-C.3 "small RCS leak," E.02 Guideline 4, 'SGTR' and j operator training do assure detection of an SGTR upstream of the. steam line radiation monitors. s Action: To enhance the detection of SGTR upstream of a steam line break, 'I OP-C.3, and Guideline 4 and E.05 should be revised to' provide explicit guidance.< Implementation: Post Startup Justification: Because the existing procedures and training are adequate, this ! enhancement can be made af ter startup. !
\
l l I i i e III.E-2 l
- ..- n_..L_--- _
.y ,
a g, , 1 TBD Chauter: III . E L-TBD Section(s) 2.1.2/3.2 ' PLANT Ri)NBACK AND REACTOR SHUTDOWN , l This section' recommends the. plant be shutdown in a controlled manner rather than tripping to minimize atmospheric releases and the possibility of a stuck open MSSV. .
- TBD REFERENCI:_,
TBC ACTIONS E0P STEPS
' Runback the plant . -
E.06 Step #3'
. - Trip reactor when within. - E.06-Step-#6 turbine bypass capacity
. Control plant runback. . E.06 Step #3 _
. Max HPI flow - E.06 Step #4-1
. If Rx Trip: Normal a' E.06 Step #2 post-trip action . E.06 Step #7 DIFFERENCES: None !
?
i i l 4 D' ' III.E-3
'l l
TBD Chapter: III.E
/" TBD Section(s) 2.2.1 SlJBC00 LING MARGIN .g-The operator.is. directed.to evaluate Subcooling Margin.
TBD
REFERENCE:
II.B TBD ACTIONS E0P STEPS
. Verification of SCM . E.06 Step 8.0
. Constant Surveillance of SCM . -E.06 Step 8.1
- Maintain RCS pressure & . E.06 Step 14.0
- temperature close to minimum SCM.
DIFFERENCES: None l i i i
)
! l l' , i III.E-4 ; i I a_-__-_-_-_-__:______--___ __
.. .i l
TBD Chapter: III. E l h TBD SecticMs) 2.2.2 LOSS OF ADE00 ATE SUBC00 LING MARGIN This Section specifies action if adequate subcooling margin does not < i exist when checked in section 2.2.1. ., i TBD
REFERENCE:
III.B TBD ACTIONS E0P STEPS i
. Trip all RCP's '. E.06 Step B.2
. E.03 Step 1.0-
- Initiate full HPI - E.03 Step 2.0
.- Rule 1
. Raise SG Level (s) . Rule 3
. E.03 Step 3.0
. Do not intentially raise level . E.03 Step 3.0' in affected OTSG. Continually inject sufficient AFW to maintain - Discussion #1 natural circulation while allowing the level to increase . Difference.#1
[' due to the tube leak.
. Without full HPI raise' level. - E.03 Step 3.0 in both SG to setpoint.
. With SCM start RCP's. . E.03 Step 16.0 l
. Throttle HPI to maintain . E.06 Step 14.0 pressure close to and above SCM, . Rule 6 but below PTS, if applicable.
l l l DISCUSSION: l
'1. If a loss of SCM occurs I.06 branches to E.03. If RCPs are tripped, 1 E.03 Step 3.0 directs the operator to manually select "ECC Setpoint" on EFIC. This will enable EFIC to automatically feed both OTSG's-to the loss of subcooling margin level at at rate that is dependent on actual OTSG 1evel and pressure, but is never less than that required for adequate OTSG heat transfer. Because of tube leakage, the i.
l affected OTSG AFW injection vill be less than that on the III.E-5
I 4
- s. .
il i DISCUSSION (Continued) - - - i (~' e unaffected OTSG thereby allowing the affected OTSG to fill at a rate l l dependent on tube leak size while maintaining sufficient AFW flow to maintain natural circulation. , l DIFFERENCES:
- 1. If RCPs are not tripped within two minutes of .a loss of SCM, one RCP per loop is run and OTSG 1evels must be increased to the loss of subcooling. margin level manually. There-will be no automatic rate control as described in Discussion #1 of this. analysis. E.03. Step i
3.1 directs the operators to ' raise both OTSG levels manually without l l regard.to a SGTR' situation. .In the absence of the automatic EFIC i control the operator would have to assume.the burden of raising the I unaf f ected OTSG's . level, ensuring adequate AFW flow to. both OTSG's and allow the affected OTSG to fill at a rate determined by tube; leak size. This places great demands on,the operator at a time when he is i already fully involved in addressing the highest priority symptom of the Emergency Operating Procedures. l The procedure obtains the proper balance between OTSG inventory control and operator burden. , 1 i ( , 1 1 l I 1 i l i i k, i III.E-6 4 _._______.-_._m__
.];
TBD Chapter: III'. E 7" , TBD Section(s) 2.2.3 PRIMARY TO SECONDARY HEAT TRANSFER-Section evaluates Primary to Secondary Heat Transfer. TBD
REFERENCE:
III.C. III.D TBD ACTIONS E0P STEPS
= Controlled Primary to: Secondary . Refer to. analysis of TBD Flowchart III.E-1, Heat Transfer? '
Difference 4. DIFFERENCES: None
.' k j
i j i III.E-7 i
- r.
- - - _ _ _ . _ . _ _ __---___--._--______-__-_____.____u-__-______a
f' TBD Chapter: III.E TBD Section(s) 2.2.4/3.8 LOSS OF CONTROLLED HEAT TRANSFER Section provides direction for restoration of Primary to Secondary Heat Tran,fer. TBD
REFERENCE:
III.C. III.D TBD ACTIONS . . . , E0P STEPS
- Restore Primary to Secondary . Refei to Analysis of TBD Heat Transf er. Flowchart III .E-1. Dif f erence 4.
l Special considerations for steam . E.05 Step 11.4 leaks concurrent with SGTR's. DIFFERENCES: None l l l l l 1 l l 1 l
. i III.E-8 ,
i 1 i
TBD Chapter: III.E f.
- TBD Section(s) 2.2.5/3.8 RESTORATION OF HEAT TRANSFER t'
.Section provides direction to begin cooldown once heat transfer.is restored to at least one OTSS.
TBD
REFERENCE:
III.C. 111.0 TBD ACTIONS E0P' STEPS
- With heat transfer restored - Refer.to Analysis of TBD to one OTSG attempt to restore Flowchart III.E-1, Difference 4.
1 1 heat transfer to the other OTSG.
. With hedt transfer loss to both . . Refer to Analysis of'TB01 j OTSGS initiate HPI cooling. Flowchart.III.E-1 3 at EMOV'setpoint. Difference 14.
. Special considerations for . E.06 Step 11.4 i j
steam leaks concurrent with SGTR's. 1 i 01FFERENCES: None i
-j l
l
'l l
l l III.E-9 l i l l l
- )
l TBD Chapter: III.E TBD Section(s) 2. 3.1/3 . 3.1 COOLDOWN AND DEPRESSURIZATION TO (~ ' BELOW MSSV SETPOINT The intent of the initial cooldown is to prevent lifting of the MSSV's by reducing primary hot leg temperature below the saturation temperature corresponding to the lowest MSSV setpoint. TBD
REFERENCE:
TBD ACTIONS E0P STEPS
. Commence cooldown with both SG4 s.
- E.06 Step 11.0
- Perf orm isolation anytime . E.06 Step 15.0 after initial cooldown. .
. RCS Cooldown rate s100'F/hr . E.06 Step 10.7
. SG tube-to-shell AT 6 100*F . E.06 Step 10.7
. Observe fuel pin in . E.06 Step 10.7 Compression Limits E.06 Step 14.3 f-
. Observe RCP NPSH
+ E.06 Step 14.3 Limits
. Maintain minimum SCM + E.06 Stop 14.0 but minimize primary to i l
secondary AP. l J
. Isolate CFTs when permitted. . CP.103 Step 10.0 '
. CP.104 Step 6.0
. CP.104 Step 3.0
. B.4
. Emergency Cooldewn Rate to . E.06 Step 10.6.3 500*F Th at 240*F/hr.
. Tube-to-shell Delta T . E.06 Step 10.6.1 Emergency 150'F.
' I II . E-10
i TBD
REFERENCE:
TBD ACTIONS E0P STEPS (
. Use emergency cooldown . E.06 Step 10.6 if OTSG 1evel is rapidly increasing or radiation . Difference #3 release is projected to reach the integrated TRACC limit.
- PTS limit, if applicable - E0P Rule 6 has priority over conflicting Curves.
Difference: ,
- 1. The TBD allows an emergency cooldown reate to be utilized if radiation releases are projected to reach the TRACC integrated ,
exposure limit. E.06 does not reference this consideration. Refer to the Analysis of TBD Section III.E.2.3.2. l l Action: j Revise E.06 Step 10.6 to reflect the changes necessary to incorporate the TRACC integrated exposure limit. Implementation: Pre Startup l II I . E-11
1
'I TBD Chapter: III.E f~^ TBD Section(s)'2.3.2/3.3.2 DECISION TO ISOLATE SG J Section presents the option 'of: isolating the af fected-SG or continue:
to cooldown on both OTSG's; l J TBD
REFERENCE:
TBD ACTIONS E0P STEPS , f
. Isolate SG - E.06_ Step 15,0 j
- Continue Cooldown i f See Dif'erence #1
. 'on both OTSG's Difference: :
i
- 1. This TBD section allows the affected 0TSG to be isolated when possible or to continue cooling down with both OTSG's. E.06 Step 15.0 directs the operator.to isolate the OTSG as soon as possible in order to minimize'the integrated of f-site exposure. This action 1 j complied with the' requirements of ATOG, the original basis-document for the E0P's. When the TBD was created it incorporated a broader philosophy for how to treat an affected OTSG. This. allowed continued steaming of an affected OTSG in order.to allow as normal-of a cooldown process as possible, thereby expediting the cooldown to'DHR l
conditions. There are, however, limits cited by the TBD for l continued steaming'of an affected OTSG. Isolation would be required if any of these are reached during the cooldown. Implementation of the TBD philosophy into the EOP's is incomplete. The final aspect is to incorporate.the TBD isolation criteria based on the integrated ' dose limit. The TBD recommends this limit be no more that 10% of the 4 10 CFR 100 doses. Action: Revise the E0P's as required to complete incorporation of the TBD 1 f option to allow continued steaming of an affected OTSG-
)
Implementation: Pre-Startup l l s l , I I I . E-12 1 1 l 1 I
TBO~ Chapter: III.E. TBD Section(s) 2.3.3/3.3.3 ISOLATION OF THE AFFECTED OTSG-(
.Section addresses whether to allow isolated OTSG'to. fill or periodically steam / feed the. isolated;0TSG.
TBD
REFERENCE:
E0P STEPS' TBD ACTIONS
. Periodic f eeding steaming .
.E.06 Step 16'.0 and/or draining the affected OTSG.
Refer:to analysis'~of TBD Allow isolated OTSG to fill. l - Flowchart III.E-1,10if ference ~6. DIFFERENCES: None i 5
'].
1 i i l e III . E-13 .l I l i i - b-_ . . . .
,, r _
TBD Chapter: ; III . E .-
--i
'TBD-Section(s) 2.4.1/3 4 SGTR-ALTERNATE CONTROL CRITERIA f' ' .
b
.l This section discusses the'ulimate SG isolation. limits.- 'l i ~
TBD
REFERENCE:
TBD ACTIONS 'E0P-STEPS ,
.. Radiation approaching pre- '
a determined limits: ., a). Plant: Runback 'a) .E.06' Steps:3.0,.4.0, 5.0, 6.0~
.b) Perform actions to- b)' E.06 Steps.3.0,:6.0,:.10.0,'15.0, 4 minimize potential.for 16.0,-18.0,;19.0 uncontrolled releases. " Cautions"' prior to E.06 Step: a 1.0i 13.0, 16.0 ' :)
c) Integrated dos'e limit, c) Refer to' Analysis for, Section IV.E. 2.3.2/3.3.2;
.- BWST:1.evel approaching a-' ..
E.06 Step 11.6. ; a predetermined' Low limit.
)
.- '56 filling due to tube leakage . .
E.06 ' Step' 16.0 '
.despite' steaming to achieve MAXIMUM'Cooldown Rate.
!' ~ f DIFFERENCES: None j i 4
'l
~
i t
-l
% III . E-14 j
~l l
q TBD Chanter: III.E. , ! C TB0Sectionis)2.4.2/3.5 DECISION O'N USE OF SG DRAINS ~ This section discusses the option of using SG drains to either. delay-the necessity of isolation'or prevent filling'an isolated SG. TBD
REFERENCE:
TBD ACTIONS E0P STEPS'
. Use of.SG Drains- . E.06,LSteps' 5.9, 9.6, 1,6.1'.2-DIFFERENCES: None e :
.i 1^
1 l l . l l 1 l 1 4 1 i 1 i l o
.i III . E-15 :
,- ... o >
3
l TED Chapter:- III.E'
.i TBD Section(s) 2.4.3/3.6 ISOLATION'0F AFFECTED OR MOST AFFECTED OTSG j
. Action is taken if either the decision was made to not steam an af fected' OTSG E a TRACC limit was reached that requires OTSG ~ .{
j isolation,
'I TBD
REFERENCE:
E0P' STEPS i TBD ACTIONS j
-Close all steam, feed and drain . E.06, Step 15.4 I
.j lines. !
j i - As the OTSG approaches a solid . . E.06 Step 15.2 &'15.3 condition, maintain RCS pressure . CAUTION prior to Step 16.0
.below MSSV setpoint.
~
.- E.06 Step -16.1.2.1 ]
= E.06.5tep 18.0 ..;
- E.06 Step 19.0 ]
w 1 4 DIFFERENCES: None I i l i i ( 1 1 i I l l \ : l 1 l l k-- III . E-16 l. l l
') l TBD Chanter: III.E.
/' ?' TBD Section(s) 2.4.4/3.4' CAN COOLDOWN CONTINUE ON ONE OTSG' WITHOUT REACHING TRACC?-
\ .
This section evaluates.whether both OTSG!s must be isolated; TBD
REFERENCE:
TBD ACTIONS 'EOP STEPS
~
.- .If.both 0TSG's have tube- .
Difference #1~
- leaks,Lisolate most affected
& continue cooldown on'one 0TSG until TRACC limit reached.
l . Difference #1: This TBD section provides for isolation of the most affected OT5G,:if
~
'both OTSG's have tube' leaks,fso asLto attempt completion of the cooldown without having to11nitiate:HPI; cooling unless'absolutelyL necessary (i.e., both OTSG's must bel isolated). 'E.06 can not incorporate this direction since continued steaming of.an affected OTSG is allowed only if certain limits are not reached. These; limits, known as the Tube Rupture' Alternate Control Criteria-(TRACC) in the TBD, are not yet fully incorporated into the'ECP's,1thus isolation of an affected OTSG is presently required:as soon as RCS.
temperature allows. The incorporation.of these limits into'the'EOP's-is discussed in the analysis .for,TSD sections' 2.3.2/3.3.2. .. Action: i Provide-more specific direction foresimultaneous OTSG tube' leaks.once TRACC limits have been fully incorporated into the E0P's.. ImDiementation: Post-Restart Justification: Once the TRACC limits have been fully incorporated' into the E0P's continued steaming of both OTSG's will'be' allowed. until a limit is reached. THE TBDJacknowledged'that for relatively small tube leaks, even if both OTSG's are affected..it'isinot likely a TRACC~11mit'will be reached before DHR conditions'are established. Furthermore, not all.TRACC' limits would: require both 0TSG's to.be-isolated. -Additionally, because of the OTSG's re-sleeving program this outage the probability of a SGTR is remote. L . III . E-17 i
.TBD Chapter: ' I I I'. E TBD Section(s) 2.4.5/3.6' ISOLATE REMAINING OTSG'& ALLOW IT'
-(T TO FILL This section-~ directs isolation of the 2nd:0TSG if continued steaming-of. it results in' reaching a TRACC limit. - TBD
REFERENCE:
TBD ACTIONS E0P STEPS--
. Isolate remaining OTSG and allow.
- E.06 Step 15.4 it to;fil1 if TRACC limit reached .- Refer to Analysis for'TBD III'.E 2.3.2/3.32, 01fference
#1 and III. E 2.4.4/3.4, Difference #1.1 :
DIFFERENCES: None I III . E-18
a
.. .. l TBD Chapter: III.E-TBD Section(s) 2.4.6 INITIATE HOI COOLING This.section gives direction to initiate'HPI Cooling to provide an j
alternate method of. core. cooling since both OTSG's have been-isolated. TB0
REFERENCE:
TBD Reference III.G TBD ACTIONS E0P STEPS 1
. . Initiate HPI Cooling . E.06. Step 17.0-1 If HPI Cooling initiated due . E.04, Entire Procedure to lack of adequate primary- .. Refer to Analysis of. - .
1 to-secondary heat transfer, TBD Flowchart III-E.1, l continue attempts to restore- Difference 4.- heat transfer. l J. DIFFERENCES: None y l l i I l i l 1 I l 1 l i i i t III . E-19 l ,
+
_o1___ _ _ _ _ _ _ _
- ' 1
.TBD Chapter: III.E- ._ j
,TB9 Section(s) 2.4.7/3.7 TAKE ACTION'AS NECESSARY T0' PREVENT -)
.j
. f"? ' . LIFTING MSSV'S l
With 'both OTSG's isolated, careful. control of HPI and/or RCSipressure ]
.is necessary'to prevent MSSV-lift. ..
TBD
REFERENCE:
TBD ACTIONS E0P STEPS
. Throttle HPI if SCM is: adequate. '- E.01, Step 18.0
- If'HPI^cannot be throttled . E.06,: Step 19.0 perform one'or more of the- -l following~asinecessary: , l 1
. E.06, Step 19.1.1-a) Unisolate Letdown b) Open RCS HPV's . E .06, Step .19 1. 2.1 -19.1. 2.'3 l
c) Open OTSG drains . .E.06, Step'19.1.3 d) Open TBV's . ~E.06', Step 19.1.4' '; i e) Open ADV's -' . E.06,: Step 19.1.5 l DIFFERENCES: None . l , 1
-l I
1 III.E-20 , I E
. - _ - a
t t TBD Chapter: III.E
'TBD Section(s) 2.5.1 ARE RCP's OPERATING?
["' ' This'section evaluates RCP status and provides. direction accordin0ly. .9 l TBD
REFERENCE:
IV.A a TBD ACTIONS E0P STEPS'
- Evaluate RCP status. - E.06, Step-20.0
.See Discussion #1' '
q
- f i
Discussion. 1
- 1. There is no E.06 step that directs the operator to simply check RCP.'
status. Rather, direction is provided to take action if RCP's are~ - 4 not operating and SCM is adequate. This method. accomplishes the: status check of TB0'section 2.5.1<and at the'same time provides. direction acccedingly that is provided by separate 180 steps-(2.5.2 thru 2.5.4). DIFFERENCES: None I 4 f 1 l III.E-21 1 l'
-- ~ - _ - _ _ _
TBD ChapteP: III.E-
~~
/~ TBD Section(s) 2,5.2 ARE CRITERIA SATISFIED'FOR RCP RESTART? 1 I i TBD
REFERENCE:
IV.A EOF STEPS TBD ACTIONS !
- If RCP's are not operating . Es00, Step 20.0 evaluate for RCP re-start 1 criteria.
Discussion #1 l
. Observe NPSH requirements -
. Refer to Analysis for l TBD Sections III.C.2.7/3.5.
Difference #4 and #5 Discussion: E.06 Step 20.0 does not directly address NPSH requirements. If an 1. RCP is to be started per the direction'of Step 20.0, the operator would use the normal system operating procedure which does instruct the operator to ensure adequate NPSH exists prior to starting an RCP. Additionally, AP.23.06, the procedure that establishes j procedural use philosophy for Operations Dept., requires that all i nornal system Limits and Precautions be ob3erved, unless specf fically directed otherwise, when operating systems / equipment by EOF direction. l
)
i DIFFERENCES: None I i 1 I I l i i III.E-22 1 I i i
.s..
o
- a. ... .
TBD Chapter:' III.E: j
..3 j
X' ^ TBD'Section(s) 2.5.3 RESTART RCP's This' stop directs the operator to-re-start RCP's if the proper D o criteria is met. -
-)
.h J
TLD
REFERENCE:
IV.A l TBD' ACTIONS E0P STEPS' Re-start RCP's 'The number; .'- E.06,: Step 20.1< and corabination.to be . E.06,. Step l20.1.1
~ determined by plant conditions. l
. DIFFERENCES: None l .
i s- 4 1 l
)
- l l
q
- l. 'l 1
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l J
.i i
1
.l
.J
! .l. l i III.E-23 f
i
. , i
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, t.
.k .
-TBD Chapter: :III.E
._ g 7- '
'T80 Section(s) 2.5;4 'BEGIN OR CONTINUE NATURAt. CIRC C00LDOWN.
.!s_ <
~
.This, section provides direction iflRCP re-start criteria; cannot?be.
j n satisfied or RCP's are notiavailable.. .. .
. TBD
REFERENCE:
III.G ii TBD' ACTIONS E0P STEPS > . :l
- l l
. iProceedLwith natural: . E.06, Step 20.3 circulation cooling. if. < R RCP's will not be il
.available.
4 DIFFERENCES: None I . I J l
.i 1
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1
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1 j 1
.d i
j j i.
.III.E-24. -l
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_-_-_.--,,.---JL-.5.'_.l_.L-
TBD Chapter: III.E j
..i I 'TBO'Section(s) 2.5.5 BEGIN OR CONTINUE FORCED CIRCULATION COOLDOWN This action.is specified if.RCP's were determined to be operating in_
f s T80 Step 2.5.1. TBD
REFERENCE:
III.6
'TBD ACTIONS- 'E0P STEPS ,1
( E.06 Step 11.0- h
. Continue or bagin forced .
circulation aoldown to DHRS' - .< E.06 Step-20.0 conditions. - E.06 Step 23.0
. E.06 Step 24.0 l
I a Observe the following . constraints: ; Cooldown Rata.Lirait - E.06 Step 10.7 oy Subcooling Marg 1n 7 . E.06 Step 8.1 -l
. E.06 Step'14.3 .j
- E.06 Step 16.2 Reactor vessel P-T and . E.06 Step 14.0 (Info page).
l PTS limits. . E.06 Step 17.1 1 '
. Rule 6-
. B.4' s
RCP NPSH (if applicable) . E.06 Step 14'.0-(Info page). '
=!
. .E.06 Step.14.3
.. B.4 Tube-to-shell AT .. E.06 Step 10,7
. - E'.06 Step 16.1.4 :
. E.06 Step 16.2.3 l
j 1 l l l I l , 1 1 l l III.E-25
- l
_ _ - - _ _ - - _ - . _ _ _ _ _ _ _ . - _ . - . _ . - - - _. ____ _ _ 9
--r. .;. <
, 'j
-I i
.; ,,j l
r
~~
- TBD ACTIONS E0P STEPS ,
4 ,
'\ '
'E.06' Step.10.7 )
Fuel-in-compression Limits'. --
* :E.06 Step-14.0.(Info;page). .
- E;06 Step 14.3 '-
l E.06 Step 1 ~.2-1.5'. (Inf o ptge) . 'i Shutdown Margin +
. E'.06 Step 1.0' , ;
B.47
.i 1
'j DIFFERENCES: '. None - , ;
'l l-
.1 1
.i d
1 1 i
-i i I l
1 d l I J i l l i l
.j l 9
-III.E-26 -j
t - u
- - .j 1
TB0 Chapter: III.E J s I 1(~' TED Section(s) 2.5.6. 2.5.7. 2.5_.8_. 1 These sections evaluate pres'urizer s bubble status and provide i direction accordingly. . l T80
REFERENCE:
III.G , TBD' ACTIONS,., E0P STEPS ,_ __ j iI Does a pressurizer cubble exist?- . . Refer.to Analysis of TBD- ! t Flowchart III.E-1, Dif ferette -
#12.
. If a pressurizer. bubble does not- l exist, can it be restored? :
. If a pressurizer bubble cannot be restored, continue.or begin. -
u g solid plant pressure control. .
-l
.i i
DIFFERENCES: None l 1 l' l l
' k
)
l l 1 a 1 i l III.E-27 l m
TBD Chapter: III.E
~;
. TBD Section(s) 2.5.9 TAKE ACTIONS TO ENHANCE IOLE LOOP AND
' RV HEAD COOLING l 1
This step addresses preventative measures to guard against Loop / Head ! Void formation. . , TBD
REFERENCE:
III.G I E0P STEPS i TOD ACTIONS _
. Keep temperature of idle loop - E.06 Step 16.2.3 below saturation by OTSG'feediqg . E.06 Step 20.1.3 l or bumping an RCP in the . B.4, Section 6.0 l idle loop. . E.06 Step 22.0 See Discussion #1 !
1
- Control cooldown and . E.06 Step 20.1.3 depressurization'such that RV . B.4 Section 6.0 heaa fluid. temperature is - E.06 Step 21.0 j 3
maintaiatd below: primary
!aturation temperature.
Disenssion: l The method of humping an RCP to keep idle looop temperature within ) saturatior. is not directly addressed in E.06 as a prevention measured ! for void formation during cooldown. TBD.tection IV.A does not l recognize the circumstances of TBD Step 2.5.9 when discussing < i criteria for RCP bumps. Thes.e circ.umstances'are that the RCS would J he on natural circulation hrve s adequate SCM and RCF's ava413ble for bumping. If this were the essa RCP's would have been started in E.06 Stop E0.0, thus, in effect this consideration wculd have been i addressed by orevious E.06 steps. DIFFERENCES: None III.E-28
l TBD Chapter: III.E ,
~~
TBD Section/s) 2.6.1 PLANT CONDITIONS ESTABLISHED FOR DHR7 , This step acts as a decision point to either enter DNP cSaration if conditions warrant or re-cycle. back to the- beginnind ci tha SGTR ; progression. 4 TBD
REFERENCE:
i TB3 ACTIONS- . , _ _ __.. (OP STEPS
'f Continue cooldown (KPI or OTSG's) until RCS conditions Refer 13 TBD Analysis for'.
allow DHR operation. .butil-than, - q continually check'to see if III.S.2.12, Oifference.#1 ; g l changing ?lant: conditions can i be taken advantage of toL . l establish a more nornal cooldwn. I 1 DIFFERENCE: None
}
U I 1
)
l 1 l l l 1 J
'i
.a
'" III.E-29 l i
'l
-: - _- _ _: r _ _ _
f TBD Chapter: III.E
~~l TB0 Section(s) 2.6.2 INITIATE OHR OPERATION
('" This action is the final action of the SGTR progression, i TBD
REFERENCE:
\
E0P STEPS l TBD ACTIONS
- C P.104
- Place RCS on DHR when plant conditions permit. . B.4 CP.104 l
. If RCS is saturated, monitor -
DHR pump operation and . CP.103 immediately trip pump if NPSH is lost. 1
. l DIFFERENCES: None l 4
l N l i l k 1 l 8 III.E-30
i TBD Chapter: III.F INADE00 ATE CORE COOLING
/' T80 Section(s) 2.1/3.1 IDENTIFICATION OF ICC \
This section describes how the operator determines or recognizes when ICC conditions occur in the core. E0P STEPS T80 ACTIONS ,
. RCS P-T relationship indicates . E.02 Guideline 5 ,
l when ICC conditions occur. ,
. Operator checks alternate . E.02 Guideline 5 instrumentation. ,
i ' . Operator to verify expected . E.02 Guideline 5 plant response with other instrumentation. i
. Operator to inspect RV head . N/A since RV level ;
level as alternate instrumentation does not exist instrumentation, at Rancho Seco. ; l
. Operator to inspect hot leg . E.02 Guideline 5 level as alternate Difference #1 instrumentation. v
. When RCS P-T point reaches . E.02 Guideline 1 the VSM curve, incore T/Cs should be used to determine actual conditions of the core.
. As soon as RC pressure and in . E.02 Guideline 5 core T/C temperature exceeds l the saturation curve operator . E.07 Steps 1.0, 2.0, 3.0, 4.0, must take action as though 5.0 RCS were superheated.
\ I II . F-1
E0P STEPS TBD ACTIONS (' '
. E.02 Guideline 5 (in addition,
- Determine if RCS is saturated simulator training is provided rather than superheated by verifying if incore T/Ct move to inform the operator that parallel to saturation curve. parallel tracking of P-T along right side of sat line is due to instrumentation errors).
E.02 Guideline 5 (incore T/Cs 1
. Response time of hot / cold leg .
RTDs must be considered when are used instead.of RTD's so determinirig if the RCS has concern about response time is become superheated, not warranted). If there is any doubt about . E.02 Guideline 5 (in addition,. , actual RCS conditions, ICC actions required for Region 2 condition should be assuned are about the same as those for and appropriate action taKen. loss of SCM. More drastic actions are only taken when ICC conditions worsen to Region 3 ; or 4). l l r 1 DIFFERENCES:
- 1. E0Ps do not explicitly call out use of the hot leg. level instrument when in ICC, however hot leg level is displayed on SPDS. E.02 i Guideline 5 stresses use cf available instruments to establish the exact state of the RCS, and operators have been trained on the hot leg level indicating system. These factors provide adequate l
assurance that the hot leg' level instruments will be used as inputs j l te confirm or establish actual plant conditions during ICC. l ACTION: Revise E.02 Guideline 5 to incorporate TBD guidance. 4 IMPLEMENTATION: 1 Post Startup. l JUSTIFICATION: l This is an enhancement so the procedure will complement . training. Procedures are acceptable without this change. l t f i l III.F-2 i
i l
.. 1 TBD Chapter: III.F JBD Section(s) 2.2- INITIATE HPI/LPI/CFT l
This section des'cribes the first actions to 'be taken to return the ' RCS to'a subcooled or at least saturated' condition in order to provide core cooling. TBD
REFERENCE:
IV.B 1 TBD ACTIONS E0P STEPS
. Verify maximum HPI/LPI flow. . Discussion #1
. E.07 Step 1.0, 4.0 j
- Rule 1 )
Rule 2
. Verify CFT block valves open . E;07 Step 4.0 l
. Verify CFT levels decrease- . Difference #1 a I
when RCS pressure decreases below CFT actuation point. (
. Open PORV if RCS pressure . E.07 Step 1.2 reaches PORV setpoint and reduce RC pressure to 100 .!
psig above OTSG pressure j and then close PORV. 1 1 DIFFERENCE: I
- 1. Verifying decrease in CFT level when RCS pressure decreases .below the CFT actuation point is not' discussed in E.07.. However, the operators, are trained to verify level decrease when RCS pressure , 1 decreases to or below the actuation setpoint. 'Since the CFT l isolation valves have already been verified open in Step'4.0, !
automatic actuation of CFT injection is' assured. No additional action could be taken based on CFT level changes. Thus'the EOP is acceptable as written. I DISCUSSION:
- 1. Rules 1 and 2 require maximum HPI flow. Verifying LPI initiation means to atsure all actuated components have gone to their.SFAS position which will assure the maximum possible LPI flow for the existing RCS pressure. Additionally the information page lists the
( mikimum. flows for HPI/LPI to assure these limits are observed when. verifying proper HPI/LPI initiation. ; III.F-3 L
1
.. .i TBD Chapter: III.F ,
..-j '
TBD Section(s) 2.3/3.2 TAKE ACTIONS TO INCREASE PRIMARY TO SECONDARY HEAT TRANSFER 1 This section describes the actions to be. taken to increase primary 'to .
~
i' secondary heat transfer. TBD ACTIONS E0P STEPS.
. Increase OTSG levels to' loss . E.07 Step 2.0 j
of SCM setpoint.
. Rule 4
. FW flow must be assured; . E.07 Step 2.0
. Rule 3
. OTSG pressure lowered to . E.07. Step 3.0 f j ~(Information page) <
j achieve secondary Tsat of i =100'F lower than Tsat for existing RCS pressure, q
. Maintain temperature - E.07 Step 3.0 differential as RCS (Information page) depressurizes until ' primary to secondary heat transfer i is established. .
l ( DIFFERENCES: l None l l (
. \
l l III.F-4 1 1 l
~ .
TBD Chapter: III.F
.. )
TBD Section(s1 2.4/3.3 RCS IS IN WHICH REGION OF ICC7
' This section determines the severity lof the actions.taken by the-operator to return.the core to a subcooled 'or saturated condition.
from an ICC region. i TBD ACTIONS E0P STEPS
. If P-T in region 1 of Fig. . E.07 Step 5.1 III.F-1, then proceed with normal cooldown. !
If P-T point is in . E.07 Steps 5.2,.1.0,'2.0, 3.0, Region 2 of Fig III.F-1, 4.0, 5.0 l
,then continue to ensure d
{ maximum HPI/LPI/CFT flow and' continue to induce { J
. primary to' secondary heat transfer. :
i
. If P-T. point worsens into .' E.07 Steps 5.3, 6.0, 7.0, 8.0, Region 3 of Fig. III.F-1, 9.0 take more drastic. actions.
.1 l-
. If P-T point reaches Region 4 . E.07. Steps 5.4,14.0,15.0,.16.0 {
of. Fig. III.F-1, take drastic - 1 actions to minimize core 'l l damage. 4 1
. In all ICC regions, operator . Rule 2 to verify that HPI/LPI/AFW i systems operate correctly and .
. Rule 3 i at maximum capacity, attempts to correct malfunctions. . Rule 4 j
. An intergral part of emergency i operating philosophy is to correct malfunctions rapidly, j and this is included in-simulator. training exercises, thus it is'not specifically' called out in E0Ps.
III.F-5 l i
I r" E0P STEPS 'l
' TBD ACTIONS i
. If RCS conditions enter a more . E.07 Step 5.0 severe ICC region, the operator should transfer to . E.07 Step '10,0 guidelines for the more severe ICC region. ,
. If RCS conditions enter a less . E 07 " Caution" prior to Step C.0 f severe ICC region, the operator should not revert to the actions . E.07 " Caution" prior to for the less severe ICC region. Step 14.0 i
V DIFFERENCES: None i 1 i, 4 l u I i 1 i l l l 1 l l i e III.F-6 1
}
TBD Chanter: III.F l __i TBD Section(s) 2.5/3.4 TAKE REGION THREE ACTIONS TO INCREASE HEAT TRANSFER FROM RX CORE TO RC ICC Conditions have worsened into Region 3 of Fig. III.F-1, thus juskifying more drastic actions to restore adequate core cooling. j i
.j EOP STEPS l TBD ACTIONS
- The kCS P-T relationship is in
- E.07 Step 5.3 Information page)
Region 3.
- E.07 Figure 1 j
- .E.02 Guideline 5 {
li
- Start 1 RCP per loop even though
- E.07 Step 7.0 ,
NPSH N/A. (Information page) {
- Do no'c override normal RCP
- E.07 Step 7.1 '
i l start interlocks. i I
- Once an RCP is started, do not
- E.07 Step 7.2 trip except for motor electrical faults.
- Open all HPV valves to relieve
- E.07 Step 9.0 noncondensables.
l l
- Keep HPV valves open until RCS
- CP.103 Step 12.0 l becomes subcooled or LPI is established.
- E.07 Step 9 l (Information page)
DIFFERENCES: i None i l III.F-7
TBD Chanter: III.F ( TBD Section(s) 2.6 TAKE ACTIONS TO FURTHER INCREASE PRIMARY
\ TO SECONDARY HEAT TRANSFER This section describes actions to be taken to increase primary to secondary heat transfer.
TBD
REFERENCE:
IV.C TBD ACTIONS EOP STEPS
. Depressurize OTSG's quickly to . E.07 Step 8.0. 8.1 achieve a 100*F AT between secondary Tsat and RC Tsat for existing RC pressure. ;
1
. Maintain OTSG levels at
- E.07 Step 8.2 loss of SCM setpoint.
. Rule 3 i
. Rule 4 i
l
- Ensure FH flow . E.07 Step 6.0 l
s
- With no SCH, OTSG level must . E.07 Step 8.2 I
\
be controlled at or above the loss of subcooling margin . Rule 3 ) setpoint.
. Rule 4
. FN flow should be controlled . E.07 Step 6.0 >
to increase and decrease OTSG 1evel to obtain the required . Rule 3 setpoint.
- Rule 4
. AFH must be stopped to the . E.07 Step 6.0 overfilling OTSG before the OTSG level reaches the overfill . Rule 3 setpoint.
. Rule 4 III.F-8
3 ., n e TBD
REFERENCE:
'IV.C . ..
E0P STEPS-( TBD ACTIONS E.03': Step 3.0
*. Start AFW whenever level must . .
be controlled at:the. loss of. ,
- E.07: Step'2.0' SCM setpoint.
- t
*: E.07 Step.6.0-
- Rule 3 Rule 4'-
- Throttle'AFW so'that-level' .~ .
E.07 Step 2.0~
~ progresses towards required 1 ..
E.07 Step'6.0
~
setpoi nt._. *
- ..' .-Rule 3. '
. Rule ~4.
DIFFERENCES:' None 1 0 0 P D III.F-9: e
TBD Chanter: III.F
~'
TBD Section(s) 2.7 PRIMARY TO SECONDARY HEAT TRANSFER ESTABLISHED After Region 3 actions have been taken, the. operator will check to see if primary to secondary heat transfor has been established. l J TBD ACTIONS EOP STEPS l
. Check primary to secondary neat . E.07 Step 10.0, 11.0 l
, transfer. Figure.1 E.07 , l
. If heat transfer has not been * 'E.07 Step 12.0 ,
re-established, then continue l with HPI cooling.
- CP.104 i l
- If heat transfer.has been. . E.07' Step 13.0 established, cool the RCS with CP.103 Step 12 l
OTSGs using HPI/MU to replace . . RCS inventory.
. If ICC conditions worsen to . E.07 Step 10.0, 14,0,-15.0, Region 4, more drastic actions 16.0 are required.
- E.07 Figure 1 DIFFERENCES:
1 None ,. e III.F-10 1
. .E >
-( ). i : >'
'TBD Ch'anter: JIII'.'F 1
TBD Section(si 2.8/355 TAKE REGION 4 ACTIONS TO MAXIMIZE :.
*- HEAT TRANSFER FROM RX CORE TO RC ..
Severe ICC conditions exist thus: requiring ldrast$c action beltaken. to. implement core cooling. - r
, u TBD ACTIONS
'EOP STEPS ] 9
. E.07 Step 5.4.(Information page)
. RCS P-T point is in Region 4. .. E.07 Figure ~1'
. :E.02 Guideline 5
.]
. Start all RCP's'.. . . E.'07 Step 14.0-
. Defeat ^RCP. start' interlocks. . E.07 Step 14.1'.1,>14.1.2-
. Do not defeat RCP motor .L E.07. Step'14.3, 14.3.'l- 1 overload trip circuit.
. E.07 Step'14'0 .
(Information page) ' i , ['-
. Open all HPVs PORV and PORV block valve.
. E.07 Step 16.1,'16.2, 16.3
~
l
. Depressurize RCS until LPI .: E.07 Step 16.4 restores core cooling.
. Depressurize OTSGs as . E.07-Step 15.1 quickly and as far as possible if aux steam is available to power AFN steam-driven pump.
l .
. Depressurize OTSGs as quickly . E.07 Step 15.2 as possible to minimum pressure which is needed to power AFM l
steam-driven pump if aux steam is not available.
.. Refer to III.F. 2.9/3.5:
. Open dump-to-sump.. valve Difference #1 DIFFERENCES:
i % . None " l III.F-11
- -_=--
j
~ .
TBD Chanter: III.F' - - -
- TBD Section(s) 2.9/3.5 TAKE ACTIONS TO MAXIMIZE-PRIMARY-TO-SECONDARY HEAT TRANSFER
-This section describes action to be taken to maximize primary-to-secondary heat transfer.
TBD ACTIONS EOP STEPS
. Depressurize operating OTSG's. *- E.07 Step 15.0 as quickly and as'far as possible.
. Startall'RbP's._ + E.07 ' Step 14'.0
.. Defeat RCP start interlocks.-
- E.07 Step 14.1.1. 14.1.2'
. Do not defeat RCP motor . E.07 Step 14.3, 1.4 3.1 overload trip circuit.
- E.07 Step 14.0 (Information page)
. If RCP trips on overload, save . E.07 Step 14.3.1 the RCP so that it can possibly be restarted later.
. Depressurize RCS as quickly as e E.07 Step 15.0~
possible'to achieve CF and LPI-cooling.
- E.07 Step 16.0-
. Depressurize OTSG's as quickly . E.07 Step 15.1 and as far as possible if aux steam is available to power AFH steam-driven pump.
- Depressurize OTSG's as quickly . E.07 Step.1.5 2 as possible to minimum pressure which is needed to power AFM steam-driven pump if aux steam is not available.
t III.F-12 1
1 i 1
. . 1 EOP STEPS j
/- TBD ACTIONS i
. Open all HPV's, PORV, and . E.07 Step 16.1, 16.2, 16.3 l PORV block valve. .
;j
- Open dump-to-sump valve. - Difference #1. j J
-)
DIFFERENCES '
- 1. TB0 ICC states that all possible valves that vent to the RB should be 1 Lopened, including dump-to-sump valve-(HV-20003). E.07 does not ;
include the instruction to open HV-20003. In order to. utilize J l HV-20003, HV-20001/HV-20002 would have to be opened,'which could allow over-pressurization' of' the OHS (300.psig rating). Overpressure could cause rupture of.the line, thus eliminating the use of the OHR mode of cooling as an option later in the event ~. Thus, E.07 excludes opening HV-20003. 4 1 i ( ' l i l l I l l l i l l l I 7b III . F-14
.o TBD' Chapter: III.F-
[ TBD Section(s) 2.10' INCORE T/C'S RETURN TO SATURATION ? This section provides .for continued action to' combat ICC or'provides' for cooldown if incore T/Cs return.to ' saturation. . TBD ACTIONS E0P STEPS
. If the RCS P-T relationship' . .E.07 Step.19.0' remains'in ICC continue with-region 4 actions.
- When incore'T/Cs return'to . E.07 Step 17.0 L "
. E.07 Step.18.0 l '
saturation.fcontinue cooldown E.07 Step 19.0
.as normally as possible .
DIFFERENCES: None ) t
-i l
l l i 9
~!
~
III.F-15 I l ______.________..u _ _ _ . _ _ _ _ _ . _ _ _ ._ :_]
( r i
. - l TBD Chapter: III.F TBD Section(s) 2.11 CONTINUE LONG TERM COOLING y
)
In this section, RCS pressure is maintained low to ensure maximum l LPI for core cooling. . TBD
REFERENCE:
TV.F. IV.B E0P STEPS TBD ACTIONS
. Maintain RCS depressurized to- - E.07 Step 16.0 ensure maximum LPI flow f
. Transfer LPI suction to RB sump - E.07 Step 20.0 when BWST reaches the sump switchover point. 1 4
. High rad levels in RC warrant . Caution statements prior to E.07 l appropriate rad precaution be Step 20.0 l invoked. . Caution statements prior to E.07 i Step 23.0
. Decay heat system can be used . E.07 Step 24.0, 25.0, 26.0, ;
for cooling if subcooling 27.0. l
; exists (Ref. Chapter IV.8) . Caution statement prior to E.07, Step 26.0.
I
. Perform necessary actions to . Refer to analysis of control RB containment systems Chapter IV.F (Ref: Chapter IV.F) n <
DIFFERENCES: None
\. I II . F-16
T80
-~
Chapter: III.G. COOLDOWN ._l TBD Section(s) 2.1: DETERMINATION OF C00LOOWN RE0VIREMENT This section is the entry section for plant cooldown and also discusses some broad considerations regarding plant cooldown, philosophy. TBD ACTIONS E0P STEPS
. Cooldown decision based on
. Cooldown decision will occur evaluation of specific plant during execution of the j conditions and considerations applicable E0P for the plant i of future plant safety and transient in progress.
control at hot shutdown vs cooldown with abnormal - Remaining at hot shutdown vs ; j conditions. cooldown with j abnormal 1 conditions decision ' will follow with execution of the applicable E0Ps. l i
. Restore the plant to as near . The fundamental premise of the normal conditions as possible E0Ps is to !.= ovide the actions prior to cooldown. required to place and maintain ]
the Rx in a safe condition. ' ('. Execution of the E0Ps will result in the plant being returned to a normal as l possible status, i l
. Maintain shutdown margin . Difference 1 l during cooldown. l 1
I DIFFERENCES:
- 1. No explicit direction is given in the cps to monitor / verify shutdown margin during cooldown. However, in CP.101, CF Tanks are emptying and injecting borated waters into the core. CFT boron concentration is predetermined to ensure adequate shutdown at cold post LOCA conditions.
In cps 103,104,105 either CFTs are actuated or HPI/LPI is activated which results in borated water being injected into the core. BWST boron concentration is also predetermined to ensure adequate shutdown at cold 4 conditions. In CP.102, which branches to either Section 5 or 6 of 8.4, Limits and Precautions exist to remind the operator of the 11% shutdown requirements. Because the baron concentration in the CFT/BWST has been predetermined to ensure adequate boration at cold conditions and B.4 contains requirements for 11% SD margin, and operator training covers shutdown requirements, CP revision is unnecessary. III.G-1
y + ' ) L J
~
'TBD Chapter:' III .G. COOLDOWN TBb 'Section(s) 2.2.1/III.B: SUSC00 LING MARGIN
'l This section verifies'whether or not subcooling margin exists.
.,,3 l
TBD ACTIONS' 'EOP STEPS
- Verify'subcooling margin. .. CP.103, Step 1.0
- CP.104 : Step 1.0
~ Guideline 1 Monitor SCMLduring cooldown - CP.104 Step;1.0 l- .
until DHRS'is placed into - CP.104, Step 9.1 I CP.104 Step 9.3 :l; service. .. '
- CP.104' Step -11.3 i
. . . CP.104 -Step 12.3 : -
.]
; CP.104 Step 17.0;. ,
-i e' CP.105 Step 3.6.
. - CP.105 Step 5.2 :
+ CP.105 Step 7.1',o7.2 =
+ . CP.105:. Step . 8.1, 8.2 - {
. . Guideline 1 DIFFERENCES:
i None { l a i I i
' :i III.G-2 i - _ _ - _ _ - x - -_-- -_ - -- _
~
- j. l f
TBD Chapter: III.G- j
#~
TBD Section(s) 2.2.2/III.B: TAKE' ACTIONS FOR LOSS OF SCM :. This section provides actions for the operator to take upon loss of-SCM. .. J l TBD ACTIONS E0P STEPS l 4
. Trip all RCPs or verify all . ~ E.03 Step 1.0 RCPs tripped.
- Guideline 1
.. Initiate' full HPI or verify .
Rule 1. Rule' 2 full HPI. . E.03 Step 2.0
. CP.101 Step 5.0
. CP.103 Step 1.1
. CP.104 Step 1.0 ;
I
- CP.104 Step 9.1
. Raise OTSG levels to loss' of' . Rule 3, Rule 4 SCM level setpoint or verify . E.03 Step 3.0 levels rising to loss of . CP.103 Step 1.2 SCM level setpoint. . CP.104' Step 9.3
. CP.104 Step 11.3.2 l l CP.102 Step 1.0 I
- When SCM is restored, . .
restart RCPs. . CP.103 Step 6.0, 7.0
. CP.104 Step 4.1 ;
. CP.104 Step 12.2.2 l
. CP.105 Step 2.0 ;
. When SCM is restored, shift . Rule 4 4 OTSG 1evel control to the appropriate setpoint.
. When SCM is restored, throttle . Rule 2 HPI (MU) flow as necessary to . CP.104 Step 4.2 ,
maintain pressurizer level . CP.105 Step 3.0 and at least minimum SCM. . CP.105 Step 5.2
. CP.105 Step 7.0-9 III.G-3
4 - i .,, t
~
TB0 ACTIONS EOP STEPS ['
. Maintain RCS pressure below .. ' Rufe'6 the PTS limit. - Rule 2,'
- - CP.105' Step' 3.1 CP.105 Step ' 5.3 '
~
4 DIFFERENCES:- None - a I ( x III.G-4 w-. _ _ _ _ . ___ . _
$'i b j.4 ,
t .,. , ,
.,. , . a
- p.
.s' TBD Chapter:f III.G
*- :TBD Section(s) 2.2.3/II.B.'III.C. III.Di PRIMARY ~TO-SECONDARY' w ' A.- '
HEAT TRANSFER This section determines N contro11edlheat transfer is occurring in both OTSGs since the. preferred.cooldown method-is'a normal'cooldown a.
.with forced' flow and controlled heat transfer;via!.both OTSGs.. -c T8D ACTIONS E0P STEPS' <
.- ~ Verify controlled heat transfer .. Guideline l 3
. Guideline 2. ' :j
.in'both OTSGs.
Ref. Chapters II.B. III.C. .: l Guideline.3; 't.! l III.D.. ,
'CP.103 Step :1.0'
.. CP.103 Step .4'.2 -
. CP.103. Step 4.4 4
. CP.103 Step 5 ~0 .
CP.'103' Step. 8'.0;
.. . : CP.104 Step' 7.1; .
.. '.CP.104 Step 111.4 !
. . CP.104 Step 13.0 ;
.. CP.104 Step 16.0 '!
- . . - CP.102 Step LO-DIFFERENCES:
None 1 l, i
- )
l
'l 1
I i- 1 III.G i
, t 1
.g.
u----__-___.s.__ . _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _
l TRO Chapter: III.G i TBD Section(s) 2.2.4/III.C. III.D: -LOSS OF CONTROLLED PRIMARY
TO SECONDARY HEAT TRANSFER l
i This section takes action to restors contro17ed heat transfer in at least one OTSG and preferably in both OTSGs. l l i TBD ACTIONS E0P STEPS
. Take actions to restore heat CP.103 Step 4.04
. transfer to at least one CF.103 Step 6.2 4 CP.103 Step 7.0 i OTSG, preferably both OTSGs.
Ref: Chapters III.C, III.D. CP.104 Step 9.0,11.0,12.0,16.0 ! l 1 DIFFERENCE"- - 1 None l l , 1 ( l
)
1 1 I l l 1 l e
~
III.G-6 I
, y ( .-
',l';. , . ; y
, . * *' +
.TBD:Chaptert 'III.G ~
,, 1..[
' TBD Section(s) 2.2.5/III.C. IIIiD- HEAT TRANSFER IN AT t. EAST t
' .ONE (1) OTSG >
J This:sectiondeterminesifcontrolled. heat)transferexistsin'at. - , least one OTSG. ,
'{ i 4
'TBD ACTIONS ~
E0P STEPS-E.0475tep 2.0l i
.If' primary to. secondary heat l
- transfer is lost and cannot ~ . E.04 Step 5.0' be restored to either OTSG,
- CP.103 Step 5.0 '. 1 CP.104 Steps 3.0,l 2.0,: 3.0,.
~
then utiiize HPI/MU cooling. 1. ' , Ref: Chapters.III.C, III;0. :.4.0,:5.0'!6.0,.7.0, 8.0;.15.0- :i l 1 DIFFERENCES ' ' I l ' -l
- None ,
- t. q I
i
.i 2
Y .) III.G-T u ll ['
-TBD' Chapter: III .~ G TBD Section(s) 2.2.6/3.5: NUMBER OF OPERATING OTSGs This section. discusses l actions based upon the. number of OTSGs its operation. ..
'TBD ACTIONS E0P STEPS
. 'If operator can control. . CP.102 Step' 2~.0 feeding and steaming of both - B.4 Section'5.0 OTSGs~,, continue cooldown in a normal mode.
- If the operator can control' .- E.04 Step 3.0,'7.0,.11.0,~12.0, heat removal in only one 16.0 OTSG, attempt to restore -
primary to secondary heat transfer in the other OTSG. DIFFERENCES: None l l III.G-8 J
I
~~
TBD Chapter: III.G l l TBD Section(s) 2.2.7/3.9/IV.B: INITIATE HPI COOLING l This section initiates HPI' cooling because neither OTSG can provide primary to secondary heat transfer. TBD ACTIONS , , _ E0P STEPS
- Initiate HPI cooling. . E.04 Step 2.0, 5.0
. Rule 1, Rule 2
. CP.103 Steps 5.0 - CP.104 Step 1.0
. Maintain HPI cooling until . CP.104 Step 1.0, 2.0 DHRS initiation it OTSG . Rule 1 heat transfer can't be . Rule 2 restored. < CP.104 Step 15.0 f
}
. Continue efforts to restore . Rule 3 OTSG heat transfer while HPI . Rule 4 cooling is in progress. . CP.104 Step 9.0,11.0,12.0, 13.0, 16.0
. CP.104 Step 14 1
DIFFERENCES: 1 None i l l 1 i I D ' III.G-9 ; l l 1
- --- _ _ o
'l
- )
TBD Chaoter: _ III.G l
.R
' RCP STATUS TBD Sect %n(s) 2.3.1/3.2:
This section determines whether.or not any RCPs are in operation. .]
}
.. _ ')
-'I TBD ACTIONS E0P STEPS _
Determine if any RCPs are .' CP.102 Step :1.1, . 2.0 'j in operation. .- C?.104 Step 9.2,10.0, ,11.0, 12.0
. CP.105 Step . 2.1 1
)
a
,1
' 0IFFERENCES: .
i l' None ,., 1 i 1 a
- i. .
o
., 1 1
l i
.l l
III . G-10 l 9 2 _ _ _ _ _ . - _ _ _ _ . _ _ _ _ _ _ _ _ . . _ . . _ _ _ . _ _ . _ _ _ _ _ . _.
. m. . ;
TBD Chapter: III.G . . . , 4 j TBD Section(s) 2.3.2/IV.A: CRITERIA FOR'RCP RESTART-This section describes the criteria.for RCP restart. 4 I
'TBD ACTIONS EUP STEPS' q If RCPs'not operating, then a CP.102 Step le't -4 CP.103', Step'4 A:. y attempt.to, satisfy restart criteria as soon as' possible. 1 C9.103 Step 6.0, 7.D :.
S
.: CP.134. Step 4.1 i CP.104'Stq] 9.??
' CF.104 Step' 12.2.2; .12.3,14.0
?
. . CP.106 Step' 2.0 ?
')
___ _ j
~ c'
<l DIFFERENCES:
I Nonc I i 1
'1 l
'l '
l .s i t i
'I 2
.j l
l l III .G ; l
3-
' t1 EC,hAptir: _ III.G __
7~5- TBD Section(s) 2.3.3/IV.A: RESTART RCPs- /. t
- s. 1 This section discusses precautions anti recommendations to be consideres before RCP restart..and for expected system responseito.RCP restart. s Section.2.3.3 cal?s for resthrting' RCPs when the criteria. for.RCP: <
operstion cre satisfied. Section 2.3.3 also references Section'3.9.1 which discuss RCP' operation considerationsLapplicable for HPI cooling. Reference Chapter IV. A.(Equipment Operation - RC Pumps) for this iBD section; all actions' required by 2.3.3 are discussed in, Chapter-IV.Ai ,
]
'I a
III . G-12 u________ _ __ . . _ _ )
' i'I.r . j. .
s;7 L ' 7: y/h Qlh v .c O W , 0 T80 Cha'ote'r: 'III.G~ ,
= TBD SectioN s) 2.4.1/3.4: PRESSIJRIZER STATUS' . . . .[m,y This section ' determines if a pressurizer bubble can be maintained or-restored. ~
3 T80 ACTIONS ~EOP STEPS q If pressurizer steam-bubble.- :. CP.105 ' Step 4.01
'does not exist and.cannot . ,,h
'be drawn, then solid' plant . .
1 pressure; control.is" required. %: ,j q If normal pressure control l ,- CP.163 Step .4'.4 ;
.~
.. . E,04.. Step 11.2.1 1 is hindered due:to-voids in
- )
h'ot' leg or 3V head, take L d action to eliminate voids. '. jj (Bump RCPs, open HPV.) . a;
. If steam bubble exists in' -. CP.105 Step.4.0-pressurizer, but heaters , . .
and/or spray is lost,. solid; plant pressure contro1 Tis l l ( t required if pressurizer can't be maintained as hottest ; part'of RCS. f 1
. Prevent pressurizer safety.s. . CP.105 Step 7.0 valve challenge. .
CP.105 Step 3.1, l-l
. Use pressurizer vent instead ~. Refer to analysis ofiTBD of PORV to eliminate steam III.G 2.4.2/3.4.
bubble if solid plant . Difference.1 pressure control is warranted. l Refer to analysis of TBD.
. As pressurizer vent is closed, .
MU should be throttled to- III B. 2.4.2/3.4 i stop pressure increase when Difforence #1-filling pressurizer solid.- J
-1
. Utilize NU and letdown to . CP.105: Step 7.2 control RCS pressure during- .<
CooldoWD. III .G-13
.j
'l
_ = = -__ . .- .. .
. . /
TBD Chapter: I' I I , G' .
~ ..l'$ TBD Section(si 2.4'.2/3.4: SOLID PLANT PRESSURE CONTROL This section discusses solid plantJpressure control.
TBD ACTIONS' 10P STEPS
'. Control primary pressure - . CP.105 Step '7.0 using MU/HPILand letdown.
Prevent pressurizer. safety . . CP.105 Step 7.0 valve challenge.
~
. .CP.105 Step 3.1
- Use. pressurizer' vent instead '.
. Difference;.1 of PORY to-eliminate steam .
' bubble >if solid ~ plant pressure control is ' warranted.
. As pressurizer. vent' is closed; . Difference 1 MU should be throttled to i stop pressure increase when
. filling pressurizer solid.
(" 1
. Utilize MU and letdown to . CP.105 Step 7.2 control RCS pressure during cooldown. ,
1 DIFFERENCES:
- 1. These TBD steps for transition from pressure control with a' steam b'ubble.
to solid plant control do not. presently existtin the E0Ps. Simulator experience suggests that intentionally removing prz steam bubble'may not L I be desirable.
.l l' Action:
' Consider procedural steps for above pressure control' transition.
Implementation: A 1 Post Startup l
, Just*ification:.
This TBD action is not necessarily an enhancement and therefore it' is not desirable to make such EOP changes at this time.- ( II I .G-14 q oc
- o. . + - - ______--_a
..} j b';j s'
- .. . . .n TBD Chapteri ' I I I .' G s ..
TBD Section(s) 2.5.1/3.1/3.2:-- NORMAL PLANT COOLDOWN This,section is covered'by OPOP-B.4'and'provides instructions for normal. - cooldown (adequate SCM, forced flow,;two OTSGs operable, normal RC~ pressure. control with a prz steam bubble). . E0P STEPS'
'T80 ACTIONS _
. Normal:cooldown procedure . E.01(Step 3.0 Guideline'1
~
will' redirect to the. cps if - abnormal plant conditions . Guideline 2 develop during normal' cooldown. . Guideline'3
- -Guideline 4 v
DIFFERENCES' None ( .. 1 a
-i i
I i III . G i I .
e 5 i .,.?.
~
TBD Chapter: 'III.G. __,
' ~
' TBD Section(s) 2. 5 . 2 /3.1/3 '. 2' i FORCE 0' CIRCULATION C00LOOWN
, 1 This section discusses Abnormal l forced l circulation cooldowns (one
' operable OTSG and/or . solid plant pressure control)..
TB0 ACTIONS 'EOP' STEPS ^
-.s
. Attempt to restore' inoperable. .: ..Thissaction is considered an.
automatic operatorJ action L and-- 10
- equipment so.that a normal cooldown can be initiated. is ' theref ore ~ not J requi red ito be explicitly described in:the-
~
E0Ps.
. Continuously monitor cooldownL .. B.4 L&P 3.1',.3.2 rate. .
- B.4 Enclosure 7.2
. .B.4 Step - 5.11:
. Continuously < monitor SCM.- . Guideline-1'
,. . CP'103. Step 1.0
. C P.104.. Step ' 1.0 1
.- CP.105 Step 3.0; 5.0,' 7.0 1 4
- RuleL1,. Rule 2. d
. CP.105 Step 8.2- l
.: CP.104LStep 9.1
. - Continuously monitor NPSH. . B.<4 L&P 3.9' j l
. Continuously monitor tube- .? B.4 L&P 3.22- :I to-shell AT limits. . 'CP.102 Step' 3.0 1
l
. Continuously monitor fuel- . Rule'6' .
in-compression limits. . CP.105 Step . 3.1 j
.- CP.105:Stepj7 .1 )
l' - Continuously monitor shutdown.
- B.4 L&P 3.7, L 3.8,- 3.13 l margin. - .. 1B.4 Note before. Step 5.9 .l; l
1b 4 II I . G-16
I E0P STEPS TBD ACTIONS ([.
. Utilize aux spray to . E.06 Step 10.5 depressurize if. AT limits - CP.102 Step 3.3 ,
. J permit. !
. Once aux spray initiated, . - E.06 Step 10.5 .
maintain continuous minimum
. Difference 1 l flow to limit thermal cycles.
. Maintain HPI recirc flow. . Rule 2 _
I
. CP.105. Caution bef ore ~ Step 3.1
. Adjust letdown to control . CP.105 Step 3.2 ;
prz level.
. Monitor quench tank to prevent' . Monitoring instrumentation is an blowing rupture disk if. expected operator action and-is, utilizing PORV or prz' vents not required to be delineated -
to depressurize. in the E0Ps. In addition, annunciators reinforce relief
,' tank conditions to the operators.
. During venting, adjust . E.02 Step 7 l- HPI/LD to maintain RCS inventory and pressure control.
. If voids form during venting, . Difference #2 stop venting.
l
. To minimize RCS pressure . Difference #3 reduction due to ambient losses, maintain prz level as low as practical.
. If depressurization can't be . A.3, " Normal Pressurizer 1 accomplished with aux spray, Operation" I EMOV, or prz vents, drain . B.4, Section 5 and fill prz to depressurize.
- i. '
III.G-17 ;
i DIFFERENCES: __; CP.102 does not include guidance to continue aux spray flow once. ( l. initiated.
)
Action: i Revise CP.102 to include guidance on continuous aux spray f' low once ] initiated. : Implementation: Post Startup j Justification: This'is an enhancement to limit thermal. stresses to the
- pressurizer. This enhancement is not required to safely shutdown /cooldown the plant following a transient.
- 2. This TBD enhancement is not' included in the E0Ps. When depressurizing the RCS with pressurizer vents the' operators are given guidance (Reference E.06 Step '14.3) and are trained to nmnitor and maintain -
adequate SCM. In addition,'upon loss of SCM, E.03 has the operators close vents. This would perform the TBD function. This. step is therefore not required. l
- /d Operators utilize HPI to maintain RCS pressure. The effect of ambient.
3. losses on pressure control would be negligible relative to control'of HPI. I i 1-1 (
III . G-18
I TBD Chapter: III.G
~~!
TBD Sectiotts) 2.5.3/3.1, 3.2. 3.3: COMMENCE NAT CIRC COOLDOWN This section discusses required actions during natural circ cooldown. E0P STEPS T80 ACTIONS
- Continuously monitor cooldown . CP.105 Step 8.2
. CP.102 Step 3.2 rate.
- B.4 L&P.3.2, 3.1 l
. B.4 Step 6.1.7.1, 6.1.7.3 j
- CP.105 Step 5.3 <
- 8.4 Enclosure 7.2
+ Continuously monitor SCM '. CP.105 Step 8.2
. Guideline 1
- Rule 1, Rule 2
- B.4 Step 6.1.7.4
- B.4 Step 6.1.7.5
- CP.104 Step 1.0
. CP.104 Step 9.1 i
. CP.105 Step 3,0, 5.0, 7.0
. Continuously monitor PTS limits . E.02 Figure 1
- Rule 2 8.4 Ster 6.1.5
. CP.105 Step 5.3
. Rule 6
. Continuously monitor NPSH. . B.4 L&P 3.9
- B.4 Step 6.1.6.2
. Continuously monitor OTSG - CP.102 Step 3.0 tube-to-shell AT limits. . B.4 L&P 3.22
. Continuously monitor fuel- . Rule 6 in-compression limits. . CP.105 Step 3.1
. CP.105 Step 7.1 l l
l I 95 II I . G-19
TBD ACTIONS E0P STEPS (
. Continuously monitor shutdown . B.4 L&P 3.7, 3.8, 3.13 margin. .
. Make attempt to return plant - CP.102 Step 1.2, 2.0 status to the normal cooldown - CP.104 Step 4.0 path whenever possible. . CP.104 Step 9.0,10.0,12.0, 13.0, 14.0
- CP.105 Step 1.0, 2.0
. If normal prz spray is N/A, . B.4 Step 6.1.7.5 and solid plant pressure
- control is not required, use aux spray if available.
. Take action to eliminate . CP.102 Step 1.0 head or loop voids. . CP.103 Step 4.4
. CP.104 Step 12.3,14.0
. Aux spray limited by temperature . CP.102 Step 3.3 between sDray nozzle and spray - B.4 L&P 3.3 water, AT < 410*F.
t
. Once initiated, a continuous Reference III.G Section '
minimum flow should be 2. 5. 2/3.1/3. 2. maintained to limit thermal cycles. Difference 1
- Maintain HPI pump recirc flow. . Rule 2
. Remove DH with naturai circ . B.4 Step 6.1.4 and maintain existing RCS . CP.103 Step 6.0, . 7.0 '
conditions until RC pumps . CP.105 Step 2.0 become available. . B.4 Step 6.1.6 i l
. Limit cooldown rate when in . B.4 Step 6.1.7.1, 6.1.7.3 natural circ to preclude head void formation.
III.G-20
)
l.
. 8
--l TBD ACTIONS E0P STEPS
. To prevent head void formation, . B.4 Step 6.1.7.1, 6.1.7.3 head cooling must be enhanced. ,
. Raise OTSG 1evels to natural . Rule 4 circ setpoint. . S.4 Step 6.2.2
. Rule 3
- If RCS is saturated, raise . Rule 4 OTSG levels to loss of SCM e CP.104 Step 9.3 setpoint. . Rule 3
. Use TBVs or ADVs to control - CP.103 Step 4.0 r.ooldown rate. . CP.104 Step 16.0
. Ensure shutdown margin. . B.4 L&P 3.7, . 3.8, 3.13
(
- Verify natural cire is . B.3 L&P 3,21 occurring. . B.4 Step 6.1, 6.2, 6.3
. Guideline 2
( DIFFERENCES None l
~
\ \ l l' l ! 1 e l III.G-21
TBD Chapter:- III.G-I TBD Section(s) 2.5.10 TAKE ACTIONS TO MITIGATE LOOP'AND RV-
\ HEAD VOIDS AS NECESSARY This step provides guidance for mitigating loop or head voids should they form.
TBD
REFERENCE:
III.G E0P STEPS TBD ACTIONS
. . Eliminate Head Voids By:
- Venting
- E.06 Step 21.1
- Ambient Heat Loss . E.06 Stro 21.2 See Difference'#1
- RCP Restart . Refer'to Analysis for TBD Section III.E. 2.5.9, Discussion #1.
. Eliminate Loop Voids by:
- Venting through HPV's . E.06 Step 22.2
- Bump an RCP - E.06 Step 22.1
- Ambient Heat Loss . See Difference #1 Differences
- 1. The TBD states that one method of possibly collapsing an RCS void is by ambient loss. However, the TBD also states that this method is a slow process and may require extremely long cooldown times. E.06:
does not contain direction for allowing ambient heat loss to collapse an RCS void since, as the TBD states, it would prolong the cooldown. This would be contrary to a basic objective of completing a cooldown as soon as possible for a SGTR situation. Action: None required. Direction provided by E.06 to mitigate an RCS void incorporates the most expedient methods while allowing continuation of the cooldawn to comply with the basic SGTR objectives.
)
- - III.G-22 l
1
TBD Chapter: III.G (s TBD Section(s) 2.6.1/3.6. This section discusses shell cooling concerns.during natural circulation cooldown or forced circulation cooldown with an idle loop. ' I i E0P STEPS TBD ACTIONS i
. Limit tensile tube-to-shell . CP.102 Step 3.1, 3.2 AT <100*F .
)
. Limit compressive tube-to- - Difference #1 ;
shell aT <60*F. j CP.102 Step 3.1 l
. Ave OTS'G Shell Temp - cold < .
1 Tensile tube-to-shell AT. l i
. Thot-Ave OTSG Shell Temp < . Difference #1 l J
compressive tube-to-shell AT. !
\
. If the idle loop is pressurized, . Difference #1 l'
( s use Tsat of the pressurized OTSG for cold in calculating Tensile tube-to-shell ATs.
. If tubes are cooling fastnr . Difference #1 l
than shell, decrease cooldown rate. l l
- If tubes are cooling faster . Difference #1 than shell, increase shell cooling.
. Cool OTSG shell by injecting - Refer to TBD IV.C 4.0 AFW. Difference #1 i
. Difference #1
- If AFW injection is causing . Difference #1 Tube-to-shell AT limits to be approached, then stop AFW III.G-23 1
E0P STEPS TBD ACTIONS
. If MFW is used for OTSG shell
. Difference #1 cooling, a small but continuous flow is required to minimize .
l thermal cycling of the lower tube sheet.
. During forced flow, if idle . Dif ference #1 OTSG sh' ell cools to slowly {
and causes tube-to-shell AT limits to be approached, then slow cooldown rate of active loop.
. During forced flow, if idle . Difference #1 OTSG shell cools too slowly and causes tube-to-shell AT limits to be approached, -
attempt to establish heat ) transfer to the idle OTSG.
- . . l i
1
. To prevent saturated conditions . Difference #1
' in idle loop and preclude excessive compressive tube stresses, induce natural circulation in idle 1 cop by j
injecting AFW and steaming idle OTSG. Difference #1 l
. Perform actions to cool idle .
loop before the active loop temp decreases below the idle OTSG shell' temp by 100'F. k., III.G-24
y(,, DIFFERENCES: ..
' 1. . The~TBD' guidance on Idle Loop' Cooling is an enhancement'over ATOG and I has not yet been . incorporated .into the TBDs. .f-
. Action:~
Upgrade E0Ps to include additional TBD guidance for Idle Loop . Cooling. Implementation: Post =.Startup Justification: This is an enhancement.o'ver ATOG'to'obtain improved' plant control-and.is not required to ensure. cote protection. These changes, therefore, are not required prior to startup. i
'i l
III.G-25
,.j
TBD ChaDter: III.G TBD Section(s) 2.6.2/3.7: RV HEAD COOLING CONCERNS [' This section discusses vessel head cooling concerns (void prevention, void recognition, and void elimination). . E0P STEPS TBD ACTIONS
. B.4 Step 6.1.7.1, 6.1.7.3
.- Maintain slow cooldown rate B.4 Note before Step' 6.1.7.3 to preclude head void -
formation. Maintain slow depressurization . B.4 Note before Step 6.1.7.3 l rate to preclude head void - formation. Maintain temp at RV head . 8.4 , Step 6.1.7.1, 6.1.7.3 fluid less than primary . B.4 Note before Step 6.1.7.3 saturation temperature.
. Periodically bump RCPs to . Refer to TBD IV.A.3.7 keep RV head temp low. Difference 5
. Utilize active RV head vent . N/A, since head vents are not system to cool head for installed at Rancho Seco.
void prevention.
. Utilize passive RV head vent . N/A, since head vents are not system to cool head for installed at Rancho Seco. l void prevention.
. Detect head void formation by . N/A, since head level utilizing RV head-level instrumentation is not measurements, installed at Rancho Seco.
I III.G-26
\
i
- . i i
i E0P STEPS TBD ACTIONS B.4, Caution statement before i
. Detect head void formation by .
Step 6.1.7.3. I observation of plant response 3 (difficulty in reducing { pressure, opposite trending ,, i l between RC press and prz level and/or MUT, RVC head fluid temp, passive RV head
)
vent temp). { Assume that any void forming . B.4, Caution statement before { Step 6.1.7.3. is a RV head void if natural f circulation flow can be verified in each loop. Eliminate RV head voids by . N/A, since head vents are not . venting
, installed at Ranche Seco.
Eliminate RV head voids by . Refer to analysis of IV.A 3.7 Difference #5 RCP restart.
. Eliminate RV head voids by . IV.A.3.7 Difference #5 ambient heat loss induced condensation.
Increase MU flow to compensate . N/A, since head vents are for head venting. not installed at Rancho Seco. i Avoid increasing void size . N/A, since head vents are not due to depressurization after installed at Rancho Seco. vent is opened. Maintain or slightly increase . N/A, since head vents are not j RCS pressure during venting. installed at Rancho Seco.
. N/A, since head level ,
. Utilize RV head level instrumentation is not 1 measurements only as trend !
trend when eliminating installed at Rancho Seco. head voids.
. Refer to analysis of l
. Restart RCPs to eliminate IV.A 3.7 Difference #5 l head voids. \
l DIFFERENCES None III.G-27
m d n TBD Chapter: III.G
..i j
TBD Section(s) 2.6.3/3.8: IDLE LOOP COOLING CONCERNS This'section discusses idle. loop concerns during natural circulation cooldowns'(void prevention, void recognition, and void elimination). E0P STEPS j TBD ACTIONS
. Attempt'to prevent idle loop . Refer to analysis of TBD.III.G voids by maintaining fluid 2.6.1/3.6 Dif ference #1.
temp in idle loop below saturation by bumping an RCP ] in the active loop. 1
- Attempt to prevent _ idle loop . Refer to analysis of TBD III.G voids by maintaining fluid' 2.6.1/3.6 Dif f erence #1 ,
temp in idle loop below ! saturation by periodically injecting AFW into idle OTSG.
. After injection of AFW, observe . Refer to analysis of TB0JIII.G primary response. 2.6.1/3.6 Dif ference #1
. Limit AFW to 5 700 gpm to a . Refer to analysis ofLTBD III.G dry OTSG when idle loop tube- 2.6.1/3.6 Dif ference #1 to-shell AT is increasing
- to within 10F of the tensile AT limit.
. Limit AFW to $700 gpm to a . Refer to analysis of TBD III.G l dry OTSG when the saturation 2.6.1/3.6 Difference #1 J temp during cooldown is j reduced to within 10*F of the idle loop hot leg temp. ;
. Limit AFW to 5700 gpm to a - Refer to analysis of TBD III.G dry OTSG when the active 2.6.1/3.6 Difference #1 loop temperature is reduced more than 50'F below the idle loop temperature.
DIFFERENCES: 2 None
$II.G-28 8
4
1
--l E0P STEPS
; TBD ACTIONS 1 ;
- Initial AFW injection should . Refer to analysis of TBD III.G i '
be 2 to 3 minutes in duration. 2.6.1/3.6 Difference #1
'1 1
. Observe idle loop Thot/ cold . Refer to analysis of TBD III.G l 2.6.1/3.6 Dif f erence #1 )
and tube-to-shell aT after ) AFW injection. i
. Continue idle loop AFW . Refer to analysis of TBD III.G injections if active loop 2.6.1/3.6 Difference #1 continues to cool.
- Once idle loop natural . Refer to analysis of TBD III.G circulation is established, 2.6.1/3.6 Difference #1 maintain OTSG inventory ,
for steaming OTSG. t
. If cyclic idle loop cooling . Refer to analysis of T80 III.G !
is performed, maintain a small 2.6.1/3.6 Dif ference #1 AFW feed rate to avoid thermally shocking AFW nozzles. { 1
. If natural circulation is . Refer to analysis of TBD III.G not obtained in idle loop, 2.6.1/3.6 Dif f erence #1 check for voids in loop. .
. If voids are present in idle . Refer to analysis of TBD III.G '
loop, eliminate voids before 2.6.1/3.6 Difference #1 l trying to induce natural l l circulation in idle loop. l i
. Monitor RCS response to . Refer to analysis of TBD III.G l determine if idle loop voids 2.6.1/3.6 Dif ference #1 l exist (opposite trending of (
prz level / press, riif ficulty l 1 in reducing RC press, hot ; leg Thot = RC Tsat, unexpected increase in prz level, trend l of loop level instruments. l t I i
' III.G-29
. ,_ w
~~
E0P STEPS TBD ACTIONS'
![ ~
Plant conditions prior to .' Refer _to analysis of TBD III.G void recognition indicate 2.6.1/3.6 Dif f erence #1 which means'to use for elimination of void.
. Refer to analysis of TBD III.G
. If no releases have occurred 2.6.1/3.6 Dif ference #1 in containment, consider using .
RCP bump instead of HPV to eliminate void in idle loop. Refer to analysis of TBD III.G l
. If a SBLOCA has occurred, .
HPVs or.RCP bumps can be used . 2.6.1/3.6 Dif f erence #+1 - to eliminate voids in idle loop. .
'If ICC has occurred, more . Refer to analysis of TBD III.G preferable to use HPVs . 2.6.1/3.6 Difference #1
( instead of RCP. bumps to ( eliminate voids in idle loop. When HPVs are opened to vent . Refer to analysis of T80 III.G (s voids, increase MU/HPI to . 2.6.1/3.6 Dif f erence #1 maintain pressurizer level.
. Do not use hot let temp . Refer to analysis of TBD III.G indications to confirm void . 2.6.1/3.6 Difference #1 elimination.
Use loop level indications . Refer to: analysis of TBD III.G to determine if the void is . 2.6.1/3.6 Difference #1' becoming smaller.
. Before bumping an RCP, restore- . Refer to analysis of TBD III.G RCS press and prz level to . 2.6.1/3.6 Dif ference #1 values indicated immediately following void formation if prz level control was in auto.
III.G-30
. I EOP STEPS -- {
-TBD' ACTIONS
( Refer to analysis of TBD III.G j j Condense idle loop void.over - a long period of time via . 2.6.1/3.6 Dif f erence #1-ambient heat losses. ,, q Monitor. compressive tube-to- . Refer to analysis of TBD III.G l i shell AT if using the - 2.6.1/3.6 Dif f erence #1 j ambient heat loss method for .j eliminating idle loop voids. A 5 DIFFERENCES: None .. s 1
-i i
1 1 f q 1 J
-i
.I 1
-i i
l l gn III.G-31
TBD ChaDter: III.G ]
.L l TBD Section(s) 2.7.1/3.10: ESTABLISH PLANT CONDITIONS' /"'d' * FOR'DHS OPERATION This section establishes conditicns for utilizing the DHS. 1 l
l TBD ACTIONS E0P STEPS-
.. Continue plant cooldown with . CP.102; Step 2.0, 3.0-either OTSGs'or HPI cooling .. B.4,.Section 6' until conditions allow use .
lB'.4, Section 5' of DHRS. CP.103, Step ' 4.0-
< .CP.104,- Step 16.0L ,
. CP.105,' Step' 4.0, - 7.0
- _ CP.105, Step 8.0 - 3
. If..DHS operating temp and . . CP.104' Step 15.0 pressure not yet achieved, .,.
then cycle back to SCM status evaluation and begin review: of key-plant condition. l l > \ , l i i
- III.G-32 ;
.-_____________A
a
]
1 i TBD ChaDter: IV.A J __ l REACTOR C00LA1T PUMPS ] This chapter provides guidance on when to' trip, restarter bump RCP5s TBD TBD ACTION E0P STEPS SECTION Loss of SCM, all RCP's must . Refer to analysis of TBD Sec' tion 2.1 . V.C be tripped immediately
. If RCP's are not tripped . Refer to analysis of.TBD Section immediately, reduce the V.C number to one/ loop Exceptions to RCP trip . Refer to analysis of TBD Section . 2.2 .
V.C criteria.
- 1. If not tripped immediately upon loss of SCM
- 2. Severe ICC conditions . E.07 Step 7.0 and Step 14.0
- 3. If running RCPS are lost . E.03 Step 1.1 (Information) during loss of SCM, start idle RCPS 2.3 - During HPI cooling the number . E.04 Step 5.2.5 of operations RCP's should be . E.05 Step 22.1.5 ,
reduced to one . E.06 Step 17.2.5 ! i 3.0 Introductory material, no actions are specified 3.1 . SCM with natural circulation . CP102 Step 1.2 f RCP's may be started and run . CP103 Step 6.0, 7.0
- CP105 Step 2.0
. B.4 Step 6.1.6.2 1
I 3.2 . SCM with no natural . E.04 Step 12.2 and 14.0 ! circulation, if OTSG(s) . E.03 Step 16.0* l available as a heat sink . E.05 Step 10.0, 24.0, 36.0* i then start on RCP . E.06 Step 20.0 !
. CP.103 Step 4.4 l
- CP.104 Step 12.0
'
- Natural circulation may or may _not exist when these steps are reached J
IV.A-1
I TBD Chapter: IV.A 'i
]
h REACTOR COOLANT PUMPS _ l TBD j T80 ACTION E0P STEPS - SECTION 3.2 . If PTS limits permit, prior . Refer to T80 III.C 2.7/3.5 to RCP restart, RCS pressure Difference #1 (can't) and temperature should be ~ established such that there l is a 600 psig difference ' between the existing pressure I and the saturation pressure ; for the existing temperature
. E.03 Step 16 ,
- Should increase SCM & I Pressurizer level prior to . E.04 Step 12 starting an RCP with the RCS Difference #1 subcooled with no natural circulation and the OTSG(s) ;
(vailable as a heat sink I
. Start A RCP and leave . CP.103 Step 6 -
running if SCM is not lost.
. During HPI cooling, one RCP . Refer to analysis of TBD Section should be started III.C2.3/3.3 I
. As soon as a RCP bump . CP.103 Step 6 restarts natural circulation RCP should be operated provided adequate NPSH is available and RCS SCM remains.
CP.104 f rom E.03 Step 10 3.3 .If RCS is saturated with . desired cooldown rate, the RCP's should not be restarted If the RCS is saturated . E.04 Step 12.3 (No heat transfer 3.4 . exists thus desired cooldown without desired cooldown rate then RCP's may be rate does not exist) bumped to restart natural . CP 104 Step 7.1,12.3 circulation . CP.103 Step 4.4 IV.A-2
t
])
1,
. . . j I
TBD Chanter: IV.A. .) REACTOR COOLANT PUMPS 1 1 g TBD . . TBD ACTION E0P STEPS SECTION Bumping an RCP means to start . .E.04 Step.12.3 information- c 3i .
.CP.104 Step 12.3 Note (con't) the RCP, wait until the .
starting current drops off, . Difference #2. and then trip it. ,
)
] i
. If natural circulation is not . E.04 Step 14 l initiated after all pumps are . CP.104 Step 14 Differencc- #3 .!
bumped then lower SG pressure . Difference #3 . so that .100*F AT- between the * { i RCS and SG exists and continue to bump pumps in 15 minute intervals j
- When natural circulation - CP.103 Step 4.3 l l commences, control OTSG pressure-to control cooldown rate f
.= Immediately after each RCP
- Difference #4 bump, SG pressure should be lowered to maintain the
. primary to secondary Delta.T.
3.5 - RCS is superheated with - E.07 Step 7 i clad temperature >1400*F, .l start and run one RCP in .l each loop in an attempt to ! restore adequate core cooling. Do not override operating limits. l l 3.6 . RCS is superheated with clad . E.07 Step 14-temperature >1800*F: Bypass 1 RCP interlocks (except electrical trips)' and start all RCP's l IV.A-3
- - - _ _ _ _a
TBD Chapter: IV.A REACTOR COOLANT PUMPS TBD E09 STEPS , SECTION TBD ACTI_0N 3.7 - RCS is subcooled with - Difference #5 indications of a head void. 1 4 _m 3.8 RCS is water solid: Adjust . Difference #6 RCS pressure to avoid opening j the PZR relief valves, if RCS pressure increases, or to i avoid losing the SCM if the j RCS pressure decreases upon j start of a RCP l l DIFFERENCE (S) i This /
- 1. Refer to evaluation of TBD Section III.C 2.7/3.5 Difference #1. j also applies to the stebs listed in the previous item in this section I
(E.04 Step 12.2, E.03, Step 16.0, E.05, Steps 10,24,36, E.06 Step 20, CP.104 Step 12) . 7 l I
- 2. The TBD defines a RCP Bump as starting the pump and tripping it as soon as starting current drops off. The E0P's wait an additional 10 seconds af ter starting current drops off, to trip the pump. The reason for this is to ensure that about one loop transit time has passed prior to tripping the pump. This action ensures that voids in j the hot leg will be forced through the OTSG and thus enhance the j collapsing of voids. The intent of the TBD to collapse voidt, and j l
ensure heat transfer is met. l
- 3. Refer to analysis of TBD Section III.C.2.7/3.5 Difference #5.
- 4. E0P steps which bump RCP's do not explicitly require this action, however, they do establish the required AT prior to the pump bump and indicate to continue to bump pumps until heat transfer is restarted. Operators know that a primary to secondary delta T must be maintained if primary to secondary heat transfer is to be established, thus maintain the specified delta T. This need is also demonstrated during simulator scenarios. The E0P's are thus considered to be adequate. Adding this non-mandatory TBD information to pump bump steps would enhance the operators response.
IV.A-4'
i \ - I' ; DIFFERENCE (S) (Continued) Action- ! Revise RCP pump bump steps to include TBD guidance concerning { maintaining a primary to secondary delta T. Implementation: Post startup. Justification: This may be done post restart because as noted above it is a non-mandatory enhancement.and the procedures and training are f t
. adeauate as'is. 'l"
- 5. This TBD guidance for a head bubble removal with a subcooled RCS is an enhancement over ATOG which has not yet been incorporated into the E0P's. This is a non-mandatory guidance except;in E.06, SGTR.
Action: Upgrade E0Ps to include TBD Guidance for head bubble removal with the RCS subcooled. Implementation: Post startup. ( 1 Justification: This is an enhancement over ATOG to obtain improved plant control and is not required for core protection.
- 6. This TBD guidance for RCP start when RCS is water solid is an enhancement over ATOG which has not yet been incorporated into the E0P's. This is a non-mandatory guidance and the operators obtain experience starting RCP's when water solid RCS at the simulator, thus the E0P's are acceptable as is. a Action:
Include the TBD guidance for RCS water solid RCP start in CP.105. l Implementation: 1 Post startup Justification: This may be d'one post startup for the reasons noted above. t i' IV.A-5 I
2: , 7" ., , . .
; , c ' -) ,
' , y 4 ,
)
ys '
, Y-W TB0 Cnanter: IV.B HPI/LPI/0 HRS /CFT' '
.. ~~ !
;2.A.2 INITTATING HPI -
( ,.. ' 1
.780 i E0P STEPS - ..l SECTION' TBD ACTION , ....
'?
Difference #1~ HPI should be. manually' l] 2.A.2? .
. i started if automatic
' initiation has~not already E.02, Step'8 l
. occurred.
HPI.must be initiated . Rule .1: Step 1.1. ". 2.A.2.1 - E.03 Step 2 whenever a loss ofJadequate, . SCM occurs.
~
2.A.2.2- ".HPI flow should'be .
.- E.06 Step 4- -
1 established during reactor. ~ shutdown with;a SGTR if , l normal MU.cannot maintain: desired. pressurizer level.. 2.A.2.3 .- When SG heat transfer. is not . Rule:1 Step 1.2 l adequate and FW is not . LE.04 Step SL ] 1 k available to'either SG, then . E.05 Step 22-
- HPI must be initiated. If, .
E.06 Step 17 two HPI~ pump flow cannot be achieved, then the EMOV;
. must be opened to provide.
the maximum HPI1 cooling' possible. . Start HPI when or before Rule l' Step-l 2 .
- 1. 2.A.2.3 -
E.04: Step 5 from Step 2,4,9,11 the RCS pressure reaches . the EMOV open setpoint of- 15 ) E.05 Step 22L the first automatic EMOV lift.
.IV.B-1 k., 1 l
- -- _ _- . I
l4
- .j 1
TBD chanttI;_. IV.B HPI/LPI/DHRS/CFT _ _ (* .) 4' L TBD ! SECTION T80 ACTION E0P STEPS With one operating HPI pump
- E.04 Step'5 the EMOV may be opened so .- E.05 Step 22 that HPI flow-will match decay..
heat as soon as possible. l
- If the EMOV is not opened,
- E.04 Step 5.3 HPI flow must not be throttled until Incore T/C begins to cooldown and SCM exists 2.A.2.3.1
- If the RC pressure
- E.04 Step 5 from Steps.2 &'9 ~
to the P-T limit, the EM3V *E.06 Step 17 should be opened and HPI cooling started to limit the pressure increase. H
- HPI flow should be throttled . E.03 Step 14 as necessary to try and keep '* E.05 Step 8, 16 the RC pressure below the-
- E.07 Step 24, 25
( RV P-T limit-
- CP.105 Step 3.1
- Rule 2 Step.2.2 2.A.2.3.2
- The PTS limit must not be
- Rule 6 Step 3.5 violated while it is in- . E.04' Step 5 from Steps 2 & 9 i effect. If the PTS'11mit is
- E.06 Step 17 j or will be in effect due to 1 HPI initiation, then RC'
]
l pressure must be controlled ) l to prevent exceeding the pts i
' limit. Therefore, open the ;
EMOV prior to starting HPI , 2.A.2.3.3
- If a SGTR results in an
- E.06 Step.10.6 and 15.3 isolated solid SG, maintain
- E.06 Step 18 RCS pressure below MSSV
- E.06 Step 16.1'.2.1 setpoint. If the RCS is' subcooled then throttle HPI.
If the RCS is saturated, do not throttle HPI but provide additional relief paths (i.e: HPV's and letdown)
._. IV.5-2
-(;
IBO Chanter: IV.B HPI/LPI/DMRS/CFT ,, 2.A.3 MAXIMI 71NG HPI FLOW RATE
;(O TBD SECTION TBD ACTION EOP STEPS 2.A.3.1 + Nhenever the SCM is lost, . Rule 1 Stop 1 maximum HPI flow must be . E.03 Step 2.0 provided to the RCS. Maximum = AP.23.06 (Enclosure 8.3)
HPI is achieved by operating.. *. E.07 Step 1-two HPI pumps and balancing a' CP.104 Step.9.1'- the HPI flow i HPI flow should not exceed + Rule 2. Step 2.1 the maximum allowed pump ~
- CP.101 Step 2.2.2 flow rate
. When using Th Orte as an- . Difference #2 indication of loss of SCM, the corresponding loop must l
have loop flow. 1 s I i I
% )
IV.B-3 i s l
- ')
.TBD Chanter: IV.B HPI/LPI/DHRS/CFT ,_.
2.A.4 THROTTLING HPI FLOH. 9 1 l 1 TBD l SECTION TBD ACTION EOP STEPS 1 2.A.4
- HPI flow may be thrsttled
- Rule 2 Step 3 ;
anytime adequate Sch exists
- Rule 1 Step.l.1 l as indicated by inco,'e T/CS. 1 HPI flow must not be i i
throttled when the RC SCM is lost. ]
. 1 i
. The HPI pump flowrate should '. Rule 2 Step 5 .
not be throttled below the '. Cautions prior to minimum allowed pump flow
- E.05 Steps 8 16, 26, 38 rate.
1
)
- When throttling HPI flow to e CP.105 Step 3.1- 'd control RC pressure, care
- Difference #3 should be teken not to allow 4 the RC pressure to drop below: !
' 1) the SCM limit 2) the RCP i
( NPSH requirement and, 3) Fuel pin in compression limit if in effect. 2.4.A.1
- HPI flow should be throttled
- E.05 Step 8, 16, 26, and 38 {
to keep the pressurizer level j near the normal operating i i level setpoint when SCM ( ! exists. i 2.4.A.2
- HPI flow must be throttled to
- E.03 Step 14 i prevent overpressurizing the
- E.05 Step 8, 16 '
! RCS when SCM exists by
- E.07 Step 24 and 25 ,
keeping the RC pressure
- CP.105 Step 3.1 I below the NDT or PTS limit
- Rule 2 Step 2.2 as applicable 9
-IV.B-4
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- b ' . 2 TBD Chanter: IV.B HPI/LPI/DHRS/CFT: ,,
;,pu , p. 2.A.5 STOPPING HPI FLOH-TBD . .
i
=SECTION TBD ACTION 'EOP STEPS ]
- . Rule 1 Step l'2 2.A.5.1 * 'HPI flow should be stopped- .
E.05 Step 8.- 16,: 26, and 138 ' and normal' MM: flow control . 1, started if the RC leak rate or contraction.' rate is.within the normal makeup flow capacity and'an adequate SCM exists. j
;I 2.A.5.2.* HPI should be stopped if LPI
- Rule 2 Step 1.1 hastbeen flowing in each line
- CP.101' Step 6
.for 20 minutes'at a rate in * .'CP.103' Step 13 excess of 1000 gpa
- E.07 Step 19: q
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I 8 Q IV.B ,
1RM) Chanter: IV.B HPI/LPI/DHRS/CFT ,, LPI AND DHRS OPERATION TBD SECTION TBD ACTION EOP STEPS 3.1 . LPI must be initiated whenever . Reference TBD V.A 2.1
. any of the LPI initiation' Difference #1' setpoints are reached 3.2 . The LPI suction must be changed ' . E.07 Step 19,20.23 (status) from the BHST to the RB Emergency _. CP.101 Step 8 Sump when switchover conditions
- CP.103 Step 14 and'16 are met.
3.3
- Hot leg level measurements should .- Difference #4 be used as an aid to indicate if an adequate water level exists above the DHRS suction nozzle.
4.1 . ' When the RC is saturated, the- . E.07 Caution prior to Step DHRS should not be placed into 26 ( operation without careful monitoring of DHRS pump cavitation 4.2.1 . If the RCS is subcooled, and a . 'CP.103 Step 18.5 LOCA exists, one LPI pump must . E.07 Step 26 be kept in the LPI mode; the . Difference #5 other LPI pump should be put in the DHRS mode of operation
. If the RCS is subcooled and a . CP.103 Step 18.2 LOCA exists, if only one LPI . E.07 Step 26 information pump is operational, it should be left in the LPI mode and not in the DHRS mode ;
IV.B-6 l
1
.TBD Chanter: IV.B HPI/LPI/DHRS/CEI- _ .W s ;
1- CORE FLOOD TANKS. BORON PRECIPITATION AND PIGGYBACK __ MODE OPERATION
~
i TBD {' SECTION TBD ACTION EOP STEPS 5.1
- The core flood tank isolation
- CP.101 Step 3 :
valves should be closed . CP.103 Step 10 , during cooldown with a loss
- E.07 Step 19 ,
of SCM when the LPI is flowing in each LPI line ' ; at a rate in excess of 1000 gpa . 5.2
- The core flood tank isolation
- CP.104 Step 6' -
valves should be closed . B.4 during subcooled cooldown s ! before the RC pressure decreases to the Core Flood Tank pressure 6.0
- Hithin twenty four hours - CP.101 Step 13
( after a Loca, actions should . Difference #6 be taken to preclude the-possibility of boron precipitation 7.1
- HPI and LPI must be operated *- E.07 Step 23-J in piggyback mode if LPI flow
- CP.101 Step 7 and 8' 1 i for at least 20 minutes is
- CP.103 Step 16 {
l less than.1000 gpm when the l BHST lo-lo alarm comes in. \ l 7.2
- When in HPI/LPI piggyback
- Difference #7 ;
mode, one HPI pump may be , secured provided both LPI ! i pumps are supplying suction I water for the running HPI . pump and HPI injection is to i all four nozzles. The second ! HPI pump can be stopped even , if SCM does not exist. J l
.s, IV.B-7
-- m 1 1
Differences: ..'!
- 1. Operator training includes. performing manual initiation of 'al'1 1 automatic equipment at'its.setpoint if it fails to-do so. j automatica1ly; therefore, a specific direction to manually initiate i automatic equipment is not included in.the E0P's..- l 2.- .This: item is of concern under natura1Leirculation' conditions with one loop; The operators are trained to.use.incore T/C's-for determining
.subcooled conditions'within the core.when RCP's are off. The action-statements within the TBD are, therefore., not' applicable..
- 3. Refer to .TBD .III.C Flowchart Comparison Difference #5.
l
- 4. Hot leg level indication was:recently installed and'made'available on -
.j SPDS. The indication. is inaccurate under forced flow conditions or:
when flow is through the decay heat drop lline. The indication will be useful'in a situation just prior to initiating drop line flow.1 - L
, i Action:
The action statement of the TBD associated with this item will be ! added to the applicable portions of the E0P's.. Implementation: Post Startup i 4 Justification:, q Operators are trained:to use all.available indication thus , implementation is not imperative prior to startup. !
- 5. CP.103 places both LPI trains in the DHR mode, once LPI flow has been.
greater than 1000 gpm in each line for.20 minutes. There is no-discussion within the.TBD regarding the placement:of both DHR trains in the DHR mode. Since one train'of DHR is sufficient to remove decay heat, there is no need to place both in the DHR mode. If there is'a hole in the'RCS, then one' train of LPI will be needed.to replace the inventory lost out the break. In this scenario it is undesirable-for both trains of LPI to be in the DHR mode. Action:' Step 18.7.2 of CP.103, which places both LPI trains'in the DHR . mode, will be removed. CP.103 will ther, agree with the TBD which' ! states that only one train of LPI will be placed in the DHR. mode. j Implementation: Pre Startup
'l l
IV.B-8' j l l
. _ . . _ _ ____._____.._.a
a j i
- 6. The TBD requires'the operators.to take actions within twenty-four ~
hours after a LOCA to preclude the possibility of boron 1 precipitation; CP.101 allows up to seven days-to' establish dilution- J flow. In order,to comply _with the'TBD, CP.101 will be revised to i incorporate the twenty-four hour. time requirements. . Action: 1 Revise CP.101 Step 13.1 to read: As soon as practicable within twenty-four (24) hours, establish' dilution flow....." 1 Implementation: Pre-startup
- 7. The TBD presents the option of securing one HPI pump and running the other HPI pump when in the piggyback mode of operation. The second pump can be stopped even if SCM does not exist. This action is contrary to the SCM rule and operator training. Hence, to limit operator confusion, this action will not be incorporated in the E0P's. IF SCM exists and adequate core cooling can be provided by-one HPI pump, the operators have the option of reducing flow by closing injection nozzles or by. stopping one HPI pump. Since the-operators are trained in'the classroom and on the simulator to take these actions no additional guidance is necessary in the E0P.
l l 1 Lk l l l I i l
- s. IV.B-9 !
L
.)
- j TBD thater: -IV.C FMW/AFW SY' STEM OPERATION _,,
i -TBD Section(s)
1.0 INTRODUCTION
2.0 DEFINITION , . .. , 3.0 STEAM GENERATOR WATER LEVEL
.u .;
TBD SECTION: EOP STEPS i TBD ACTIONS.
- These'.three sections are introductory to Sections 4 and 5 whi:h' provide the detailed system operation guidance. Section.3.0 q discusses reasons for.sitpoints;.-these setpoints are determined by engineering. analysis and incorporating into-the E0P's is specified in other TBD sections. The definitions'are obvious and the terms are used in the E0P's as defined in the TBD.
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E i i k- IV . C-1.. ' ; 1 i 3
TBD Chanter: IV.C ,, TBD Section(s) 4.0 FEEDWATER CONTROL TO STEAM GENERATOR THAT CAN HOLD PRESSURE This section provides general guidance for FH control and feeding dry OTSG's or OTSG's with no primary side flow, i TBD SECTION: TBD ACTIONS E0P STEPS
. The FW flow rate snould be . No specific E0P steps direct controlled to increase or this action because it is such decrease the SG 1evel to an obvious generic action as to obtain the required setpoint net require steps. Simulator training stres,ses frequent checking of automatic level controls to assure proper control.
- Feeding a dry OTSG:
- Refer to analysis of TBD III C.
. AFH should be used rather 2.5/3.4. The referenced E0P than MFH steps utilize AFH before MFH.
- RCP should be on . Difference #1
( DIFFERENCES:
- 1. Unlike the TBD, the E0Ps do not specifically address feeding a dry OTSG. However, whenever feed is being established to restore heat transfer, which would be the case with a dry OTSG, AFH is always used if available as per normal operating procedure A.6 Section 7.4 (Revision 26), Other sources (MFW, etc.) are used only if AFH is not available. Per'the TBD, analysis would be required before startup, but the E0Ps appropriately use MFH if needed to mitigate the accident as permitted by the TBD.
RCP operation when feeding a dry OTSG is not explicitly stated in the E0P's, although direction is normally given to start and maintain an RCP if SCM is available. Thus RCPs will most likely be running if possible when a dry OTSG is fed. Again, if a dry OTSG is fed without RCS flow an analysis will be required per the TBD. The TBD does not prohibit feeding a dry OTSG without forced flow. ( -~ IV.C-2 ; i
n
, ., -l a
1
-- . ,i Action: .,_
1 Include explicit guidance concerning feeding a dry OTSG inthe 3
- E0P's (consider Rule 3) as a post startup charge.
Implementation: ,,
~
Post Startup.. Justification: Post-startup.is appropriate for the reasons noted above~.
)
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TBD Chanter: IV.C TBD Section(s) 4.1 EXCESSIVE FH'
-4.1.1 EXCESSIVE MFH 4.1.2 EXCESSIVE AFH ,
4.1 is introductory to 4.1.1 and 4.1.2,.thus are not included below-TBD SECTION: TBD ACTIONS EOP STEPS 4.1.1.1 When the reactor is shutdown, *. Refer to the' analysis of TBD: the MFH flow must be controlled -Section V.B.3 to prevent the.SG 1evel from exceeding the shutdown _S-G overfill setpoint. -
. .0TSGs should not b'e-steamed . Difference #1-once they have overfilled
- Take actions quickly to
- Refer to the analysis of TBD terminate excessive MFH Section .III.D. ~2.4, III D. 2.5-starting by closing valves !
c- and progressing to pump trip as high levels are approached
. Whenever FN is stopped to . Difference #2' both SGs FN flow should !
I be restarted before both SGs are dry ;
.i 1
4.1.2.1
- When the' reactor is shutdown,
- Refer to the analysis of TBD !
the AFH flow must be stopped Section V.B.4 ) to the overfilling OTSG before ; SG 1evel reaches the shutdown- ,l SG overfill setpoint j 1
- If AFH valve operation is
- Difference #3 !
unsuccessful stopping flow,
- Refer to analysis of TBD !
trip the pumps and batch feed Section V.B.4 regarding valve the SG's og starting and operation and pump trip i stopping AFH pump as needed ; i' k IV. C-3
' DIFFERENCES:
- 1. E0P's do not provide guidance not to steam an OTSG once it has been ~
overfilled. Because this is desirable but not mandatory per TBD, this differer.:e is acceptable. Operator training, including i simulator scenarios, stress not feeding an overfilled OTSG. Action: . Include E0P guidance that a once overfilled OTSG should not be- ; steamed. l 1 Implementation: Post startup Justification: Post restart is acceptable for the reasons noted above
- 2. E0P's restore feedwater (restore' heat transfer) as soon as' practical by appropriate branching following the TBD Part III " Diagnosis and-Mitigation" guidelines but do not include the. specific desirable TBD guidance to do so before drying out the OTSGs. The primary concern is to control heat transfer rapidly which'is a main thrust of.the E0Ps.
The desirable action of not drying out.0TSG's is included in training, particularly simulator scenarios. The E0P's and training thus are acceptable with this difference. Action: \ Include E0P guidance to attempt to restore FH to OTSG's (as I applicable to the plant conditions) before dry out. Justification: Post restart is acceptable for the reason noted above.
- 3. E0P's do not include the TBD desirable guidance to batch feed the OTSG's with AFH pump starts if valve failures prevent AFH control.
The AFH system now includes two parallel paths of Class 1 control and , isolation valves in each flowpath to each of the OTSGs. All valves i can be remotely controlled from the control room. The probability I for batch feed is very small.. One of the redundant AFH pumps is driven by an electric motor and the other is driven by either a steam turbine supplied by main steam or an electric motor (dual driven). The motors have starting limitations that would prohibit their cycling for batch feeding. Only two starts in five hours or three starts in 24 hours are permitted per motor. Numerous batch feedings per hour would be required to remove heat while avoiding an overcooling transient. The steam driven turbine inlet valve'could be cycled from the control room but the valve stroking time is intentionally slow to prevent an overspeed trip. This would result in ragged control of feed flow and possible overcooling and overheating transients. Because of this and because this is a desirable but not mandatory TBD action in the E0Ps are acceptable as is. IV.C-4 I
q
= - - - - -
.' c .
TBD Chantarh IV.C
, . .)
TBD Section(s) 4.2' INITIATING AFW {m This section provides no actions in addition >to-those specified in j
-TBD V.B. Refer to.the analysis of the indicated TBD sections."
TBD SECTION: o 1 TBD' ACTIONS EOP STEPS
]- ,
. 4.2.1 1 *- Refer to analysis'of.TBD Section.
V.B.5'- 4.2.2 -
*- Refer to analysis.of-TBD Section. .
V.B.6- ,
;. )
- 4.2.3
- Refer to analysis of'TBD Section.y.f
.V.B.7' DIFFERENCES:
None: (" l l l-
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' fV.C-5 -O I
l TBD Chanter: IV.C- .__ , TBD Section(s) 4.3 MAXIMIZE AFH s l TBD SECTION: TBD ACTIONS EOP STEPS i I 4.3.1 Whenever there is udequate
- Rule 3 Steps 2,3,5, Difference j
#1 1 primary to secondary heat transfer. AFH flow rate should be maximized without causing the SG pressure to go more than 100 psi below the SG pressure control setting, until the. required >
SG 1evel.setpoint is reached or .i adequate primary to secondary 1 heat transfer is established DIFFERENCES:
- 1. E0P's implement the TBD guidance to limit the AFH fill rate to limit OTSG pressure drop but do not explicitly require maximizing AFH flow rate to achieve this OTSG depressurization. EFIC has an OTSG level increase ramp which is a function of OTSG pressure, decreasing as- l OTSG pressure decreases. -This ramp rate has shown to be effective on !
plants with EFIC and as modeled on the simulator. It-is preferable to use AFH automatic controls rather than operator manual control.s. thus the non-mandatory TBD guidance to maximize flow is omitted. The i E0P's are acceptable as is for the reasons noted. l i IV.C-6
-- . ll l
TBD Chanter: IV.C . , ,, ! TBD Section(s) 4.4 THROTTLING AFH TBD SECTION: TBD ACTIONS EOP STEPS ; 4.4.1 ~If AFW flow shwld be added, . Refer to the analysis of TBD it should be controlled so V.B.8 ' that a continuous AFH flow is provided and the SG.-level , never decreases with an overall l progression toward the required l setpoint. 1
. Except when minimum AFW flow . Rule 3 Steps 3,4,5 is required (TBD IV.C.4.4.3) i SG 1evel can'be held constant i as long as the AFH flow is 1 removing adequate heat.
. Holding level constant would j be desirable during an overcooling j i
l 4.4.2 The AFW flow rate should be . Refer to analysis of TBD J i throtticd to prevent the SG IV.C.4.3 pressure from dropping more than 100 psi below the desired SG pressure control setting.
- Do not go below the required AFN finw rate per IV.C.4.4.3 (150 gpm) q
_. l l 4.4.3 Whtrever adequate SCM is lost . Refer to analysis of TBD V.B.9 and incore T/C's are not decreasing, AFW must be controlled to provide at least the minimum flow rate listed ~ l to each SG until the loss of SCM i setpoint is reached: Rancho Seco: 150 gpm l l DIFFERENCES: None l IV.C-7
i
... .d TBD Chantar ' IV.C _ ,;
f? TBD'Section(s)- 5.0 INVENTORY CONTROL OF S/G THAT CANNOT HOLD PRESSURE .
.5.1 REQUIRED FW FLOW RATES'TO SGCS) WHEN NEITHER CAN HOLD PRESSURE- . , ,
Section 5.0_is introductory and contains'no_ actions not evaluated
- in-later sections. The evaluation below starts:with Section 5.1 TBD SECTION:
TBD ACTIONS- EOP STEPS
- 1. ' Attempt trickle feed both S/G'
. Supply AFH to both S/G at-E.05 Steps 5.0, 25.0
~
. limited rate. *
'. Automatic FH probably need.
- E.05 Step 25.2,:25.3, and to be bypassed information 25.0:(bypass auto-
' function is implied)
- 1 RCP/ loop should be
- E.05 Step.24.0 operating ' q
.f~ m
- Continue to isolate leak-
- E.05 Step 4.0, training, AP23.06 Enclosure 8.3
. Discussion'#1
- 2. Trickle feeding or.e S/G
+ If one leak is inside R.B. .
then that S/G thould have all~ FN stopped e' E.05 Steps 23.0, 34.0,.37.0
.1
- Isolation of I SG.may be . Difference #1 ,
desirable'for repairs or . E.05 Procedure ! if heat removal cannot be - L. E.04 Procedure controlled with 2 SG's H
-i
*- If 1 SG is isolated, allow . E.05 Steps 6.0, 14.0 1 it to boil dry while' maintaining heat transfer: ] -
on the other SG km IV.C-8 ' '" '; i l
]
.c.
TBD SECTION: _
- EOP STEPS TBD ACTIONS
. Continue trying to stop . E.05. Step 4.0 J the leak on at least 1 SG * -Training .
. AP.27.06 Enclosure 8.3
. Discussion #1 ]
l
. If a' forced cooldown . E.06 Step 11.4 situation exists (such as- . E.06 Appendix A.(See also E.06 i
SGTR) the other;SG may need Step 16.1) to be fed for tube.to shell t delta T or RC loop flow if 0 1 RCP's are stopped
- 3. 'Do not feed either S/G
. If both SG's.have significant . E.05 logic results in-isolating, l both SG's and going to CP.104 . leaks in the RB, it may be desirable to initiate HPI and HPI cooling cooling and allow both SG's. . E.05 Steps 5.0, 23.0, 34.0 35.0, to boil dry Status before Step 35
- CP.104 DISCUSSIONS:
- 1. Continuing efforts to isolate the leak is ~ an automatic operator action which does not require specific mention in the' EOP's. The cited E0P steps isolate all' major branch lines, only'sceam trap lines are not listed. AP23.06 Enclosure 8.3, Use of E0P's, Section 4.1 ;
directs the operation to take action to control the plant at any time, without being restricted to waiting for an E0P step to direct-the action to be taken. Simulator training includes steam leaks and encourages operators to examine all possible leak sources ] i f i IV.C-9 . l 1 i l
DIFFERENCES: __
- l. E0P's do not explicitly include the options to isolate one SG for .
maintenance activities or if trickle feed is not controllable on both S/G's. Maintenance options are not included in E0P's because this is a management decision not related to gaining pignt control in emergencies. If trickle feeding both SG's does not. produce-controllable heat removal, excessive heat transfer will result:and the operator will cycle back to the start of. E.05.EOP will result in isolation of the overcooling.SG. The E0P's thus implement the intent of this TBD action and are acceptable as: written. Action: Revise E.05 after steps which trickle feed both SG's-(Step 25.0)
'to isolate one SG if controlled heat removal is not obtained.
Implementation: Post startup Justification: This is an enhancement to reduce branching and for the reasons noted above, this change may be made after startup. s 1 l IV.C-10 i
TBD Chanter: IV.C _ TBD Section(s) 5.2: FEEDING A DRY SG HHEN THE OTHER SG l CAN HOLD PRESSURE ( A single SG with an unisolable steam leak may need to be fed. These circumstances are discussed in this section.
)
TBD SECTION TBD ACTIONS EOP STEPS
. Normally only the good SG is .. E.05 Steps 3.0, 6.0,'14.0~
fed, the other is allowed to - boil dry
. l
. Natural Circulation Cooldown . E.06 Appendix'A Steps 'I and 2 )
. CP.102. Step 3.0
- E.06 Step 22.0-
. Refer to analysis of TBD Section -
III.B.2'.8/3.5, Difference #3 l ;
. Excessive SG tube to shell . CP.102 Step 3.0 (limits cooldown Delta T rate in Step 3.2)
- Flow should be added at the- j cooldown rate adjusted j
. ICC Heat Removal- . Difference #1 Should consider t.dding FW l to depressurized SG for additional heat removal IV.C-11 :
1 DIFFERENCES: l
..j
(~ 1. ICC with a SG with an unisolable steam leak.(depressurized SG) is not' I yet incorporated in the'EOP's. Because the TBD action is desirable, not mandatory, the E0P's are acceptable as written. Action: Consider Revising E.07 to feed a depressurized OTSG. Implementation: Post Startup Justification: Post rest, art is' acceptable for the reasons noted above. I
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j l l IV.C-12 l i l _ =---- - - _ = - - _ _ _ _ - - - - - - _ . _ :)
.; i
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.TBD rh nter: IV.D-INCORE-THERM 0 COUPLES. _
fe ' TBD SECTION TBD ACTIONS EOP' STEPS. 2.1.1 * .As soon as SCM is lost,:an: *~ E.07 Step,,5.0 2.1.2 average of incore T/Cs .* Difference #1- .
-should be used for ' *- '.SPDS Averages 5-T/Cs determining the reactor'
- AP.23.06 Enclosure'8.3: Step'5.5<
core outlet temperature.
-Refer to' analysis of TBD. -'
2.2
- Anytime there is,no natural-
- circulation 'or - forced : IV. G. - 4 circulation in the RCS, .
the'incore:T/Cs should be-
' compared to the. PTS. limit. .j
. 2.3 e. The hot. leg RTD indication * .E.03 Step 18.0 Information.
should be'within.10*F of-
- E.04. Step l13.0'Information.
the incore T/C reading when :* :E.05 Step 10.0, 25.0, subcooled natural circulation 37.0 Information is occurring,
- When the RCS is saturated.
- Difference #1 incore T/Cs should be used d,
to confirm natural circulation. DIFFERENCES: .j
- 1. There are three times in the-EOPs which state to; specifically use. incore o T/Cs. They are (1)~ Guideline 1 with.no RCPs running and'SPDS is.not' available; (2) E.07, steps to evaluate-ICC; and (3) Rule 3; Step 5 ,
regarding minimum AFW flow when SCM is lost. The operators are trained at tha simulator to use Incore T/Cs-to determine core conditions any time SCM is lost or'RCPs are off.. Since the operators are trained in this manner, no change to the E0Ps is needed at this time. To-complement training, a procedure enhancement could include information on the information page regarding the use of. Incore T/Cs over..RTD TH - l Actions: ] Revise E0Ps to include-TBD Section IV.D 2.2.1 guidance for use.of-incore T/C. Implementation: q Post Startup i Justification:
~
Procedures and training are adequate as is. This is an enhancement ; so the procedures complement the training.
, J IV.D-1
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TBD Chanter: IV.E HIGH POINT VENTS' _ TBD SECTION TBD ACTIONS- EOP STEPS 2.1 As soon as the clad reaches
- E.07 Step"9, 16 a temperature of greater than 1400*F, all HPVs should be open.
2.2 Reclosina HPVs uoon return
- E.07-Step.16 (Information), 19 from ICC
- CP.103 Step 12 from E.07 Step 13
- If adequate.SCM is regained,
- CP.104 Step 1 2 from E.07 all HPVs may be reclosed. Step 12
- CP.105 Step 3.5 from.CP.104 Step 17.or CP.103 Step 9
- If natural circulation is
- CP.104 Step 11.5-(This step is-lost at a later time, it. reached from CP.103 Step 5.
may be necessary to reopen E.078 branches to CP.103 if the HPVs to remove any OTSGs are removing heat in Step noncondensible gases left 12.) in the system.
- It is allowable to close
- E.07 Step 16Information,19727
( , the HPVs once the decay
- CP.103 Step 12 from E.07 Step 13 heat removal system is
- CP.104 Step'1.2 operating with RC pressure
- CP.101 Step 12.0
< 140 psig.
2.3 A. Control of RCS Pressure
.prz HPV should be used
- E.06 Step 14.2.3 I for cor, trolling RCS
- Rule 6 Step 2.1.1 )
pressure in situations
- Difference #2 where normal or auxiliary prz spray is inadequate.
HPV capacity is lower than EHOV. i
\ IV.E-1 !
t i w--.._____.____ _._
w c.. TBD r%mnter* IV.E HIGH-POINT VENT (Continued) ,, 7"x E.05' Step.12, 20 "27, 42' It is possible to'open' . 4 all HPVs in an attempt
- E.03 Step 14 ,
.to reduce RCS pressureE -+ ' Rule-6 Step 2.1.1.
when-the' PTS limit is in . .- Difference'#1 danger of being exceeded: ' during HPI. cooling. .
- During HPI cooling with a =- E.06. Step 19.0.
solid SG which-has a tu.be-
- Difference #3 .
rupture in~it, open the-HPVs.
~ B; Refill of a'Voidad ' Hot Lea
. HPVs could be used to
- E.06 Step'22 restore natural. .. E.05-Step 11.2. .
circulation provided the;
- Refer to analysis of.TBD core has been restored to Section III.C.2.7/3.5.
l a'subcooled condition... However, RCP bumps will remove the steam voids-faster by sweeping them into the subcooled liquid where they collapse. C. Provide for~RV Head Cooling Durina Natural Circulation
. The RV head vend may be .
- Not applicable. . Rancho Seco opened to provide some has'no reactor vessel head vent.
RV head cooling or to-relieve steam if necessary. l IV.E-2 ,
)
1
~ .
DIFFERENCES: __ ; [ 'l. Any time PTS is in danger of being exceeded or is exceeded, Rule 6 and. PTS direction within the procedures have the operator depressurize.the RCS via the pressurizer spray, pressurizer vents or EMOV. That HPVs are not specifically called out.to be used to avoid PTS,because the relief a capacity is very small compared to the other options used in the E0P3. . J The HPVs would not relieve pressure quick enough to avoid PTS.during. , j most overcooling scenarios. Use of the HPVs for pressure' control is non ; mandatory and therefore, is not included for the reasons noted above. l J
- 2. Section IV.E.2.3A implies the pressurizer .HPV should be used instead of j the EMOV as long as adequate pressure control can be maintained. The l pressurizer HPV is so small that it would not provide adequate. pressure {
control in emergencies requiring pressure control such as HPI cooling.
. SGTR or natural circulation, overcooling avoidance of PTS, etc.; thus the EOPs generally specify use of the EMOV before the HPVs. ,
- 3. The EOPs do not require the OTSG with the tube leak to be solid prior to opening the HPVs because: . (1) it is difficult to determine when the OTSG is solid;- 2) early action to limit RCS pressure will limit OTSG overfill, thus reducing the chance of a solid water OTSG condition. .l 1
I l { l-' i 1 1
)
l , l l l l i
. 1 i
IV.E-3 h
TBD Chanter: IV.F. CONTAINMENT SYSTEMS ,, 4 TBD ACTIONS ~ E0P STEPS 2.0 1) RB isolation control involves reducing and controlling leakage through RB penetration . and actions may include:
- a. Verifying RB .- - E.02 Step 8 penetrations .
automatically isolate. 1
- b. Selectively isolating
- Recover RCP seal return and unisolating E.02 Step 8.0 penetrations as needed.- E.03 Step 2.0:
Isolate RB penetrations (secondary side) CP.101 Step 10.0
- c. Operating equipment
- Difference #1 in a secondary containment or auxiliary l
building to' monitor and control leakage from the RB.
- 2) Specific parameters can be monitored that may indicate the need for full or partial RB isolation including:
- a. High RB radiation.
- Difference #2
- b. High RB temperature.
- Difference #3
- c. High RB pressure. . [.02 Step 8.0
- d. Low RCS Pressure.
- E.02 Step 8.0 IV.F-1 gb t
t a
L < I [ -TBD Chanter: 'IV.F CONTAINMENT SYSTEMS (Continued)' TBD ACTIONS EOP STEPS
- 3) The decision to open valves . Cautions.are provided'before^
should be accompanied by a the following steps:. ~: judgement of possible E.07 Steps.20 and.23-consequences. CP.101 Step.12.7' CP.103 Step 11.0 l i 1 3.1 1) Energy,being released to l the RB may be reduced by:
- a. Maintaining coreLcooling... Difference 4
.b. Limit FW added to an.
- E.05 Step:14 '
OTSG that.has.a break' '* E.05 Step 37 . inside;the RB.. *- E.06 Appendix A Step.2.0 .
'c. Increase heat removal *!,. Difference #5 by the LPI-Coolers.
- d. Increase heat removal
- Difference #6 by the OTSGs.
. . l
- e. . Isolate any break in. - E.03 Step'6 l the RCS if possible.
- 2) If high temperature:is *- E.05 Step.17, 23 .33- ]
reached, the RB coolers
- CP.101 Step 12.6 -
should be startea.
- 3) If RB coolers fail to keep a- E.02 Step 9 i the R8 pressure below e Difference #7_ i limits, backup cooling j with RB spray may be used.
3.2 1) Hydrogen concentration I should be controlled.to l either prevent or limit , 1 burning to prevent possible equipment damage as follows: j l
- a. Mixing the RB atmosphere.:* CP.101 Step 11.0 j
- b. Reduction of hydrogen . CP.101 Step 12.10.
by recombiner orl purge. .
- Difference #8 ;
i IV.F-2 f
p , j ,
.c
.:- .qd
~TED chanter: IV.F CONTAINMENT SYSTEMS '(Continued) ._
- 7. y.,
l
}
,)
'TBD ACTIONS: EOP STEPS
-i 3.3' Actions should be taken to' . Refer to a'nalysis TBD.IV.B.6., ,
prevent boron. precipitation. t
]
1 3.5' 1) RB. sump 1evel~'should be' , . ,E.07 Step;23 ! l maintained hightenough to e' CP.101, Step 8- l provide' adequate NPSH for . Difference #9 I LPI or RB. spray. . l
-2) Operator should.look.for -* Difference #10:
'l a SGTR if. RB sump level . . 4(Step 11.6, E.06.) '
cannot be maintained at- E an adequate level'. ; 4
- 3) If RB sump level.becomes . *: . Difference #11
.too high,. considerations for lowering it should. '
be made depending on y cooling method used.
- 4) The amount of radiation in. . See Section 2.0.'
the RB sump must be. - considered before attempting to remove any water from the sump. 1 DIFFERENCES: The E0P's do not specify operating equipment in'the auxiliary - building for purposes of monitoring or controlling leakage from the RB. The operating equipment involved at Rancho;Seco. include. area- - radiation monitors-and radiktion monitors.for component cooling ' 1 water, nuclear service cooling water and nuclear service raw water, 'j Such instructions are not necessary in the E0P's since alarms'on these radiation monitors-are addressed by annunciator procedures and I these procedure will direct the operators to perform the.necessary. :; response actions. J
.I l
l IV.F-3 1 - l :
.- z - -
, - .i a
!TBD t%nter - IV.F CONTAINMENT SYSTEMS :(Continued)
Differences #2/3:
.. 2/3. The' E0P's :do not address monitoring R.B.E radiation levels'.an'd R.B.. l temperature for: purposes of. initiating R.B.. isolation. R.B. ]
radiation: levels and R.B. temperature are, however, constantly- 'l i monitored by' the Control . Room Operators during plant operation. to ' . maintain' awareness'of R.B.' environmental' conditions!. Both parameters' c are used, in combination-with other plant parameters in verifying: ,, , suspected ~or actual LOCA's. ' l L ,. .. I High R.B. pressure and--low RCS pressure are constantly monitored by the SFAS for: purposes of detecting LOCA's andiupon detection, implement R.B. isolation. Since low RCSl pressure and high RB; s-
'{
pressure will develop within seconds of a large LOCA,l isolation signals. based upon,high RB temperature or. radiation levels are not. needed for initiation. y
'4. Maintaining adequate core cooling,-without overcooling, is the: ,. . - :i universal objective of the.EOP's. -Control Room Operators, through training, are aware of: this objective and do- not' need ; explicit steps ;
in the E0P's to repeatedly inform them of.this tmportant, function. 5/6. Cooldown rates during cooldown-using either LPI or OTSG cooling is; . , specified .by the Shift. Supervisor with regard to- the limits.-specified : ' in the Technical: Specifications. - Refer to III: B 2.10. .
- 7. . CP.101 Step 1.0 requires RB Sprap to be run'for 22 minutes minimum and Emergtney Coolers to run for 24 hours following a major LOCA.
- 8. Step 12.10 of CP.101 discusses monitoring RB hydrogen concentration and verifying.that the hydrogen purge blowers are operable. If RB hydrogen concentration were~to increase to 3.5: volume percent, then hydrogen purging would begin per'A.52:-(Hydrogen Monitor and Purge System). Prior to startup, the hydrogen purge system will be 4 abandoned in place and new hydrogen recombiners will-be installed in-
, the R.B. In addition. and: prior to startup, the E0P's will be l revised to incorporate instructions for utilizing the recombiners. 1 i i ! 3- *t> l IV.F-4 i y a
TBD Chanter: IV.F CONTAINMENT SYSTEMS (Continued) __
- 9. Sump level lights are checked prior to recirculating the RB sump.
1(~T
" However, there are~ no' explicit steps.in the E0P's. that specify maintaining emergency sump level high.enough to provide adequate NPSH. After a.large break'LOCA, most,1f not all BHST water will end up in the RB sump along with.RCS inventory and w'111 provide adequate NPSH without_ operator action required to maintain it.
- 10. The E0P's do not mention any steps _ requiring the operator to look for.
a SGTR if RB emergency sump level cannot be maintained at an adequate level. Such instructions are not necessary since existence.of a SGTR is determined independently from sump level via alternate instrumentation, operator. training, and execution of the. emergency procedures. See also Chapter.III.E 2.1.1/3.1.1, Difference #1. i
- 11. The E0P's do not contain any steps requiring sump level to be decreased if it becomes:too high. A high sump level is not.a problem since a 1.evel as high as 8 feet can occur without submerging any safety related equipment. Discharge of the BHST inventory and RCS j inventory to the sump results in a level of 6.1 feet.- 1
'i 1
i i l l IV.F-5
l TBD Chanter: IV.G REACTOR VESSEL P/T LIMITS ...
' TBD Section(s) 1. Introduction-This section is.a general discussion of.the Technical Specifications-reactor vessel P/T limits. The only action statement is to operate
-within the P/T limits. Figures in the E0Ps andon SPDS present the limi t. The EOP steps which refer to initiating HPI cooling in E.04 give direction to avoid the limit. Additionally, operator training and routine startup and shutdown procedures include observing the P/T limi t.
DIFFERENCES: None
\
IV.G-1
_TBD Chanter: IV.G _ TBD Section(s) 2: PRESSURIZED THERMAL' SHOCK LIMIT This section is a description of'the PTS concern, specifies'when 'it is applicable, and instrumentation to use when evaluating.it. TBD ACTIONS EOP STEPS
.- The PTS P/T limit must be used . Rule 6 Step 1 if any valid RC temperature . E0P Figure 1 (RCS PTS Operating (Table IV.G-1) is below Curve) 500*F and:
- Difference-1 HPI' inject valve position is l
- a. RC cooldown rate has used rather than HPI flow exceeded the Tech Spec because HPI flow indications limit nt' have limited > accuracy below 100 gpm.
- b. All RCPs are off and HPI flow exists through any HPI line to the RV (not the normal MU line).
. Ther.:
( a. Prevent any significant . Rule 6 Step 2 heatup or repressurization . Difference 2 once SCM is restored.
- b. PTS takes priority over . Rule 6 Step 3.2 fuel pin in compression.
1 .
- c. PTS limit remains in . Rule 6 Step 3.5 effect for the remainder of the cooldown even if the cause has been corrected.
. PTS limit per Figure IV.G-1. E0Ps Figure 1 (exception E.07.-
Figure 2)._ EOP PTS curve is saturation -100*F as required on Figure IV.G-1. IV.G-2
]
..4 1
-DIFFERENCES:
J~' 1. E0Ps do not implement Table.IV.G-1 for temperature measurement _- 1
'- instrument to use during PTS. !
1 Actiori: , Implement Table IV.G-1 into the E0Ps by placing. it on the RCS PTS Curve (Figure 1 in all- E0Ps except E.07 where it is Figure 2). Implementation: J Pre Startup .) i
- 2. Rule 6 Step 2.1.2 indicates to prevent "any" heatup or pressurization for at least three (3) hours where the TBD indicates to prevent."any
, significant" heatup or repressurization without a time limit. ' The Rule i
6 also requires to contact station management. ] Action Delete the three hour time limit in Rule 6. Implementation . Pre Startup. 1 a 1 1 ,. l
)
f
= .
IV.G-3 . 1 ' (.-
~
~
[' -J j
)
TBD Chanter: V.A _, TBD Section(s) 1.At HPI SPECIFIC RULES TBD ACTIONS E0P STEPS 1.A.1 HPI must be INITIATED whenever . Rule 1 Step 1.1 ! loss of adequate SCM occurs. . E.03 Step 2.0 , l.A.2 . HPI must be INITIATED when . Rule 1 -Step 1.2 (The 2450 psig SG heat transfer is not setpoint is discussed in TBD adequate and FH is.'not Section IV.B.2.A.2.3.) available to either SG.
- E.04 Step 5.0 (initiates HPI cooling).
. E.0 Steps 1.0; 2.0, 4.0, 9.0, 11.0, 15.0 (logic steps which go to E.04 Step 5.0).
- If two HPI pump flow . E.04 Step 5.0 (EMOV'is always cannot be' achieved,~the .
opened unless there is no PORV (EMOV) must be opened.- HPI/MU flow). (TBD Section IV.B.2.A.3 . E.04 Caution before Step:5.0
=1ridicates this means if (with no HPI/MU available,-RCS only one HPI pump flow inventory must be conserved, is available, not zero .thus the EMOV is left closed).
HPI flow). 1.A.3 Whenever SCM is lost, maximum . Rule 1 Step 1 I HPI flow must be provided. . E.03 Step 2.0 (EOPs branch back to E.03 whenever SCM is lost.) l
. AP.23.06.(Enclosure 8.3) 4 (Highest priority symptom is loss of SCM.) 1
. E.07 Step 1.0 1
. CP.104 Step 9.1- ,
i i I l V.A-1 l
(
- 4 TBD ACTIONS EOP STEPS'
. {'"
1.A.4 HPI flow must be THROTTLED . E.05 Steps 8.0,-16.0 (Avoids to prevent RCS overpressure PTS and excessive SCM >100.) when SCM exists.
- E.04 Stepf 2.0 and 5.0, 9.0
,
- E 06 Step'17.0' Rule 2 Step'2.2.(If PTS is'
- a. Tech Spec P/T. limit. .
avoided, TS F/T is' avoided.) i
- Rule 2 Step 3 (Allows -
throttling if SCM exists.)
. E.02, 03,.'.04, 05 and .06-Figure -1, E.07 Figure 2 and SPOS all show'TS P/T limit curve.
.. Rule 2 is referenced whenever HPI is initiated.
. Difference #1 b .- PTS limit. Same references as above plus:
- E.05 Caution before Step 2.0-
= E.05 Step 12.0,~20.0, 27.0, 42.0
- Rule 6
- E.03 Step 14.0-
- E.04 Step 16.2
* 'E.07 Steps'24.0, 25.0
- CP.105 Steps 3.1, 5.3, 7.1 DISCUSSION:
Per AP.23.06, Enclosure 8.3.. Rules always apply and they.are also referenced in appropriate E0P locations as an aid to the operator. Thus, the EOP steps which refer to the Rules are not listed in this analysis. V.A-2 l a_ ___ _
DIFFERENCES:- _ If a PTS condition applies, Rule 2' requires HPI throttling prior to exceeding the PTS limit. The PTS limit is always more restrictive than the. Tech Spec RV P-T limit. -For the case where the PTS limit does not-apply the HPI may be throttled anytime the RCS is subcooled, and Figures f in the EOPs and SPDS show the'RV P/T limit which is well.known by the - operator. HPI throttling to avoid Tech Spec P/T limit is thus assured without the explicit reference to it in Rule 2. Avoidance of Tech Spec: _ P/T limit is also explicitly stated when HPI cooling is initiated (E.04 i Step 5.0) by opening the EMOV prior to initiating HPI flow. )
-t Action: )
Revise Rule 2 to explicitly include the Tech Spec P/T limit.- Imnl ementation: - Post Startup , Justification: Because the EOPs assure compliance as written now, this enhancement l may be made after startup.- i l ( ) V.A-3
TBD Chanter: ~ V. A
'(
TBD Section(s) 2.0: LPI' SPECIFIC RULES TBD ACTIONS EOP STEPS 2.1 LPI must be INITIATED whenever Difference #1 any of the LPI initiation setpoints is reached. l 2. 2. . LPI' suction must be switched CP.101 Step 8.0 from the BHST to RB emergency .CP.103 Steps 14.0, 16.0 sump when conditions to dn- E.07 Steps 19.0, 20.0, 23.0, Status so are met. before Step 23.0 DIFFERENCES: ,
- 1. Operator training includes performing manual initiation of all. automatic equipment at its setpoint if it fails to do so automatically, thus a q specific direction to do so is not included in EOPs. ,
c a i l ' l k V.A-4
TBD Chanter: V.B _ TBD Section(s) I throuah 9: MFW/AFW SPECIFIC Fi[LES Refer also to the analysis for TBD Section IV.C. TBD ACTIONS EOP STEPS
- 1. IF SCM lost, SG 1evel must be . Rule 3 Steps 1.1, 5 controlled at or above the . Rule 4 Step 4 loss of SCM setpoint. . E.02 Step 4.0
. E.03 Step 3.0
. E.04 Step 11.3
. CP.104 Steps 9.3, 11.3
. E.07 Steps 2.0, 6.0, 8.2, 15.3, 18.2, 25.3
. CP.103 Step 1.2
- 2. If all RCPs off and SCM exists, . Rule 4 Step 3 SG level must be controlled . E.02 Step 4.0 at or above Natural Circulation . E.03 Step 18.0 setpoint. . E.04 Step 11.2
. E.05 Step 10.0
. E.06 Step 11.0
- CP.104 Step 11.3 7
i
- 3. When reactor is shutdown, . Discussion #1 HFH raust be controlled to . E.02 Step 4.0 prevent SG 1evel from . E.05 Step 1.0 exceeding the shutdown SG . E.06 Step 16.0 overfill setpoint.
- 4. When the reactor is shutdown, . Discussion #1 AFH flow must be stopped to - E.02 Step 4.0 1 an overfilling OTSG before . E.05 Step 1.0 SG 1evel reaches the shutdown - E.06 Step 16.0 )
SG overfill setpoint. 1
- 5. AFH must be STARTED whenever + AFH autostarts upon low level HFH flow to both SGs is in either OTSG.
disrupted causing SG water . E.02 Steps 3.4, 4.3 ; level to decrease to the AFH . E.04 Steps 3.0, 7.0 l start SG level setpoint. . E.05 Steps 7.2, 15.0 j i V3-1
/' -TBD ACTIONS EOP STEPS s
- 6. AFW must be STARTED whenever e Rule 4 Step 1.2 there is inadequate. primary . E.04 Step 3.0 to secondary heat transfer OR
~
whenever SG 1evel must be-
- Rule 4 Step 1.4 controlled at the loss of . E.03 Step 3.0 SCM setpoint.
- All E0P steps applicable to TBD Section V.B.1 above apply here because AFH cannot be controlled at setpoint unless it is first started.
- 7. AFW must be STARTED or MFW + MFW cannot be rerouted to AFH rerouted to the AFH nozzle nozzles.
when forced RC flow is lost.
- AFW autostarts upon loss of all four RCPs.
- All E0P steps applicable'to BD-Sections V.B.1 and V.B.2 above apply because AFW cannot be' controlled at a setpoint unless-it is first started.
- 8. If AFW flow should be added, .- Rule 3 Steps 2, 3.1, 4 it should* (must) be controlled + E.03 Step 3.0 (Information'3.4) 'l so that continuous AFW flow
- Discussion #2 is provided and the SG 1evel never decreases with an overall progression toward the required
.setpoint.
Discussion #2
- 9. Whenever adequate SCM is lost a Rule 3 Step 5 and incore T/Cs are not
- E;03 Step 3 0 (refers to Rules decreasing AFH must be 3 and 4) controlled to provide at least ,I the minimum flow rate listed in Chapter IV.C to each S/G (150 GPM-SMUD) until the loss of SCM SG level setpoint is reached.
V.B-2 f
DISCUSSION: __ , 1. The Rancho Seco'EFIC MFH overfill setpoint has not yet been established. It is set at maximum on the, full range level (water at' upper tube sheet) until the setpoint is determined. All steps noted for the previous TBD Sections V.B.1 and V.B.2 are applicable to this TBD section because any instruction to the operator to" control SG level at a setpoint would accomplish controlling or stopping flow before the overfill setpoint is reached.
- 2. Rule 3 Steps 2.3.1 and 4 indicate it is desirable to (i.e., should) maintain AFH flow but TBD V.B.8 indicates a requirement (must be). .The TBD is inconsistent regarding if continuous AFH flow is always required. TBD IV.C.4.4.1 indicates that continuous- flow is desirable
("should"). The TBD Rule V. B.8 indicates continuous flow is manditory ("must"). The rule is intended to obtain optimum conditions for OTSG heat removal with AFH by maintaining the highest possible thermal. center. Core protection is not'an issue with respect to this' rule, thus it is apparent that the rule is desirable, not a requirement and TBD Section V.B.8 is incorrect stating "must." The cited EOP Rule Steps implement the TBD intent of Section IV.C.4.4.1. (. V.B-3
... _J TBD Cha$ter: V.C ..
- (E TBD Section(s) I t ' RCP SPECIFIC RULE-u I
TBD ACTIONS EOP STEPS
- 1. .When adequate SCM is lost,
- E.03 Step"1.0 all RCPs must be tripped . E.03 Step 16.0 immediately.-
- Difference #1' Exception: If RCPs are not .. -- E.03 Caution before Step 1.0 tripped within two minutes -*: E.03 Step 1.0. !
after losing adequate SCM,.
- AP'23.06 Enclosure 8.3 then reduce the number of operating RCPs to one i_n
- each loop.
DIFFERENCES:-
' 1. E.03 Step 16.2 allows.up to two minutes.of.RCP operation if SCM is lost-when restarting.a RCP after regaining SCM. The- RCP trip .<2 minutes .
criteria is based on an analysis which assumes, among other. things, the RCS is initially subcooled without voids and there is maximum decay. ( heat. Although there will be significantly less than maximum decay heat, there may be voids in the RCS. Without further analysis it.cannot-be. concluded that a two minute run is: acceptable. Action: Delete the permissive for a two minute pump operation and. replace with directions to' trip RCP. j Implementation: Pre Startup
')
( v.C-1 *!
1 I LOGIC COMPARISON 1 l This section compares the TBD and E0P logic by performing a side, by side presentation of the TBD and E0P flow charts. Differences are identified by numbered notes and explained on an attached text for each of the six flow j chart comparisons. Comparison is made to all TBD flow charts except the cooldown section III.G. (Cooldown procedures are examined in a seperate part of this report.) l ( i l
. FC-1 I
a m
~
COMPARISON OF TBD AND E0P FLOWCHARTS < 1
'j TBD Fioure III'. A.1 and E.01 Immediate Actions and '
E.02 Vital = Systems Status Verification .. DIFFERENCE #1:
-DESCRIPTION: y The: flowchart indicates that if there is an upset in heat tran'sfer at ' l any time above cold shutdown the operator.is.to' stabilizen the plant.by; first gaining reactivity control and secondary control. The TBD states '
that "...the applicable partsiof thel guidelines, if any,ishould f be. followed to correct the heat transfer conditions." The present EOPs 'j bypass the reactivity and secondary' inventory and pressure control' steps. of E.02 for heat transfer upsets'that ' occur: when .the reactor isi shutdown. EXPLANATION: Overcooling result in positive reactivity insertions. During the ' heatup/cooldown phase of plant operation ~the reactor is shutdown by t several percent. Only severe, prolonged overcooling can result in- . inadvertent criticality. . The RPS:high flux: trips are set'at.less than ~ - five: percent when the RCS:is below normal operating pressure.1This wil1J J" prevent large amounts of generated core heat. .One. rod group is normally withdrawn' during the heatup/cooldown mode, providing for instant l negative reactivity insertion if required; Furthermore.coperators would' take actions:to initiate high pressure injection from.the.BHST which will provide negative reactivity-for.the case of, severe overcooling. When the reactor is in 'startup mode, reactivity shutdown valu' es areL reduced so that an overcooling transient could result in.an~ inadvertent ~ 'l criticality. All- safety rods are withdrawn in' this-case. . Tripping the - ' ' reactor at the initiation' of a cooldown transient would prevent this Concern. Identification of an overfeed.or OTSC steam rupture during heatup/cooldown conditions is important..due to the potential of rapid-overcooling due to low core'. decay heat output. 0verheating conditions. are less of a. concern at these plant-conditions ~due.to the.added' time period for operation action but still require attention' . E.01sshould be revised such that the operator addresses al1~ steps ~of E.01 and E.02 should a heat transfer upset of loss of subcooling transient' occur-during heatup, cooldown, or hot. shutdown modes. This can be f accomplished by modifying the.last . step from E.01. (See action item.)
.i 1
.. e ~FC III.A R k j
, 1 L < l
The E.02 step th'at checks.0TSG steam pressure controlling at 1000 psig ~~ will not be directly applicable in the heatup/cooldown mode. The check /" of steam pressure will provide the operator with an early indication of the magnitude of the overcooling and the affected OTSG(s). The. check involving feedwater flow will identify overfeeding transients. Operators are knowledgeable of the required feedwater flows, OTSG 1evels, and OTSG pressures expected for different points in the' cooldown or heatup phase of plant operation through their training and experience. No changes to these steps are required. Additional guidance will be provided in AP.23.06 which tells the operator to follow all steps of the E0Ps provided the actions do not exaggerate the unexpected transient of E.01 Step 3. ACTION: Revise the branching for upsets in heat transfer and losses of subcooling margin when the reactor is shutdown so that entry will occur at the beginning of E.02. This dan be accomplished by changing Step 3.0-of E.01 to read:
"If an unexpected transient occurs.within the Reactor shutdown, ItiEli Go to E.02 Step 1.0."
This will bring the E.01/E.02 flowchart into compliance with the TBD flowchart. IMPLEMENTATION: Pre Startup DIFFERENCE #2: DESCRIPTION The flowchart and TBD text do.not include the immediate actions of E.01. EXPLANATION: The immediate actions of E.01 are completed in the TBD within the respective subsystems. Reactivity control contains the step to trip the reactor. The turbine is tripped as part of the TBD step to control OTSG pressure. Letdown is reduced to aid in the control of primary system inventory due to the expected cooldown and contraction of the RCS following a reactor trip. The manual reactor and turbine trip are
~
backup actions for conditions that should have automatically occurred. i FC III.A
m DIFFERENCE'#3:. .. [ DESCRIPTION: The-flowchart requires that at the conclusion of treating a heat' transfer upset symptom that the. operator determines if a SGTR exists. The' EOPs do not always have a specific step to check for a SGTR in every case ncr do they branch back to E.02 as the TBD flowchart indicates. . EXPLANATION:- Heat transfer upsets take ~ priority over a SGTR. ~ When the' heat. transfer upset is arrested and the plant is stable, the lower priority symptoms are treated (cer TBD and AP.23.06). If the specific E0P or CP checked for SGTR, the operator would branch-to E.06. If not, the E0P entry conditions would be used to enter E.06 after heat.'ransfer was stabilized (refer to AP.23.06). s. r FC III.A
'{.
~
COMPARISON OF TBD AND EOP FLOWCHARTS RR *
- 8 E.01 IMMEDIATE ACTIDHS rausn me es to E.92 VITAL SYSTEM STATUS VERIFICATION --
ans 8. M 8879 mwee 13 Sil.n
._ a -
- - - 1 i 885 e- . ,e., ,
ogg, EX57 $4P'S IPP sua emastings meses saa trette tu ggAT um egurres malggum M E EE M- MM jpIPP4 i innsetnts flCTIOne E.81
, E.02 measur fase g ra.;
esmetivtfY tus enactes menettytt? CollTROL ese#en seesta rumantv samass C81sfegua0 asusten poums
*A le"W rJumam/een sammener Baumanes apu essa passene me uf' spees 3d.,j g,,,,,,,, mummut emneak
_m j
.Le.agL.e e . 9838E55 8."I"_"' ._
I q passev """"*" ., 3' enesman me Palment da.1.J suumsessy assowest sammuy saurma6 -
- e, ,e,,,e, -
bpeeumus essamer {
- . .e m I
MT,_ l d See &la 88,88
' 5 charmsamb j
'I4 RCP RUMMING '
magessak essvesestsau Niet PoleER u,gg,gy ,,m, puman namumb 800 PolsER amtsam to sustauk senemus etsst t ansvens pues vos 19
$CM 88 78 08978 E. 88 ves 1e
"'" 3d.,a
-- so to rame w ms
- .. a _ , ,
,,e,,,,,,,,, - - e,..-e_
,em.,,, -
- a. e ..=
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l i COMPARISON OF TBD AND EOP FLOHCHARTS-i TBD Fiaure III.B-1 and E.03 Loss of Subcoolina , DIFFERENCE #1- f l DESCRIPTION: l The TBD in Step 2.3 controls RCS inventory. The analogous > step in the EOP initiates HPI flow. The TBD step appears to encompass more operator j actions than the E.03 step. The details of each step must be compared. ] EXPLANATION: . TBD control of RCS inventory contains two substeps: maximize HPI flow f and isolate possible leaks. E.03 initiates HPI and references E0P Rules. ] l and 2. The manual initiation of HPI using the SFAS _ digital channel . i l initiate pushbuttons starts the HPI pumps and opens the HPI injection { valves to a prethrottled position. Reference to Rule 1 will have the , i operator maximize HPI flow. Also refer to III.B.2.3/3.2. E.03 isolates possible leaks after.a check for excessive heat transfer. > The TBD isolates possible leaks before a check for exces'sive heat transfer. This deviation is explained on an alternate page in this section. (Difference 5) , 1 DIFFERENCE #2: DESCRIPTION: ; It is not clear that TBD Step 2.4 accomplishes the same actions as E.03 Step 3.0. EXPLANATION: i OTSG levels are increased to the ECCS setpoint when SCM is lost. Auxiliary feedwater (EFIC) is the preferred feedwater flow path (TBD IV.C.3.3). The verification of EFIC in Step 3.0 of E.03 is in agreement l with the TBD. E.03 Step 3.0 references Rule 4 which defines the proper OTSG level setpoint for different plant conditions. The values in Rule 4 agree with the levels described in the TBD in paragraphs l IV.C.3.1, 3.2, 3.3. 1 FC III.B
t DIFFERENCE #3:~ ... 7 -DESCRIPTION-7
. This E0P. step does not appearLin .the TBD flowchart..
EXPLANATION:
^
This' E0P_ step: originates from-lessons?1' earned from the TMI-2$ event and
.is an NRC commitment. _Its placement early in E.03 ensures representative RB atmosphere samplessare drawn in a timely manner?to' support' accident. severity calculations.
DIFFERENCE #4: DESCRIPTION:' E.03' checks for excessive heat transfer at1this point!.'.The TBD flowchart appears to _have no similar. check.
. EXPLANATION::
Included in-the text of TBD block 2.4 is the statement "SG 1evels:must-be~ controlled at the loss of SCM setpoint Lin each SG that can hold pressurt." An OTSG with a steam leak resulting in an overcooling will; be identified in:the E.03 step and.either< isolated or the steam
~
generator will be dried out(in-E.05. Thus,Jthe.E.03 check' accomplishes the same intent as an earlier.TBD step.. , DIFFERENCE #5:- DESCRIPTION: The E.03 sequencing 'of the _ treatment of excessive. heat. transfer actions' and the isolation of leaks diverges from the;TBD.E The TBD. includes the isolation of leaks in the " Control RCS Inventory" block. The TBD: isolates leaks prior to checking for excessive. heat transfer. The E0Ps follow the ATOG sequencing. ACTION: Reverse Steps 5.0 and 6.0 in E.03 so that isolation of possible RCS leaks' occurs before actions to check for excessive heat transfer. Reversing these steps will bring E.iO3 in line with the-TBD action.. IMPLEMENTATION: Pre Startup. FC III.B
-r
, DIFFERENCE #6: , ('- DESCRIPTION: The E03 flowchart contains a-' decision ~ block- that transfers back to the-beginning of E.03 if subcooling margin is regained but subsequently lost. This step'does not appear on<the TBD flowchart. EXPLANATION:- This step is not explicitly. stated in the TBD. However, the'TBD and ATOG philosophy is based on the priority of- symptoms with loss of SCM. being the highest. Refer to TBD paragraph III'.A;3.3. DIFFERENCE #7: DESCRIPTION: The E0P decision point of'CFTs emptying does not. exist in the TBD'- flowchart. ' EXPLANATION: Core flood tanks will' discharge during large break LOCAs and' prolonged? overcooling. For the case of large LOCAs, the TBD and the E0Ps will. accomplish the same' actions although the pathway and questions asked differ slightly.a The TBD asks if heat transfer to the OTSGs exists. In'
.this case, it would.not as the OTSGs would'be heat sources. RCS /. pressure and RCS cooldown would be on break /HPI-CFT flow.- The operator following E.03 would conclude excessive heat transfer.did not., exist as .j the OTSGs would uncouple-from the RCS. CFTs would be seen emptying;so i the branch to CP.101~would be made.- CP.101 addresses cooldown on break /HPI-CFT flow for large LOCAs.
DIFFERENCE #8: DESCRIPTION. 4 It is not apparent that TBD Step 2.10 is equivalent'to E.03 Step 10.0. The check for OTSG heat transfer follows the check for core cooling down on HPI only in E.03 and precedes'it in the TBD flowchart. EXPLANATION: Although the TBD and E0P flow charts appear to differ, the only actual i disparity is the placement of the check for.0TSG heat transfer. The TBD checks for the existence Lof 0TSG heat transfer first and if.there is ' none, a check is made to see if OTSG heat transfer is required. .E.03 first checks if OTSG heat. transfer is required and if it is, then checks for its existence. The two flowcharts produce the same end results, j D FC III.B
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q DIFFERENCE #8:: (ContinuedF .. If the break is'large enough,LCFTs will discharge'and OTSG-heat-transfers is not- required. : The EOP flowchart has the advantage of branching to a !
'large LOCA procedure more quickly. The operator need not spend time i analyzing for OTSG heat' transfer. .The-time period required for- 11 analyzing'for heat: transfer is longer.than the period-required for , i assessment' of CFT discharge. .The operator is required to check more-i parameters in the former. case.'
If the break is not large enough to result:in CFT discharge,;but..is 1 large enough such that HPI? flow is adequate for core cooling at greater.
'j than the maximum Tech Spec l rate, OTSG heat transfer is not required. :If the break'isinot large enough to allow- sufficient .HPI flow, E.03 induces -
OTSG heat-transfer to increase'the cooldown; rate. The:value of 100*/hr t is based on the maximum Tech Spec allowable cooldown rate. A cooldown system with an unisolable leak should be cooled and depressurized-as quickly as possible to limit the volume of' inventory lost outltheLbreak. The TBD. flowchart induces.0TSG heat transfer. if HPI/ break flow cooling" does not result in conditions for long-term decay heat or LPI' cooling? through. branches'to normal plant control or branches.to-loss of heat-transfer for cases where RCS' pressure endsup-higher.than OTSG pressure. . CP.104 includes reestablishment of OTSG heat transfor should the cooldown rate become'less than 100*/hrm 'These CP.104 steps' ' accomplish the same results as' the TBD flowchart.. .- Both the TBD and E0P flow charts work equally well for medium sized leaks'where CFT discharge is not occurring if the SPOS is available.,
.However, when SPOS is not available, the TB0 : initiation check for- heat ;
transfer in one or both OTSGs.will slow the. operator's' response. 0TSG
~ Tsat is 'not immediately available .and the relationship' of> Tsat to RCS cold and OTSG AT cannot be easily made. The operator need not be'
.butdened with this check if CFT or,HPI'flowiis sufficient to provide core cooling. The E0P sequencing streamlines the procedure and-places the operator in the appropriate cooldown procedure as .quickly as possible. j 4
The E0P blocks that check if'the CFTs discharge or cooldown rate exceeds ' I 100*/hr meet the intent of'the TBD. block 2.10. Large and' medium sized LOCAs will- cool the RCS by HPI flow or a combination of HPI and.CFT j flow. The RCS will rapidly cool.to_ lower than OTSG saturation j pressure. RCS pressure will decrease below OTSG pressure because the j RCS is also saturated. For these cases, both the TBD and E.03.a110w the- d C RCS to cool on break /HPI flow. TBD block 2.11 is equivalent to the early steps of either CP.101 for large breaks or CP.104 for medium and small breaks. A loss of SCM caused by a severe overcooling transient will not . 1 transition-through this part of either the TBD or E0P flowchart. The I TBD does not feed an OTSG that'will not hold pressure ine ' rck'2.4. i E.03 sends the operhtor to E.05 in block 5. ) FC III.B t
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DIFFERENCE #8:' (Continued)' '
~Losse4 of SCM due to a loss.of OTSG heat transfer either by total loss of '9 v ater or hot let voids blocking natural circulation 'will: result.i )
i t. W cooling. Both prior TBD and EOP: steps addressing the attainment . of ; ver OTSG levels will ensure efforts. to restore main or auxiliary
~
feedta r- flow,1if lost (block 2.4 and' Step 3.0, respectively).. If full, HPI fww cannot be achieved :the RCS 'cooldown rate ~ may not .be 100*/hr.n j h The E0Ps will attempt to restore OTSG heat. transfer by branching .to e ' E.04.,'The'TBD-also restores OTSG heat'transfor but.no cooldown rate is. ! specified. - The E0Ps are conservative;in that they take action to cool, -
- and depressurize the plant as quickly as possible.: ,
DIFFERENCE #9:
, DESCRIPTION *-
If SCM is regained,the TBD flowchart branches to . normal. plant control. The E0Ps continue with actions other than normal plant control in the cps.<
- EXPLANATION:
Subcooling margin will eventually be. regained for all size'LOCAs.but the-loss of inventory will. continue. Concerns'other than normal plant - control need to be addressed. The.TBD flowchart is too simplified in-
~
this area for the different outcomes of all possible' transients'. :The TBD flowchart works for loss of SCM due:to causes that can be-( corrected. For cases where the.ECCS equipment allows for restoration of SCM, the TBD flowchart is too simplistice DIFFERENCE #10: L DESCRIPTION: ; The TBD flowchart cools the plant on one OTSG. The EOR attempts.to - establish heat transfer to the second OTSG should only one be available. This is accomplished.by branching to E.04.- The TBD flowchart does not appear to attempt to restore heat transfer to the second OTSG. EXPLANATION: i The description paragraph for this TBD block (III.B.2.8) states that .j attempts should.be made to restore heat transfer to both steam' i generators. Thus, the TBD and EOP.. intents are identical in.this area.. i For a detailed discussion on establishment of heat transfer:to one 0TSG i while heat transfer exists in the other OTSG,-refer-to comparison'of TBD ., text with E.03,1Section III.B.2.8/3.5. FC.III.B ; a
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j DIFFERENCE #11:
' DESCRIPTION:
The TBD addresses cooldown on break /HPI flow' and/or saturated OTSGs. : These steps are not indicated on' the E.03 flowchart. EXPLANATION: All steps concerning these decisions and subsequent actions are in the cooldown procedure part of the EOPs. Refer to the comparison of the TBD . and E0P cooldown methods. .
]
DIFFERENCE #12: I DESCRIPTION: The TBD has a general action statement following the restoration of subcooling margin. The E.03 procedure is more detailed in this area. The TBD text must be reviewed for any TBD-EOP differences in this area. 1 EXPLANATION: Closure of ADVs and TBVs is not discussed in the TBD. They are closed to prevent a rapid cooldown for the case where hot leg voids have blocked natural circulation. OTSG boiler-condenser heat transfer has been attempted, and RCPs are available. Starting an RCP will collapse the voids and OTSG heat transfer is assured. The E0Ps start one RCP per loop but.the TBD starts only one RCP if OTSG l heat transfer cannot be established. [ NOTE: . The E.03. flowchart conflicts with the E.03 procedure on the number of RCPs to be started.] The EOPs assume feedwater is available and the OTSGs can be made a heat sink. The TBD action addresses the more general case. Only one RCP should be run if OTSG heat transfer is not available to reduce the heat , input into the RCS. This instruction is familiar to the operators and i is included in E.04 Step 5 and E.05 Step 22. E.03 should be revised to . account for all possible plant conditions if subcooling margin is regained. ACTION: Revise E.03 Step 16 to start only one RCP if feedwater to the OTSGs is not available. Revise the E.03 flowchart to reflect the E.03 procedure. FC D I.B
-_____________________-_7 DIFFERENCE #12: (Continued)
.j IMPLEMENTATION: Pre-Startup 1 The E0P step to stabilize Tcold does not appear iri the .TBD or- ATOG. . l This step has been added for the case where the leak has been isolated I and HPI flow is insufficient to remove all core decay heat. The RCS I could rapidly heat up and pressurize, possibly exceeding the PTS limit, if the previous action to close the valves was'not countermanded. For-transients where HPI capacity is sufficient to reestablish SCH and { initiate an RCS cooldown with flow out a break or the EMOV, it will not l be possible to stabilize Tcold. TBVs and ADVs will remain closed. 3 l The verification of natural circulation is not included for this step in , the TBD. This E0P step was added for the case where HPI' flow is not- ; sufficient to remove all decay heat and OTSGs are removing some or all decay heat. ; For reference back to SCM regained - reference details III.B.2.13. i
)
1 l l i I l l 9 D FC III.B l l
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COMPARISON OF.-TBD RND~E0P FLOWCHARTS - . ..- E.03 LOSS OF'SUB'C00 LING MARGIN '
'PAoE Or S .
'gg. ~ yT ~~;k GU10ELINE- lIII*E l.' R I
- j. .i TIFICATION OF'R LACK OF
~
i ADEGUATE SUS = '4 COOLING MARDIN d 3.I _______________________________________p___________ j 1 o TRIP ALL RCP*s TRIP ALL RCP's e...... iv,A e a E
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INITIATE NP!
- I CONTROL RCS ,
INVENTORY-S.2 _________________y . EFIC ACTUATION e.......e LLJ . . I
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.g SUSC00 LING yg, du :
SUSC00 LING l NARC N B nARCIN C RESTORE 0 RESTORE 0 l i
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. 8 E' ?\ 1 vs C0 70 vs TAKE ICC SUPERHEATED g,gy SUPERNEATED ACTIONS III.F _
no *! we ' 1. t - 8 e.......e
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CORE FLOOD vg CO 70 TMNKS gp,ggg l EneTY!NC i no
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1 COMPARISON OF TBD AND EOP FLOWCHARTS. . E.03 LOSS OF.SUBCOOLING' MARGIN Prot 0, 'S Eg Ip.g F A@HEAT TRANSFER IN NS ONE OR SOTH SCs v50 o is C/0 RATg CONTINUES t.,
= TO COOL aa0 ygg
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IN.DOTH If,I.FF 8,g OTSC* s t
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CD TO $$*3 pp*****$ e CP.lS9 se***eese COOLDOWN OH i DRERK/HPI FLOM g 5 3.7/IV.S l
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- 2. S ISATURATE0 CD TO C00LOOwM i CP.108 WITH SCs 3.8/tiI.C ]
__-._y CD TO RESTORE HERT j E.09 ' TRANSFER
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~~"""""; SUSC00 LING REESTRSLISH I
MRACIN NORnRL PLRHT RESTORED r S.4 0 E.87 2.7 ICC
~~~~~~~
TRKE ICC SUPERHERTED RCTIONS Ill.F MO 0- _ _ _ _ .- _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . __m___________ . - _ .
COMPARISON OF TBD AND E0P FLOWCHARTS - . E.03 LOSS OF'SUBC00 LING MARGIN gor o e T,sg he 3 a .s m 13 IF eCa LO.T ..... A DURINC LATER Ifj F,F,Q STEPS 14 THROTTLE HPI v 2.6 l 16 " REESTABLISH ~ CLOSE ADV'S & MORMAL PLANT ygy, g CONTROL 3.4 16 i START ONE RCP 0,I FF 17 STASILIZE WITH A0V'S & TSV' S o gg CAN RCPd o NATURAL
'E "U" CIRCULATION 19 o OPEN SPRAY BLOCK VALVE '
o
.l LOST .
PRIMARY 70 SEC HEAT ft C0 TO l TRANSFER i 1 ne l 21 SCTR E.86 me 22 CD TO CP.lS6
COMPARISON OF TBD AND EOP FLOHCHARTS TBD Fiaure III.C-1 and E.04 Loss of Heat Transfer , DIFFERENCE #1: DESCRIPTION: The TBD requires HPI cooling'be initiated in two cases:. .
- 1) The.RCS is saturated, feedwater is available, the RCPs'are not available, the transfer is not~ established after. making the OTSG a heat sink.
- 2) Before RCS pressure. reaches the EMOV setpoint, the RV P-T limit, or ;
the PTS limit if feedwater is not available. - For the first case the TBD waits 'for the RCS to become saturated before initiating HPI cooling. E.04 waits until RCS pressure reaches the EH0V setpoint of 2450 psig. The criteria for the second case are identical in the TBD and E0P. EXPLANATION: The EOP step is the same or more. conservative than the TBD. For a scenario where feedwater is available, the RCS is subcooled and hot leg voids block natural circulation, the RCS will heatup and expand. RCS pressure will increase to the EMOV setpoint. 'At this point the E0P instructs tha operator to commence HPI cooling. Assuming the RCS starts ; at expected post trip values under natural circulation conditions, the 4 EMOV will lift when core temperatures are less than 600 degrees and the RCS still subcooled. If the initiation of HPI. cooling were delayed j until saturation conditions occurred in the RCS, core outlet ! temperatures would be 665 degrees.. ] l If the RCS were saturated the attainment of the 2450 psig pressure may ; take longer with the' resultant RCS temperatures exceeding 600 degrees. However, the temperature would not exceed the 665 degree saturation temperature.- For this scenario the E0P actions are either conservative or the same as the TBD. l 1 l e i FC III.C l 1
-. )
i DIFFERENCE #1:' '(Continued) _] Other conditions in the TBD requirements'for HPI cooling initiation-will delay HPI core cooling.later than done by the EOPs. .If.the.RCS .is , j saturated and RCPs-are operable but. bumping them does_not restore . ~! I
, primary to secondary heat transfer, the TBD never does establish HPI-
. cooling. Similarly, a literal interpretation of tWel requirement to have' steam generator levels raised,to the loss of.SCM setpoint would. prevent the initiation of HPI cooling if levels.were still' approaching the ECCS' setpoint. Although maximum HPI flow will. be initiated in both these cases the EMOV will not be opened.. (It.may open at its setpoint and-cycle). RCS pressure will remain high and reduce the-amount of HPI flow that could reach-.the core.
If the RCS is saturated, maximum HPI will already be' established'by E.03 and Rules 1.and 2.,> Core cooling is assumed with only one.HPI' pump and- 1 the EMOV is closed per TBD III.C.3.3. .It may be possible for the RCS~to .; the saturation line.. ' ' ' remain For this saturated as it heats case ~ opening and pressurizes the EMOV to provide a along'ath'would vent p be an enhancement to E.03. , j ACTION: . Revise E.04 by adding a step between 9.0 and 10.0 to state: If the RCS ; is saturated with feedwater available to-at least one OTSG then' initiate-HPI cooling. IMPLEMF.NTATION: Pos.t Startup JUSTIFICATION: HPI is already at maximum allowa'bl'e flow since the RCS is' at-saturated d ' conditions. The EMOV need-not be opened to assure core cooling-per TBD-III.C.3.3. .The revision is an enhancement'to E.04 and is'not requiredi to prevent core or equipment damage. i j l I l J FC'III.C
- u lt
DIFFERENCE #2: _ DESCRIPTION: The TE,0 continually branches back to the check for HPI cooling required if feedwater is not available. E.04 does not hacie.this branch. EXPLANATION: E.04 bases the requirement for HPI cooling on one parameter, the EMOV ; setpoint. E.04 Step 2.0 states that anytime pressure reaches 2450 psig i prior to the restoration of heat transfer the HPI cooling must be J initiated. Therefore the E0P branch that corresponds to the TBD branch l is implied. l This part of the E0P flowchart also appears to differ from the TBD in that the TBD waits for the 2450 psig sotpoint to be reached before initiating HPI tooling for cases where feedwater flow has not been f established. But both the TBD text and the interpretation and training on E.04 allcw the operator to initiate HPI cooling if feedwater flow . reestablishment appears to be not possible. l l l Both the TBD and EOP allow the flexibility of attempting to restore j l feedwater without immediately initiating HPI cooling until RCS pressure l The TBD accomplishes this by repeated cycling l reaches 2450 psig. through the "HPI required" determination while the E0Ps allow the operators to continue with the steps of attempting to establish i feedwater up to the point that HPI is required before pressure reaches i 2450 psig. The E0Ps branch directly to the " initiate HPI" if feedwater l flow does not exist and pressure reaches 2450 psig. In the E0Ps the i requirement to initiate HPI before 2450 psig is emphasized via Rule .1 thus the need to initihte HPI is constantly monitored by the operators during the feedwater restoration steps. DIFFERENCE #3: l DESCRIPTION: l It is not evident that the E0Ps follow the TBD because the E0P flowchart is more detailed in this area. EXPLANATION: E.04 Step 7 levels are maintained according to plant conditions. These level setpoints are in agreement with the TBD Section IV.C. E.04 Step 10 decides whether RCPs are operable and then perform the actions.of Steps 11 or 12. These steps correspond to TBD Section 2.7. The actions in the E0P steps are in agreement with the TBD. FC III.C m
DIFFERENCE #4: __ _(f DESCRIPTION: ;
)
The branch 'for CFTs emptying does not exist in'the TBD. i EXPLANATION: This decision ~ point applies to the case where a large LOCA would exist coincident with a loss of heat transfer. The steps following this I! branch attempt to reestablish heat transfer with RCP pump bumps and by l lowering OTSG pressure. These steps .would be improper if'a large break ] LOCA occurred because the combination of CFT and HPI flow is sufficient J to cool the core. E.04 Step 8 directs the operator to CP.101 (LOCA with-CFT Emptying which contains actions more appropriate to a LOCA condition. DIFFERENCE #5: DESCRIPTION: )
.i E.04 starts and runs an RCP at saturate RCS conditions if one hour has j passed since reactor trip and heat transfer has not been established.
The TBD does not include this instruction. . EXPLANATION: Refer to analysis of TBD III.C.2.7/3.5 Difference #5. I ( DIFFERENCE #6: DESCRIPTION: i The E.04 flowchart includes a decision point.for subcooling margin. The TBD flowchart does not include this step. EXPLANATION: This decision point is included in E.04 to allow the transfer to the proper cooldown procedure based on subcooling margin. The two different methods of cooldown (subcooled or satura~ted) is implied in the TBD and 3 included in TBD flowchart Step 2.9. There is no difference between the ; intent or actions in the TBD or E0Ps in this area. The E0P flowchart is I just more detailed than the TBD flowchart. 1 T? FC III.C l
l .i; l-. _ COMPT.RISDN OF TBD AND'EOP FLOWCH'RTS-port t *8 6 E.04 INADEQUATE HEAT TRANSFER -
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j COMPARISON OF TBD AND E0P'FLOHCHARTS
'TBD'Fiaura III.D-1 and E.05' Excessive Heat Transfer ,
DIFFERENCE #1: DESCRIPTION: To ensure- PTS' limits are not exceeded, E.05 has inserted an extra step. to trip MFW and AFH pumps'that are still~' supplying flow the thel0TSGs.- The TBD does not include this action at this point of ~the mitigation-tactics. , v EXPLANATION: l a
. Excessive heat, trans'fer in tho' E0Ps'is ' defines as = TC decreasing out of the: post trip window and OTSG~ pressure < 960 psig'or Tsat < 540*F. It is not dependent on the cooldown rate. The TBD states "The most. ,
positive indication that the transient that is occurring is an . overcooling rather than a LOCA isithe fact that the secondary Tsat'will be decreasing rapidly." ' Additionally the TBD refers to tripping of the. MFW and AFH pumps only when the OTSGs are in danger.of being overfilled.~ ACTION: ( Excessive heat transfer is a dynamic situation and should be described in terms of cooldown rate with respect to Tc. -(e.g. Cooldown rate >- 100*F/HR and Tc below 525'F) This would also better define' excessive heat transfer when'.the plant is in the heat-up/cooldown mode and Tc is below 525*F. IMPLEMENTATION: Post - Restart-JUSTIFICATION: . 1 E.05 is more conservative that the TBD in this regard. Numerous excessive heat transfer transients have been' mitigated at the PSI . simulator and this requirement has not degraded the safety. level of the nuclear plant. y FC III.D ; a
- . ';l DIFFERENCE #2: .
DESCRIPTION:~ .! Steps 2.3,'2.4 and 2.5;of the.TBD and: Steps 3.and 4 of E.05 differ' j diagrammatically.- ., j i EXPLANATION: Although these steps differ diagrammatically, both the TBD and E.05.- accomplish the same function. Steps 2.3 of the.TBD and Step 3.of E.05 i determine whether or'not it-is apparent one OTSG is causing the < ~ 1 j overcooling. Step 3 of E.05 also directs the isolation of one'or both OTSGs depending on the status of'the OTSGs. The steps necessary'to ) o isolate one or both OTSGs are delineated in Step 4 of.E.05. Isolation of one_ or both OTSGs is accomplished;in Steps 2.'4 and 2.5'of
~
the TBD, depending on the response to Step 2.3. Rearranging the TBD-
' flowchart in this manner made.it possible to list all the valves for.
1solating both'OTSGs in Step 4. - DIFFERENCE #3: DESCRIPTION: Step 2.6 of the TBD and Steps 5 and 6 of the TBD differ diagrammatically. ! EXPLANATION: These steps accomplish the same function. Step 2.6 of the TBD -l determines if levels and pressures have stabilized in one or both OTSGs 'l to establish if an operable OTSG exists.. E.05 determines ~the' I operability of OTSGs by observing if levels and pressures are decreasing 1 l in the OTSGs. Step 5 of E.05 determines if.at least one OTSG is i L operable. Step 6 of E.05 determines if both 0TSGs ~are operable.: DIFFERENCE #4: ! i i DESCRIPTION: 1 Step 2.7 of the TBD states heat transfer should be reestablished in'one :! or both OTSGs. Step 7 of E.05 directs.the operators to reestablish heat 'i transfer to both OTSGs. l EXPLANATION: l
.i Step 2.7 of the TBD and Step 7 of E.05' accomplish the same function'for: 1 this scenario. It was determined in Step 6 of E.05 that both generators are operable, therefore, heat transfer is reestablished to both OTSGs.
i 1
.j FC.III.D
'I 5
l DIFFERENCE #5: _ J DESCRIPTION- 1 Verifying stable plant conditions when both steam generators are f operable is more detailed in E.05 than the TBD. , j EXPLANATION: f I Verifying stable plant conditions is described in the TBD as monitoring l for upsets in heat transfer, particularly. loss of subcooled margin. The TBD also emphasizes the need to monitor for a steam generator tube rupture (SGTR). These two items are incorporated in E.05 in Steps 9'and
- 11. Steps 8 and'10 of E.05 are necessary since E.05 may have been' .
i entered from E.03 " Loss of Subcooled Margin," which directs tripping the RCPs and initiating HPI. Objective 1.1.2 of the TBD discusses the need for'the operator to terminate the overcooling transient as quickly as possible to minimize the potential for exceeding PTS limits. If PTS limits are exceeded, it is necessary for the operator to stabilize RCS temperature and pressure. Monitoring for PTS and performing the functions necessary if PTS limits have been exceeded is accomplished.in Step 12 of E.05. DIFFERENCE #6* i DESCRIPTION: (s Step 14 of E.05 is not included in the TBD. EXPLANATION: This is on informational step intended to ensure the operator remains in E.05, and does not proceed to E.04 " Loss of Heat Transfer", after heat transfer is lost. in the OTSG that is allowed to boil dry. DIFFERENCE #7: DESCRIPTION: Step 2.7 of the TBD reestablishes heat transfer _to one or both OTSGs. Step 15 of E.05 reestablishes heat transfer to only one OTSG. EXPLANATION: I Step 15 of E.05 and Step 2.7 of the TBD are essentially the same. Step i 6 of E.05 determined that only one OTSG was operable for'this scenario. { l i i l D FC III.0 1 4
l q
-. .:\
DIFFERENCE #8: , . DESCRIPTION: 4 Verifying' stable plant conditions.when .only one steam generator is operable is more detailed in.E.05 than.the.TBD. EXPLANATION: l
)
Step 2.9 of the TBD monitors for. loss' of subcooled margin and an SGTR Steps 18'and 19 of E.05 perform-these' functions. Reactor building environmental l conditions (i'.e. reactor buildi'ng ' temperature and. humidity) are monitored to. determine-if a. steam break has occurred inside the reactor building. Temperature and humidity j should increase only until the steam generator has boiled dry! E.05
~
also directs the operator.to determine if' PTS limits ~ have been exce6ded. The reason for this is stated ih Difference 5.' DIFFERENCE #9: DESCRIPTION: E.05 has three additional steps (22, 23 and 24) from the pointwhen neither OTSG is determined to be operable to the point when trickle feeding is established to both OTSGs. ,
,7 EXPLANATION:
l At this point in the scenario both OTSGs have been isolated and once j they have~ boiled dry there will be no cooling to the reactor core. ,RCS- .i temperature and pressure will increase from the time they have' boiled
~
dry to when trickle f.eeding of. the OTSGs ' occur. Step 22, E.05, directs the operators to initiate HPI coolingLif pressure increases to the EMOV setpoint. The TBD states HPI' cooling should be initiated when feedwater. is not-available (at this point in:the scenario it has not been reestablished) and the EMOV setpoint is.. reached in Section'III.C.2.2. Step 23, E.05. ensures the steam breaks'are outside the reactor building, ; before trickle feeding both OTSGs. Step 24, E.05, attempts to establish forced circulation in the RCS before trickle feeding.the OTSGs'in order to provide a more controlled .; method of heat transfer. ' This is advantageous since forced circulation ; with feedwater available guarantees heat removal from the RCS with
-immediate feedback to the operator.
l FC III.D ---_-_---___-__________________-______:--_-__________--___ .iI
~
DIFFERENCE #10: __ DESCRIPTION: Step 2.8 of the TBD directs trickle feeding one or both OTSGs or HPI cooling. Step 25 of E.05 reestablishes heat transf,er to both OTSGs by trickle feeding. E(PLANATION: Step 2.8 of the TBD and Step 25 of E.05 both accomplish the same function. For this scenario E.05 has determined that the breaks are outside the reactor building and it is possible to trickle feed both OTSGs. DIFFERENCE #11: DESCRIPTION: Step 2.9 of the TE" ershasizes the need for the operators to monitor for a loss of subcooleo sargin. This step is not included in E.05 for this scenario. EXPLANATION: Section III.O.29 states that "A prolonged overcooling can result in a loss of subcooled margin, in which the operator would have to take actions". ACTION: Include a step for the operators to monitor for adequate subcooling margin prior to Step 31. IMPLEMENTATION: l Prior To Restart DIFFERENCE #12: DESCRIPTION: Verifying stable plant conditions when trickle feeding both OTSGs is , more detailed in E.05 than in the TBD-. l EXPLANATION: Step 2.9 of the TBD emphasizes the need for the operator to monitor for adequate subcooled margin and SGTRs. SGTRs are monitored for in Step 31 of E.05. However, monitoring for a loss of subcooled margin is not incorporated in the final steps for this scenario in E.05. (See Difference 11.) FC III.D
DIFFERENCE #12: (Continued) _ Steps 29 and 30 of E.05 provide a means of allowing the operator to loop i back to the appropriate sections of E.05 in the event one or both steam .i generators are regained. Step 27 of E.05 directs the operator to i determine if PTS limits have been exceeded. The reason for this is I stated in Difference 5. Securing from HPI cooling"(Step 26) would be ] necessary if HPI cooling was initiated in Step 22. E.05. DIFFERENCE #13: . DESCRIPTION: l E.05 has five additional steps (22, 23, 33, 34 and 36) from the point when neither OTSG is determined to be operable to when trickle feeding I
.is established to one OTSG.
d EXPLANATION- , i Step 22. E.05, is explained in De'scription 9. Step 23. E.05, determines { that at least one of the steam leaks is inside the reactor building, therefore, it is necessary to start RB cooling (Step 33, E.05) to limit , the increase in pressure, temperature'and humidity of the reactor J building to minimize equipment damage. Step 34, E.05, determines if one OTSG has a steam leak outside the reactor building that could be used for heat removal via trickle feeding. Step 36 E.05, attempts to establish forced circulation in the RCS before trickle feeding the OTSGs I 7 in order to provide a more controlled method of heat transfer. This is i advantageous since forced circulation with feedwater available j guarantees heat removal from the RCS with immediate feedback to the operator. DIFFERENCE #13: i DESCRIPTION: Step 2.8 of the TBD establishes trickle feeding to one or both OTSGs or i HPI cooling. Step 37 of E.05 establishes trickle feeding only to one OTSG. l i EXPLANATION: Steps 2.8 of the TBD and Step 37 of E.05 accomplish the same function i for this scenario. The TBD states that a steam generator with a steam line break inside the reactor building should not be trickle fed if the steam release to the reactor building is determined to be inappropriate. Step 37, E.05, establishes heat transfer only to the OTSG with the steam leak outside the reactor building. l FC III.D
, l DIFFERENCE #15: ll DESCRIPTION:
Verifying stable plant conditions.when trickle feeding one OTSG is.more detailed in E.05 than the TBD. ,, EXPLANATMN: The TBD emphasizes the need:for the operator'to monitor;for SFTRs'and loss of SCM when verifying stable. plant conditions (Step 2.9 of!the TBD). These functions are accomplished in Steps 39 and 41 of E'05~ . . , Step 3, E.05, has the operatorssecure~HPI cooling that.may have,been initiated in Step 22. Step.40, E.05 provides a flowpath; to Step- 14;if
]
operability.of the steam generator with the steam leak outside:the' reactor. building is regained. The operator is also directed to D determine if PTS limits have been exceeded for reasons stated in-l Description 5. DIFFERENCE #16:- DESCRIPTION:' Step 2.8 of the TBD establishes trickle feeding t'o one or both_0TSGsior- R HPI cooling. A similar step is not included in E.05 for this: scenario.
' EXPLANATION:
f Step 22, E.05, initiates HPI cooling only if RCS pressure increases lto the EMOV setpoint. Step 23 and 34, E.C5. together determine that both steam breaks are inside the reactor building. . Step 33, E.05, initiates the-four reactor building emergency coolers to minimize the ' degradation of the reactor building environment caused by the' steam leak.. E.05 is inadeauate in that it does not~ direct the operator to initiate
~
1 HPI cooling once it has been verified that both steam breaks are inside l the reactor building. There is nothing to-be gained inl waiting for the RPS to heat up and pressurize to the EMOV setpoint before HPI cooling'is l initiated in this case. The current procedure could have the operators enter CP.104 before HPI' cooling was initiated,, resulting in the operators opening the EMOV. before starting HPI pumps ano leading to a ;
-loss of subcooling margin condition.
ACTION: Insert a step.to initiate HPI cooling before Step 35. IMPLEMENTATION: Prior to Startup q FCII.D -D
DIFFERENCE #17: __ r DESCRIPTION: Verifying stable plant conditions is not incorporated into E.05 for.the scenario that leaves HPI cooling as the only means for removing decay heat. EXPLANATION: Step 2.9 of the TBD emphasizes the need to monitor for loss of SCM and steam generator tube rupture. At this point, both steam gener.ators are isolated with steam breaks inside the reactor building. An actual SGTR would be treated as a LOCA. HPI flow would be controlled to compensate for leakage'through the tube rupture. E.05 directs the~ operators to CP.104'where subcooling margin is monitored. 1 J FC III.D
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____L._.__ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
4 [ COWARISON OF TBD'AND E0P FLONCHARTS TBD Fiaura III.E-1 and E.06'OTSG Tube Ruoture , DIFFERENCE #1: DESCRIPTION: E.06. Steps 2 through:7 correspond to TBD Step 2.1.24for plant'. runback and shutdown. E0P. Steps 3.5 and 6 provide direction for the power reduction'and reactor / turbine shutdown. E.06 Steps 2, 4 and 7. provide direction for the consideration of reactor trip possibility =and utilization of BHST water.by TBD Section III.E.3.2 Plant: Runback and
. Reactor Shutdown.
DIFFERENCE #2: . DESCRIPTION: TBD Step 2'2.1 is designed for continuous' surveillance by looping the-TBD flowchart back to this step until plant conditions, allow DHR-operation. The aspect of continuous surveillance is addressed in E.06' by Step 8.1. The action of E.06 Step 8.0! satisfy the requirements of:TBD ' Steps 2.2'.1 (- and 2.2.2 regarding evaluating' for adequate SCM and if necessary initiating corrective actions if adequate SCM doesn't exist. Additionally, the heirarchy of the EDPs requires a loss of SCM to be addressed.before any lesser priority symptom thus, even if E.06 didn't! specifically state to evaluate SCM,,it would be understood by licensed Operators that this-is necessary. Once the required actions are -taken-for a loss of SCM, the operator is directed to attend to the next higher priority symptom, which for this case is a SGTR. This direction is provided in E.03, Loss of Subcooling, Step 21.0. TBD Section III.E.2.2.2, Loss of Adequate Subcooling Margin, contains a provision that would allow the. operator to not raise level to the -loss of SCM setpoint directly if two HPI pumps are at full flow so'as not to cause inventory control problems in the affected OTSG. - This provision , is optional and is not addressed " 06 because specific guidelines for OTSG level control, AFW flowra' and HPI requirements are set forth as a consideration of ensuring adequate core cooling is provided for- the entire. spectrum of break sizes rather than a consideration of OTSG inventory control. This approach is~ consistent with the concerns and objectives of the TBD SGTR Chapter (III.E), Sections 1.1.1. and 1.1.2. i e FC III.E f -
1
; j
._;j DIFFERENCE'#3: . .L
/~ DESCRIPTION: E.06, Step 9.0 is.part of'the plant runback and-shutdownLactions. .
' discussed in Difference 1. This action step exists'to account:for the:
1 possibility of a. reactor trip that would cause the'* operator.to go from E.06, Step 2.0 to E.06, Step 7.0 and bypass the actionsfof E.06,'Stepj 5.0. DIFFERENCE #4: DESCRIPTION:. ,a TBD Step 2.2.3, 2.2.4 and 2.2'5 evaluate.for centro 11ed 0TSG heat'
. transfer in one or both Steam Generators. In the EOPs.these actions are taken before 'E.06,- SGTR,-is entered 'per the . priority symptom treatment philosophy. Controlled OTSG heat transfer is addressed by: either. E.04,v 1 Loss of Heat Transfer, or E.05 Excessive Heat: Transfer. These EOP
. procedure corresponds.to the referenced. sections.of TBD Steps-2;2.3, 2.2.4 and 2.2.5 except'forethe situation.where there is~an unisolable 1
steam. leak concurrent with an OTSG tube leak. This circumstance.is. addressed.by TBD Section III.E.3.8 and.is provided.fortin E.06E Appendix- !
'A' which is referenced by.E.06 Step 11.4.
DIFFERENCE #5: l DESCRIPTION: I, TBD Step 2.3.1 initiates plant cooldown at either. a normal or emergency cooldown rate limit. These limits and then bases are discussed in TBD Sections III.E.3.3.1 and are implemented in E.06, Step 10.0. E.06, Steps 11.0,12.0 and-13.0 provide direction- specific to performing a-plant cooldown at Rancho Seco. E.06, Step 14.0 provides direction' for minimizing. primary to secondary differential pressure in order to reduce.0TSG tube leakrate as much as possible. This action relates to the recommendation for reducing leakrate in TBD Section III.E.2.2.1. FC'III.E M
]
m
~
DIFFERENCE #6: _ , [ ' DESCRIPTION:. At this pointin.the TBO'(Step.2.3.2)'a decision is.made whether to isolate the affected OTSG or continue cooling with both OTSGs within the .i TRACC (Tube Rupture Alternate Control Criteria) liniits. . E.06,; Step 15 l
. isolates the affected OTSG unless'the. unaffected'0TSG is.not operabl~e.
F In this instance cooldown continues on the affected 0TSG but'still within TRACC limits. With the affected.0TSG isolated,Ethe.TBD allows it, to either fill. due to' the. tube:1eak or to be periodically steamed or fed i j to. accomplish a given objective'(e.g. maintain tube -~to-- shell AT limits).: Again, TRACC limits. must: be complied with. otherwise the OTSG/s must be isolated.. E.06,' Step >16.0 provides1 specific direction-for. fielding / steaming an affected OTSG and correspond,Lin part to-TBD;r Step 2.3.3. Because the option of OTSG isolation.'without reaching a . TRACC limit in TBO, Step 2.3.3 is. not desired, .the. branch from .TBD,. Step 1
- 2.3.3 to TBD, Step 2.4.3'is not applicable.for Rancho Seco. Refer to .J analysis of TBD III.E.2.3.2/3.3.2 Difference.#1 regarding implementation 1 of the radiation TRACC limit. q I
DIFFERENCE #7: DESCRIPTION: TBD Step 2.4.2 allows the use of OTSG draiik, 'if available, in order to either prevent,or delay tho' necessity of isolating the affected OTSGs by reducing the required steaming rate:or to prevent filling.of an! isolated
/.. OTSG. Because Rancho Seco isolates the affected OTSG as soon as-possible (based on RCS temperature) use'of OTSG drains to reduce steaming of the affected OTSGs dcas not apply. 'The use of drains is.
employed as a method of controlling OTSG 1evel so as not to allow the isolated OTSG to fill. This action is taken'in E.06. Step-16.1.2.1. DIFFERENCE #8: 1 l DESCRIPTION: Throughout the cooldown the TBD allows steaming of affected OTSGs , providing a TRACC limit is not reached. Once a TRACC limit is. reached 'l the affected OTSG(s)'aust be isolated. Because of the diversity of the TRACC limits and the fact they apply throughout the cooldown, i implementation of the TBD recommendations results in multiple E0P steps to fully and properly address TRACC limits. ; The Radiation Release TRACC limit itself has multiple considerations, (j all to minimize radiation release. These objections are met in the E0Ps' ' as follows:
-j Step 3.0 directs the operator to reduce power and shutdown-the-
, plant as rapidly as possible while maintaining stable plant' control.
FC III.E l
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, i L _J DIFFERENCE #8:' (Continued) _
(7' -Step 15.0 directs theLoperator-to isolate the OTSG based on an RCS
- ' temperature-designed'to ensure the 0TSG code safeties will not lift' following isolation. JIsolation of the OTSG as soon as possible :
. guarantees that the Radiation TRACC limit will-not be exceeded..
Refer to;the: analysis of TBD III.E.2.3.2/3.3.7 Difference #1 .. regarding TRACC radiation; limits. _ Isolation of. the OTSG atia point below code safety settings ~ ensures the MSSVs do:not lift thereby < . reducing radiation release' as well; as not. challenging the.MSSVs. Once lifted...an MSSV could fail to fully reseat creating an unisolable radiation release path.
- The BWST level TRACC limit is. addressed in E.06, . Step 11.6 where
.the operator.is directed to' isolate the affected OTSG(s) if BHST "j
-level decreases to 32' feet. :This:levelcis designed?toL fulfill the'
. concerns. of-themTBD for BHST depletion' due to either clarge leaks or:
' delays in. establishing,DHR operation.: 4 -
The .SG Overfill TRACC . limit is addressed by 'EOP Step 16.'l .2.1 which' I calls for OTSG~ isolation at'a-level of 951.. ,This complies with the TBD concerns of Section II.E.3.4.3; In addition, action.is specified for attempting to lower OTSG 1evel by use of OTSG-
~ drains. If successful, this will enable the OTSG to be. steamed, even if only periodically. to achieve a desired. objective (e.g.
maintain OTSG tube - to -shell- AT within limits). Having the OTSG available for steaming. allows greater flexibility in controlling the plant during cooldown and will . allow this process to be completed easier. This action is per that addressed in TBD Soction III.E.3.6.3. DIFFERENCE #9: DESCRIPTION: If both OTSGs must be isolated HPI cooling must be emplo'yed for core cooling ~ until DHR is placed in service. ..This possible situation. is addressed in TBD Section III.E.2.4.6 and implemented by E.06 Step 17.0. DIFFERENCE #10: DESCRIPTION: TBD Step 2.4.7 requires action be taken to prevent' lifting.MSSVs on filled colid OTSGs when on HPI cooling. This is part of the Radiation Release TRACC limit addressed in TBD Section III.E.34.1.2. E.06, Steps 18.0 and 19.0 implement this requirements based on whether HPI can be- 4 throttled or not and provide instructions _as recommended by TBD Sections- y III.E.2.4.7 and III.E.3.7. FC III.E-i
?
1
DIFFERENCE #11:-
~
DESCRIPTION:- ] '( ~ TBD Steps 2.5.1 through 2.5.5 examine'RCP status and provide l direction.for cooldown accordingly E.06. Step 20.0 directs the operator to restart RCPs if adequate.SCM. exist's'. Step'20.1.3 directs the operator to maintain natural circulation. cooldown. if' . RCPs cannot be started. .The . specific plant operating procedure-for - a natural circulation cooling-is referenced for guidance. 1 E.06, Step 20.1.1 addresses the circumstances where.HPI cooling is
'in progress and RCPs can.be restarted. Here the: direction is to' )
restart onlyL1 RCPJrather than two (one in each' loop) as'a. . consideration for:RCP. heat input to the RCSJand; PTS. This action. .j' conforms to the recommendation of TBD Section 'III.G.3.9. DIFFERENCE #12: DESCRIPTION:' f l TBD Steps 2.5.6 through 2.5.8 addressL the pressurizer status and provide' > direction based on whether a steam bubble _ exists and, if not,.whether1 one can be formed. These steps are'part of aiseries..thatLdeal with the cooldowr. process to DHR. Their intent is to ensure as normal cooldown-as possible once the special considerations for a'SGTR situation'are-addressed. . E.06 is structured in a similar fashion, however, it considers RV head and RCS loop voids first since if there is 'a problem in either of these areas it should receive prompt attention. :Once the
'RCS is determined to be free of RV head and RCS loop voids,.a pressurizer. bubble can be formed, if necessary. The operator is- ,
directed to plant procedure 8.4 for continuation of cooldown if at least-one OTSG is operable. by. E.06, Step'23.0 within B.4 direction is-pressurized for drawing a pressurizer bubble following a~ circumstance that. fills the pressurizer solid. DIFFERENCE #13: DESCRIPTION: TBD Step 2.5.9 has the operator take actions to enhance idle loop and RV, head cooling so as not to form a void in either of these areas during a natural circulation cooldown. TBD Step 2.5.10 directs actions be taken to mitigate loop and RV head voids should they form.
!, FC III.E L
1 ' '
~ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - _ _ _ _ _ _ _ .
j'
, a .
si, BIFFERENCE #13: (Continued).- , TBD Section III.G. Cooldown j4ethods provides detailed considerations : for-post transient cooldowns.and is referenced by TBD Steps 2.5.9.and' 2.5.10. For RV head void prevention'on plants 1not. equipped'with head vents, such as Rancho Seco. .there is essentially,only one method ( , available; limit cooldown rate. Because a'RV head" void.is only of: j concern during a; natural: circulation cooldown,. the rolated' precautionary ~ .: measures are continued.in the.. appropriate procedure, 8.4. Section 6.0.1 .I Natural Circulation Cooling. . E.06 $tep 23.0; directs the operator;to'
'D this' procedure if OTSG cooling is: being utilized..
d The aspect of idle loop voiding is:addresssd in L.06 at the on'-set.of j OTSG isolation since it is' from this pointLidle kop voiding becomes a -1 concern. TED SectioriIII'G.3.8.1 provides specific recommendations for -
~
idle loop; void prevention. . These recommendations' are reflected in E.06, <> Step 16.0. Should a.RV head. void or RCS loop. void form the TBD provides guidance on >j mitigating their effects :(TBD Sections III.G.3.T and'III.G.3.8).. E.06, i Step 21.0 provides.. direction for minimizing the affects of a head- ) bubble. Again, since Rancho Seco has.no RV head, vent the methods. j! available are somewhat limtted. The-'TBD recommendations for. limiting. : cooldown. rate to within E0*F/HR. while depressurizing with the EMOV are; implemented in E.06 Step 21.0. }! E.06, Step 22.0 addresses corrective actions in the event.an RCS loop void forms. The actions for RCP pump bump and/or hot leg venting are in agreement with those. recommended by TBD Section III.G.3.8.2, Idle Loop , Void Recognition and Elimination. i QlEEERENCE #14: DESCRIPTION: The end point for a SGTR situation in the TBD is to establish. conditions required for DHR operation-and place the-plant on DHR.- Until DHR conditions are established the TB0 flowchart remains in a continuous loop so as to take advantage of any improvement in plant conditions.that. would allow a more normal ' plant cooldown process. 'The DHR transition may have to be made from either OTSG cooling or HPI. cooling. E.06, Step 23.0 provides for the DHR trans) tion through the natural 1 circulation procedurt in B.4 if OTSG cooling is in effect the operator. ] is directed to CP.104 Transient Termination Following an. Assurance That j Leaves the RCS Being Cooled by HPI Cooling. l l t FC III.E ; 1
i cot 1P AR T SON OF TBD AND'EOP FLOWCHARTS -- . ! E.06 SGTR PAGE 3 0F 4 ._ t IDENTIFY g LEAKING - SOTR 0700 INNTIFIE0
- n. j
-.---- -- -- - =-.==- - - -
d
= - .
.-- 1 I
LusJ l E PERFORN PLRNT pag RUNDACK ANO YES REACTOg REACTOR $NUTDONN TRIPPEO a. E I 9 l t REQUCE PONER . l l \ IF P1R LEVEL MAINTAINEO eeeeeeese i plee* eDIFF 1 e l eoeeeeeet j i
, vEs j PfaFoan PLANT SUPPoef RCTIONG e
41E3 Poust ' fp!P TURsINE AND DERCTOR m -- . .. .. . )
,, .g-- - - - _ . _ = _
PERFORM E.88 IF NOY 00NE
)
o _ o
. R
~ "pCn""" CD TO IS SCf1 PERF0nn nCTIDMs E.88 see****ee AGEeunTE eDIFF 2 e MINTR!NED FOR L0ss l-eeeeeeeee DF SCM !
l
- 111 m YES ES I g
9 r PERFORM PLANT SUPPORT RCT!DNS * *
- ggpp IF NOT DONE eteeeesse
_ _ . . -__ z____., - - _ eeeeeeee, eDIFF 4e teeeeeeee
. EaEn - f Tang ACTIONG gg e TO RESTORE gg CONTROLLEO CONit0LLEO pain to gEc0Monav CONTROLLED No MEnf TARN 6FEa NEAT TRRNSFER NEAT TRMNSFER
[M $T (ERST 1 MA!NTRINEO RESTORE 0 ONE OTSO u c.
.I t t . c. D 3. R YES gg u ---- i R]
B 0 ....: nEP E
r C0t1P ARISDN OF: TBD AND E0P' FLOWCHARTS . . E.08 SGTR' PAGE 2 0F 9 E0P TBD
- l. o PREPARE FOR C00LDbWN ,
- r. .1l
,, COOLDOWN RNO DEPRESSURIZE INITIRTE RCS SELOW M88V COOLDOWN _.p.
g s.a. _ tt
,y,,,, e.......e errC
- D.I.F.F.5..e.
ta i DYPRS$ SFRS to DEPRESIL;RIZE RCS is o o . ISOLRTE RFFECTED OTSC I *! O F F S'
********e
/
/o s.a d
ISOLRTE SC C00LDOWN FEED STERN FtLL OF te , ON TWO OTSGs RS REG' O MAINTRIN OTSC DESIRED OR 6 0W LIMITS TO FILL
- 2. : t. 2 Pta!00tc a FEt0/9fEAM 00E6 NOT APPLY ,
TO ARNCHO SECO
----_______-___________._e_.___---.________---__--___
eee.e.e
. .D.I.F.F.
..7.e
'8
g l ISOLRTE l CRM C.D. RFFECTED CONI ON SCs USE OF DRRINS OR M0FT W/0 REACHING AFFECTED DESIRED SG % RLLOW W ~ W ,. SS
. . . . .i OPERATE DARINS OR RFFECTED SCa
& REDUCE STERMING
. 3.5 e
h F' G A
r l- . .j COMPARISON OF TBD JRND EOP FLOWCHARTS _ . E.06 SGTR , . or ,- g EOP ********* TBD
*0IFF8
- 3 "l'---- ---------.. Q '- --
REDUCE POWER
--------- T) e.9.sl AND SHUTDOWN THE a. 9. t\
LPLANT QUICKLY /
/ ISULATE
'! MAINTAINING-WHILE . / CAN CD '\ AFFECTED OR,l iSTABLE PLANT j CONT. CH SGs \ go lMOST !
'AFFECTED-
! CONTROL W/0 REACHING 2.4.2 I _.]' / iSG AND t
.'\g TRACC / i ALLOW
,/ TO FILL rJ >
'\a.4/
\ -3.6 ,
ES PJ 11 E
$INITIATERCS CUOLDGWN BY
'! STERMING BOTH l OTSG's F rs '
, .9. )
/CAN CD\.
\
[ CONT. ON SC's 'N go AND DRAIN W/0 15 REACHING ,/ 7 N gTRACC ,/ ) ISOLATE , AFFECTED N 3,9 OTSC YES ; E rs G qJ . 9 MAINTAIN x la.9.sl OTSG f ISOLATE LIMITS
/ _CAN CD \ REMAINING
(,/ OH ONE SG \g' CONTINUE W/0 W SG AND
\ REACHING ., jALLOW IT
\ TRACC -
- TO FILL rJ \ / i 43, '
l 3.6 I. E D
s L' COMPARISON OF TBD AND EOP FLOWCHARTS - -
.gg E.08 SGTR 3,
C
*i
.2.yp;*: . 0 -
g9 !? lahtj i
.0TH IM! fl Aft '. ' I l a
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- e. tr P* s 480 es mg.TMT ggg g
ve met TWO CalTERIA
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= a .URI25A a== u.,=0 n,L CONTSOL
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IAIl.i.G
.___ _ _..___________ ____ _ _ _ _ _ _ _ ..____- "l ' ' _' _
n a s ,,,i,,, unegion s =, ya et0 a0an . 3 8 aNO ac- - 0.L.o.ut.y [ e T .6 g agg
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. O.IY..[.f.$1
_______________ _ - = - - e3 e3 8 tiTNt* PLANT OTSC " c0 to c0Nett:0 , ] g*g e.7 mn s.N Ns0 OPERAKE 1 OP." 1 m..yn..:*: -
- e. . ..
m GO TO CP.139 IHlf! Aft 08811 OPttat t Ded til.C ,
- A _ _ _ __ _ -
g
Jis i COMPARISON OF TBD'AND'EOPF 'LOHCHARTS TBD Fiaure'III.F-2 and E.07 Inadeauate Core Coolina , DIFFERENCE #1: DESCRIPTION: Step 2.2 of the'TBD requires the initiation of HPI', LPI and verify CFT. isolation valve status. : Step 1 of- E.07-initiates HPI and LPI. but does" not verify the.CFT valve-status. EXPLANATION:'
- The. TBD gives direction to verify .CFT 'statusfinnediately after- '
attempting to establish OTSG heat. transfer. The.CFT discharge valves are required to be open to during operation. - Postponing the CFT ' verification in the EOPs allows:the operators .to take actions to establish heat transfer sooner and it places verification!of CFT level' decreases at a' point where the CFTs.are more likely to be discharging into the core. DIFFERENCE #2:
' DESCRIPTION:
E.07 Steps 2 and 3 are more detailed than Step 2.3 of therTBD. EXPLANATION: TBD actions for Step 2.3 include ' raising OTSG . levels as high as possible in the-0TSG and lowering OTSG pressure untili secondary Tsat is about 100* below primary Tsat. The E0P steps similarly raise OTSG 1evel to-381" and lower OTSG pressure to decrease Tsat 90*-110' below RCS Tsat. DIFFERENCE #3: DESCRIPTION: Step 6 of E.07 directs the operator to' establish manual AFH control. This step is not included in the TBD.. EXPLANATION: Manual control of AFH is. required to prevent EFIC from automatically lowering and controlling OTSG 1evels at 27.5" when one RCP per loop is. started in the following step: FC III.F x - _ _ _ _ _ - - _ _ __ -
a:
\' _
DIFFERENCE #4:- _
- DESCRIPTION:
Step 2.5 of the TBD takes action to open the'High Point Vents (HPVs).' Step 2.6'of the TBD takes action to depressurize the OTSG to achieve a 1 100*F delta T between secondary Tsat and primary .Tsat. E.07 requires the operators to first depressurize the OTSGs and then'open the HPVs in Steps 8 and 9 respectively. EXPLANATION:- This difference is of.no consequence since no new actions are"taken in Step 8, E.07, that were not already taken in . Steps 2 and 3:of E.07a DIFFERENCE #5:- DESCRIPTION: The.TBD and E.07 differ diagrammatically at this point. Additionally, Step 11 of E.07 has the operator remain in the present mode until saturated conditions are established in the RCS. _This step does not' appear in the TBD. EXPLANATION: Step 2.7 of the TBD decides if. primary to secondary heat transfer' has -
.. been established. If the primary to secondary. heat transfer has been established the plant should establish a saturated cooldown mode'with the steam generator. .If not the-TB0 states it will be_necessary to continue with HPI cooling. . The TBD is in error at this point since.true, HPI cooling (HPI initiated with' flow;through the EMOV) isinot in progress and the TBD does not. recommend opening the EMOV until'the'RCS has reached Region 4. Additionally Step 2.7 requires the ~ operator to. ;
continually monitor for conditions worsening such that thelRCS enters i Region 4. i Once in Region 3 one of two conditions must occur. Conditions will- 'i either worsen such that:the RCS enters Region 4, or'the HPI will refill-. ; the RCS and saturated conditions will be' reestablished. Step 10 E.07, j has the operator' continually monitor RCS parameters for entry into- l Region 4 and directs- the operator to _ Step 14 if this occurs. Otherwise, 1 Step ll,'E.07, directs the operators to-continue in the present mode -j (HPI at maximum flow and high' point vents open) until the- RCS~ returns to - 1 saturated conditions. Once saturated conditions have been established. Step 12 E.07,' determines if primary to secondary heat transfer exists.: i If so, Step 13. E.07, has the operator maintain RCS pressure 25-50.psig
> OTSG pressure in an effort to regain subcooled margin. Once subcooled margin exists or RCS decreases 'to 140 psig, the operator is-directed to ;
CP.103. If primary to secondary heat transfer cannot be established the ; operator is directed to CP.104 that initiates a'cooldown using HPI ; cooling. D FC III.F i
o. DIFFERENCE #6 - DESCRIPTION: l As part of the actions in Step 2.8 of thejTBD.the-operator is' directed
.to open the HPVs and the EMOV. Step 2.9;of the-TBD directs'the operator to further depressurize the OTSGs. .The steps are.p'erformed in reverse order in E.07. by steps 15'and116.
EXPLANATION: The TBD states in Section III.F.3.5, "TheiRCS should be depres.surized as; quickly as possible to achieve CF and LPIL cooling. To achieve quick RCS: depressurization, the operating SG(s) should be depressurized as quickly and as far asipossible." Later, the TBD states :"All possible RCS' valves should be opened if not already opened." The intent of the TBD: is therefore met. DIFFERENCE #7: DESCRIPTION: Step 2.10 of the TBD requires.the operator continue with the actions ofJ 2.8 and 2.9 until saturated condition exist, then proceeds to establishing long term cooling.: ' Step 17, .E.07 differs -from Step R2.10 of the TBD by the fcilowing: 1) It directs the operator to decrease running RCPs to'one in each loop. 2).It directs.the operator.to-
- continue with the procedure whether or not'the RCS is saturated.
EXPLANATION: l Securing one RCP per loop is advisable;in order to minimize the damage 1 to the RCP and the heat rejected to the RCS. . It.is necessary for the operator to continue with E.07 to take actions that will be needed to 1 support long tens cooling. :The actions .taken in the following steps l will not alter the present mode of cooling. ! DIFFERENCE #8: DESCRIPTION: i E.07 provides greater detail in establishing long term cooling than does.' the TBO. , EXPLANATION: Continue long term cooling, Step 2.11 of the TBD, is' described as transferring LPI suction to the Reactor Building sump and lining up the , Decay Heat Removal System if possible. It a' Iso warns of the' possibility! 4
~
of exceptionally high radiation levels which may be present in the . Reactor Building and suggests- that. appropriate. radiation precautions be- ' invoked. E.07 will establish either LPL cooling or LPI-HPI piggyback cooling, depending upon LPI. flow conditions and .the BHST level. If LPI , cooling is providing adequate core. cooling.(LPI flow greater than FC III.F I I s' .
- .i DIFFERENCE #8:- (Continued) 1000:gpm for greater than 20 minutes) then St'ep 19.has.the' operator ,1 secure HPI cooling and core flood tanks. This mode'of. cooling is J i
continued until the BHST lo-lo level is reached at which time Stcp 20 transfers.LPI suction to the Reactor Building sump and Step 21 secures j the remaining RCPs. ;
-For conditions where the lo-lo level.in the BHST is reached before.LPIi ,
cooling has been determined to be; adequate. Step 19 directs the operator = to a cooldown mode via LPI-HPI piggyback cooling. Step 23 aligns,the j systems for piggyback operation. Steps 24 and 25 continue the.RCS i cooldown either by OTSG or HPI; cooling. Once .RCS pressure is ' below' 250 : :l psig Step 26 places one LPI system in the decay heat removal, mode if l both Decay Heat Systems are operable. :When RCS pressure decreases to.- 150'psig, Step 27 secures from the LPI-HPI piggyback mode of cooling and- 1 secures the remaining.RCPs if both Decay. Heat Systems are. operable. J Caution statements are presented prior tb steps-20 and 23 regarding'.the ; evaluation for potential release of radioactive gas or liquid from any . I previously isolated system and ~the evacuation of. the Auxiliary Building basement. l , y i y l
> FC III.F
COMPRRISON OF: EOP.: AND?TBD;: FLOWCHARTS. . E.0=7!INRDEQURTE CORE COOLING PRGE.1 0F:.3. 1 i EOP -TBD ,i f 2.1-l FROM GUIDELINE g IDENTIf!CRTION. t OF ICC- a i 3
- _ l 1 ,,
. ,i -j d
********* 2. 2 l l INITIRTE- I
*DIFFis* ~INITIRTE.
HPI/LPI ********* HPI/LPI/CFT1 i
*********- 2.3l' j INCRERSE OTSG
$U.I.F,F,2,g' TRKE:RCTIONS TO LEVEL TO 381" ,
INCRERSE PRIMARY TO SECONDARY' i g HERT TRANSFER , LOWER OTSG 1 PRESSURE '! 4 ir VERIFY CFT ISOL VALVES .1 OPEN 1
'r u I
5 TAKE RCTION BRSED ON GPDS RCS.IS REGION . SRTURATED IN WHICH 2' 'l ICC OISPLAY C/D- REGION OF.ICC 1 1 I W/SGs FIGURE. ) III,p_I -l REGION 2 ! l REGION REGION REGION' _5 1 3 9-REGIDH EGION f GO TO O 'C CP 103 ; R B i 1
COMPARISON OF E0P AND TBD FLOWCHARTS - - E.07. INADEQUATE CORE COOLING PAGE 2 0F 3 A c EsTAetzsw *0!FF 3
- Ru Uu. APu ........
CONTROL
.. . ,._._s-._._.-__--____--_. . - _ . . - - _ - -
START ONE 4 2.s l TAKE MC10*I 3 i RCP PER LOOP ........ ACTIONS 70 INCMASE HEAT TRANSFER FROM Ru CORE TO RC S < r LOWER 0T88 ir PRESSURE 2.6lTAKE ACTIONS 70 FURTHER INCREASE PR1RART/9ECONDART
' HEAT TRANSFER OPEN ALL NPY VALVES o *0!FF 5
- i,
........ x,x INCORE REston RIMARY TEs 0 SECONDAR ##
T/Ce INCMASg g HT. TRANSFER TO RECION gy ESTAB.
"8 TE8 ir 18 /
RCS ETijRNED TO ,, SATJRATION
\ TEs ir 1 o RIMAN ESTABLISH YEs TO SECONDARY NO CO TO HP! COOLING MAT CP.194 TRANSFER 13 <r
- NAINTAIN RCS PRESS.
> OTGC o
SATURATED C/D C0 TO WITH SGe CP.193 l_______.___________________________.._______ . _ .~
C0t1PARISON OF E0P'RNO TSO' FLOWCHARTS . .a E.07 INROEQURTE CORE COOLING Pact S 0, S El T._S_O - B D ST'4R1 ALL ACP . ******** *
- RectoM P0ue go,1gf,8,$ - ACT!DNS TD ftRN!MI2E I
15 PERT TRANSFER FROM Rn CORE TO RC PURTNER LOWER 4 0T0C PRESOURE 2.9 I TAKE ACTIONS 70 gg f' MANIM!2E PRIMARY . TO SECONDARY HEAT DEPRESSURIZE TRANSFER THE RCS 11 MP DECREASE
$*OIFF h* Cs RgTUR agTURNgo TO .TO ONE RCP ******** "
j TO SATURATION PER LOOP SATURATION
.__y__^T ------ ~ ~~~~~ -~~~~~~~~ ~~~
"~~~~~~~
MAINTAIN OTSG 2. I il
, LEVEL ******je$
p, CONTINUE
- e. ,******
N TERM COOLINC 19.2 LPI ) 1839 CPM > M8 l 29 MIN 19.1 i no LO-LO LEVEL IN SWST , I I ES 19.2 ' ALICM FOR ISOLATE CFTs PICCYSACK SECURE MPI OPERATION COOLfMC 1 i 29 25 gg l CAN RCS CONTINUE. HP! SWST l TEMP SE No "8
" RT LO-LO CONTPOLLEO g LEVEL OTSCs ;
,,,,t,,L, V88 i 24 "8 '
CONTINUE l C00LOOWN WITN ' OTSCs UNTIL DNS AVAILISLE L 28 4 29 PLACE I LP! TRANSFER LPI TRAIN IN OMS SUCTION TO RS MODE
- EnERCENCY SUMP 21 STOP ALL RCPs RCS(ISS "8 PSIC YES ESTASLISM CONTINUE LP!
LP!/DNR , COOL!kC-M3CB _ _ _ _ . _ ---
TBD TO E0P COMPARISON 0 (0_0LDOWN PROCDURES The SMUD E0P Cooldown Procedures (CP's) have not been revised to implement the TBD. The CP's originated from the ATOG cooldown procedures. The ATOG CP's have been modified to be correct for the present plant configuration. The attached studies have been completed to verify the bases of the E0P CP's. First, exit conditions for all the E0P's were compared to the entrance conditions of each CP. This verifies that there is a smocth and accurate transition between the E0P's (based on the TBD) and the CP's (based on ATOG). All E0P exit points reference an appropriate cooldown procedure. Second, each E0P CP was compared to its corresponding AT0G CP. For each CP the steps that do not correspond between the E0P's and AT0G were circled and numbered. The differences were then dicussed. The differences found were either implementations of the TBD or are enhancements of ATOG made to provide further clarification or improved plant operation.
, CP-1
I COMPARISON OF E0P EXIT CONDITIONS ( TO CP ENTRANCE CONDITIONS f Emergency Operating Cooldown Procedure Procedure E0P/ STEP EXIT CONDITIONS CP NO. ENTRY CONDITIONS E.03/9.0 Core Flood Tanks are emptying 101 A large LOCA has occurred and which indicates a major LOCA. the Core Flood Tanks 'are emptying. E.03/10.0 RCS Cooldown rate >100"F/hr 104 A transient has occurred that RCS is saturated. -Core cooling has left the RCS being cooled is by HPI/ break flow, by HPI cooling. The RCS may Recovery of OTSG cooling is be saturated, unnecessary. E.03/11.0 RCS is saturated. HPI is 103 A transient has occurred that maintaining RCS inventory, has left the RCS saturated Core cooling is being with OTSGs removing heat. provided by OTSGs. OTSGs are operable. RCS may be saturated. E.04/6.0 No heat transfer to either 104 A transient has occurred that OTSG. Natural circulation has left the RCS being cooled , doesn't exist and can't be by HPI cooling. The RCS may started. Core must be cooled be saturated, by HPI cooling. E.04/8.0 Core Flood Tanks are emptying 101 A large LOCA has occurred and which indicates a major LOCA. the Core Flood Tanks are l P -+ S heat transfer lost and emptying. I cannot be required. E.04/17.0 RCS has adequate SCM. Heat 105 A transient has occurred that transfer with OTSGs has been may require pressurizer reestablished and is being recovery solid plant cooldown 3 controlled. with OTSGs removing heat. The RCS is subcooled. There may or may not be a bubble in 3 the pressurizer. I E.04/18.0 RCS is saturated. Small break 103 A transient has occurred that indicated. Cooldown with the has left the RCS saturated OTSG can be performed. HPI with OTSGs removing heat. maintains RCS inventory. OTSGs are operable. RCS may be saturated. CP-2
'l l
COMPARISON OF E0P EXIT CONDITIONS , l' TO CP ENTRANCE CONDITIONS, 1
'l Emergency Operating Cooldown Procedure Procedure E0P/ STEP EXIT CONDITIONS CP NO. ENTRY CONDITIONS '1
( E.05/21.0 RCS is'subcooled with press. 102' Normal'cooldown. RCS is j and temp stable. Only one subcooled. One or both OTSGs: j OTSG is operable and is are operable. RCPs may or-steaming to the condenser may not be operable. or atmoshpere. Cooldown with a dry 0TSGLis permitted. E.05/32.0 RCS is subcooled HPI cooling 305 A transient has occurred that secured. RCS is being may require pressurizer cooled by trickle feeding recovery solid plant cooldown. both OTSGs with AFW. with OTSGs removing heat. The RCS is subcooled. There may or'may not be a bubble in j the presurizer. ' E.05/35.0 RCS is being cooled by HPI 104 A transient has occurred that cooling. At least one and has'left the RCS being cooled possibly both OTSGs have by HPI cooling. The RCS may steam line breaks in the RB. be saturated. Neither can be fed unless one is determined to be outside. E.05/43.0 RCS is being cooled by trickle 102 Normal cooldown. RCS is feeding one OTSG which has a subcooled. One or both OTSGs steam line break outside RB. are operable. RCPs may or Other OTSG has break inside may not be operable. RB and cannot be fed. Cooldown with a dry OTSG is permitted. E.06/24.0 Both OTSGs are inoperable. 104 A transient has occured that RCS is being cooled by HPI has left the RCS being cooled i cooling. by HPI cooling. The.RCS may be saturated.
]
. I CP-3 i
I
i 1
'ATOG TO E0P COMPARISON' (C - )
CP.101 i DIFFERENCE 1 - ATOG step 1.2- - l i This step is not included in the 'EOP's. CP.101 is in affect only.if a large LOCA l has occurred. The rate of depletion of the BWST for a'large break.LOCA would greatly exceed the rate of makeup to the BWST that could be achieved. In this case..it-will be necessary to establish recirculation from the R.B. sump as the BWSTsis' .) depleted. Direction to makeup to the BWSt is given.in the Annunicator Procedure;for the.BWST' low level alarm. It' directs the operator to makeup to the BWST' upon the permission i of the Shift Supervisor or Assisant Shift Supervisor. Because the additional borated water that could be made up would not be significant relative to that being injected, this step'was.omitted from the E0P's. Although it requires establishment of a - R.B. recire flowpath sooner it also allows the operators' to deal with the LOCA . and makeup to the BWST with normal operating procedures when' time permits. DIFFERENCE 2 - E0P steps 1.1 and 1.2: These steps do not exist in AT0GLs They were added to the E0P's to' instruct the operators to leave the CBS and emergency coolers running following a LOCA in order to reduce.the iodine levels of the R.B> and to thus limit offsite releases. This step requires no additional operator action. Therefore, its affect is an enhancement 6 over the AT0G procedure. 4 DIFFERENCE 3 - E0P step 2.0: Determining if a CFT line break has occurred and taking actions to secure LPI flow to that' loop if a break is observed is not addressed in ATOG.- Adequate core cooling will occur with a CFT line break if LPI flow is available to both injection nozzles (reference TBD IV.8). ACTION: The steps, which check for CFT line breaks, will be removed from CP.101 and replaced with instructions to ensure LPI is available to both injection nozzles. IMPLEMENTATION: 1 Pre-startup. 1 DIFFERENCE 4 - E0P step 3.0: Isolating the CFT's 1s not performed in the ATOG CP.101. This step is included-in the E0P's as a TBD enhancement over the ATOG procedure. TBD IV.B section 5.1 i recommends that the CFT's isolation valves should be closed so that the CFT's do not interfere with RCS depressurization by introducing nitrogen into the RCS. ! In addition, the TBD uses the criteria of LPI > 1,000 gpm in each line to isolate the CFT's (reference TBD IV.B.5.1). , CP-4' m% __--m___-a___.______ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ - _
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i ATOG TO E0P COMPARISON k CP.101 I i DIFFERENCE 5 - ATOG step 2.A. E0P step 4.1: { 1 For no heat transfer to the OTSG's when RCS pressure stabilizes above LPI operating 1 pressures ATOG branches to CP.103, while the E0P's branch to CP.103 step 3. The { operator should be directed to step 3. Step 2, "CFT's emptying go to CP.101", , i would create a branching loop and would not allow the operators to go to step 3 j where the steps for RCS cooldown begin. The E0P clarification resolves this branching , discrepancy and therefore is an improvement over the AT0G procedure. ' DIFFERENCE 6 - ATOG step 4.0. E0P steps 6.0 and 7.0: The placement of the steps to terminate HPI flow if adequate LPI cooling exists differs between ATOG and the E0P's. The E0P's were revised and incorporate this step earlier in the procedure to allow termination of HPI, prior to establishing piggy-back mode cooling, if LPI flow is adequate. The AT0G progression, however, directed the operator to establish piggy-back cooling prior to determining if HPI was still necessary. The E0P, order potentially saves operator time and burden in the event that LPI flow is adequate and HPI piggy-back cooling is not required. (TBD IV.B.2.A.5.2 allows HPI termination if LPI flow > 1,000 gpm per loop for
> 20 minutes).
DIFFERENCE 7 - E0P step 8.1: f This step does not appear in ATOG. The E0P's were revised to include this step to prevent suctions from being switched due to a BWST level transmitter failure. This is consistent with the TBD direction to check for othe % ources of water loss upon receipt of BWST low low alarm. Reference TBD IV.F 3.5. Checking sump instrumen-tation ensures there will be a water source when suction is switched from the BWST to the sump. DIFFERENCE 8 - E0P step 8.2: l The E0P's were revised to include this step; this additional verification to check HPI suction does check HPI suction does not appear in AT0G. This is a precautionary measure to address the scenario of piggy-back mode. This step ensures suction will be provided to the HPI pumps when the BWST is isolated. l DIFFERENCE 9 - E0P note preceeding step 9: i This note is additional precautionary information to ensure consideration of HPI {
, pumps if a piggy-back mode cooling exists. It is an enhancement of the ATOG procedure. !
CP-5 1
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L ] a 1 i ATOG TO E0P COMPARISON j CP.101 { DIFFERENCE 10 - ATOG step 4.4, E0P step 9: ATOG references a limit on LPI flow of 3,750 gpm, while the E0P limits LPI flow l to 3,000 gpm. The LPI limit of 3,750 gpm is the maximum flow that is allowed to l each DHR cooler. LPI pump runout occurs at 3,000 gpm when suction is being taken from the R.B. sump (reference A.8 L&P's 3.10.6 and 3.12.2). The E0P limit considers LPI pump. runout and cooler operation. It is therefore more conservative than AT0G. i DIFFERENCE 11 - ATOG step 4.1: I Direction to restore normal seal injection is not included in the E0P's. Requiring j normal MU to establish RCS seal injection is an operator burden that could result i in operator attention being distracted from more significant matters. At this stage in CP.101 it is likely that the BWST is depleted or will soon be depleted. This would require the operators to take suction from the makeup tank for seal injection. In addition, because there is no letdown available the operators will be required to continually makeup to the makeup tank from the DRCST and the BA q Addition System. j At the point where ATOG instructs the operator to establish seal injection LPI flow has been > 1,000 gpm for > 20 minutes. The RCS pressure and temperature is ) l significantly less than normal temperature and pressure. It is very unlikely that ' damage to the seals would occur from the postponement of seal injection. The E0P's therefore do not dictate that seal injection be established at this point, but l rather allow the operator to proceed with more pertinent actions and establish { seal injection when time permits. i DIFFERENCE 12 - ATOG step 5.1.A. E0P step 10.1: 1 The step " Depress manual to clear the EFIC trip signals", is not explicitly included ' in the E0P's; rather it is understood that EFIC trip signals will have to be cleared in order to stop the AFW pumps. This AT0G step is therefore part of E0P step'10.1 "stop the AFW pumps". DIFFERENCE 13 - ATOG step 5.1.C. E0P step 10.1: The list of isolation valves differs between the ATOG and the E0P's. Startup and MFW regulating valves (FV-20575. FV-20576, FV-20525 and FV-20526) in ATOG were replaced by MFW stop valves (FV-20529 and FV-20530) in the E0P's. This was due to the EFIC modifications. The new valve isolation arrangement still provides the same degree of isolation for MFW, l CP-6 l e l
1 ATOG TO E0P COMPARISON CP.101 . Additional AFW valve isolations were added to the E0P's (FV-20531, FV-20532. HV-20581, and HV-20582) as a result of the EFIC mods. THs creates a higher degree of isolation for the AFW System. Finally, the OTSG blowdown valve HV-20611 (blowdown isolation at the condenser) exists in the E0P's, in addition to the individual blowdown isolation valves, to provide double valve isolation, i DIFFERENCE 14 - E0P step 14: , This step regarding R.B. hydrogen was added to the E0P's. It does not exist in AT0G. This step ensures adequate hydrogen mixing in the event that Reactor Building upperdome air circulators are not in-service. DIFFERENCE 15 - ATOG step 5.2: Step 5.2 of ATOG requires verification of R.B. isolation. This is performed in step 1 of the E0P CP.; " Verify SFAS initiation". In step 1 the operators verify that SFAS has closed the R.B. isolation and if that action did not automatically occur the operators would manually isolate the R.B. at that point. The ATOG step is' redundant with the direction given in step 1. DIFFERENCE 16 - ATOG step 6.1: The steps described in the ATOG step 6.1, " Shutdown turbine, feedwater and steam systems" are also included in the plant shutdown procedure OP B.4. This step is redundant with step 12.4, which states " complete secondary plant shutdown per B.4", and is therefore not included in the E0P's. I DIFFERENCE 17 - ATOG step 6.5.D, E0P step 12.6: l i ATOG describes starting 3 R.B. coolers with maximum NSCW. The E0P's describe starting 4 R.B. with maximum NSCW and NSRW, The E0P's add conservatism by starting the 4th R.B. cooler and provide additional necessary information to also start NSRW to cool the NSCW. , DIFFERENCE 18 - ATOG step 6.5.B. E0P step 12.6.2: I The E0P's provide clarification of the ATOG high temperature limit. The E0P's also require the coolers to be started if temperature indication is lost to provide additional conservatism. CP-7
) 1 ATOG TO-E0P COMPARISON
( CP.101 DIFFERENCE 19 - ATOG ster 6.9,EOP step 12.10: The ATOG procedure provides specific guidance on operation of hydrogen blowers. SMUD is installing hydrogen recombiners to reduce the. hydrogen concentration ir:- the Reactor Building. ~ The E0P's will provide guidance specific to;the recombiners.. It will not be necessa'ry to stop the recombiners on high radiation levels because. I they will be self-contained in the R.B. and will have no R.B. penetrations. The' ' CP's will be revised due to this hardware change. and hydrogen recombiner guidance-will satisfy the intent of ATOG step-0.9. . ACTION: Revise CP.101.to reflect installation of' hydrogen recombiners. 4 l
-IMPLEMENTATION:
Pre-startup. DIFFERENCE 20 - AT0G step 17.2.B.'EOP step 13.2.2: 1 The E0P step provides guidance over tha't'in ATOG.to remove the clearance from and rack-in breakers 2A171 and 2B107 prior to opening HV-20001 and HV-20002.'- This
'information is necessary since the breakers are normally. cleared and racked!out j for Appendix R considerations.
DIFFERENCE'21 - ATOG step 7.2.D: This step is not included in the E0P's. It is understood that the alternate method of dilution flow will be performed if the conditions'for the' desired method cannot be satisfied. DIFFERENCE 22 - E0P step 13.2.4: This step was added to the ATOG material in the E0Ps. The step-was added as a result of equipment qualification studies. It requires HV-20003 to oe fully opened' before its controls are submerged and it becomes inoperable. CP-8
swNP.20007 2(s.s31 4ASCOCK & WILCCX UTILITY PQwtR G ENER AfloN Olvt$10N NUMSER t i TECHNICAL. DOCUMENT 74-1127469-00 l 1 CP-101 A LARGE LOCA HAS OCCURRED AND THE CORE FLOOD TANK IS EMPTYING D I5"E 1.0 VERIFY SFAS ANDhfAKEUP TO BWS Q f
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1.1 Check SFAS actuation per Section II Step 9.0 and 10.0. 1.2 WNEN BWST level reaches 10 ft. level, THEN begin makeup to BWST with borated water. O /S~f
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2.0 IF THE RCS PRESSURE STABILIZES ABOVE THE MAXIMUM OPERATING PRESSURE FOR LPI, THEN:
.a. I_F,there is heat transfer to OTSGs THEN go to CP 103.
- b. IF there is MO heat trans fer to OTSGs THEN go to CP-104
, 3.0 CONTROL HPI. ,
j 3.1 See Specific Rule 1. v
. . 3.2 WREN the BWST low level alarms, THEN open valve HV-26007 (low pressure Injection to Pump P-238A) and HV-26008 (low pressure injection to Pump P-2385).
3.3 WREN the BWST low low level alarms' THEN; ,
- s. Open reactor building emergency sump valves to the LPI suction headers, within 4 minutes of recipt of alarm.
- b. Close valves SFV-25003 and SFV-25004 to isolate the BWST.
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SA8 COCK & WIL'CQ1 I UTILITY POWER GENERAflON DIVISION NUMSER , j TECHNICAL DOCUMENT 74-1127469-01 l 4.4 IF LPI high flow alarm is received , THEN throttle valver - SFV-26039 (Loop A) and 'SFV-26040 (Loop B) to ' limit flow to 3750 spa to prevent pump runout. C /M"f / 0 O/ff & 4.0 ' WHEN ' LPI PLOW HAS BEEN GREATER THAN 1000 GPM IN EACH INJECTION LI ;
' FOR AT LEAST 20 MINUTES, THEN STOP HPI FLOW.
.1 Stop HPI system and . establish normal MD. to maintain sesi
'niection.
D/ff . b
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5.0 ISOLATE MAJOR REACTOR BUILDING LINE PENETRATIONS. 5.1 JF, F core cooling is being maintained by the HPI/LPI/CFT (01) systens , THEN Depress Manual switches to clear the EFIC trip si Q. D/#'# ' , ( b. stop the AFW. pumps .f g 8 1 AND v' c. close the following valves to isolate the OTSGs.' 1 ' i c
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\ CP-10 Section.CP-101
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SWNP.20007 2(s.331 1 4AsCOCK &' WILCQK UflLifY PowtR GENERAflON DIVillCN NUmstR TECHNICAL DOCUMENT 74-1127469-00
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y l OTSG A OTSG B- Control Panel Valve Name' l O/F"f FV-20576 'Startup PW Valve O 1 CFV-20575 FV-20525 FV-20526 MFW Valve' . l FV-20529 FV-20530 nrw stop vatve FV-20527 FV-20528 AFW Bypass Valve SFV-20577 SFV-20578 AFW Control Valve PV-20561 PV-20564 .HIRI Turbine Bypass Valve . _j H1RI Turbine Bypess Vs] PV-20563 PV-20566 PV-20571A PV-20562A HIRI Atmoephere Dump Va
. PV-20571B PV-20562B H1RI Atmosphere Dump Valve PV-20571C PV-20562C H1RI Actsosphere Dump Valve HV-20570 HV-20571 H2PSB Main Steam'Line Trap HV-35070 HV-35069 lI2PSB Main Steam Line Trap HV-20569 HV-20596 H2SPB-Main Steam to Aux. FWP HV-20597 HV-20598 H2PSB Main Steam to Reheaters HV-20565 HV-20560 H2PSB Main Steam to Aux. Stee
.HV-208587 HV-20588 H2PSB Main Steam Sample HV-32243 H2PSB Main Steam to Pegging S'ess c
HV-20609 HV-20610 H2PSB OTSG Blowdown 5.2 WHEN a. RB pressure increases above 4 psig.. g . - .
- b. RC pressure decreases below 1600 peig. .
0,g,-
- c. RB radiation increases above the high radiation limit.
/W
_THEN, ensure that the R3 isolation valves are closed. 6.0 ESTABLISH LONG-TERM COOLING. 6.1 Shut down turbine, feedwater, and steam systems when ti D/M oersits. U 6.2 Close EMOV. JF, EMOV does not close THEN close EMOV block 'l valve (HV-21505). 9 6.3 Begin secondary p1' ant shutdown per OP 5.4. 6.4 Continue LPI cooling until further instructions are given. ( ' A \ j) Section CP-101 CP-11 DATE: P AGE 44 1
, 1.0-8-62
BWNP 20007.20.s3l .. , 8AscOCK & WitCo1 UTILITY POWER G E NE R ATlo N DlVl$loN NUM$tR g TECHNICAL DOCUMENT 74-1127469-00 6 .~5 IF, any of the following occur:
- a. RB pressure is greater than or equal to 4 psig.
S.K.
- b. RB temperature is greater chan or equal to high temperature limit.
- c. RB radiation is greater than the high radiation limit.
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- d. R3 H2 concentrations is greater than or equal to 3.5 wt.%.
ff' THEN scarc[3 R5 coolers with maxitsum NSCW) Q)f 7 6.6 Monitor gas ' and particulate activity and radiation levels ( to decemine if penetration areas and emergency pump rooms I Do not establish a flow ! are safe for personnel entry. 6 \ - path in any system isolated ' by the SFAS without review , of kg/ *i f ,/ the potential release of radioactive gas or liquid. v 6.7 Sample the RCS fluid for boron concentration to ensure 1 { that the RCS is not being diluted. - IF the RCS is being I x diluted, THEN check for leaks into the RB.
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. 6.8 Sample periodically the 'RB sump recirculation water for 9
pH. Maintain pH at 9.3 if RBSS is in use. (One spray addi-tive tank should provide a pH o f 9.3. The second tank is available for pH adjustments). 6.9 Monitor reactor building for hydrogen [nitiate hydrogeM urge when hydrogen concentration reaches 3.5%. Verify hydrogen purge blowers are operable. IF R3 radiation exceeds the high high radiation limit, THEN stop the hydrogen purge. l D/f?
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6.10 Establish makeup water to dhe' spray ponds from the Folsom South Canal or the site reservoir or theLeirculating water canal. If makeup is-' unavailable, maintain the' spray- pond outlet : ~ temperature between 84 and 94F . by. ~ cycling NRW-041 ,
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(042) spray pond interlock valve as, required (intermittent. operation will reduce drift losses, initiate spray at ' 94F and terminate' spray at 84F). *
. 7.0 ESTABLISH DILUTION FLOW TO THE RV.
'7.1 As . soon as practicable within 1seven (7) days, establish dilution flow to the reactor vessel to prevent boron.
precipitation by one of the following steps (7.2 or 7'.3) 7.2 The following line up is the preferred method for estab-lishing dilution flow to the RV (This method . provides the additional reliability of maintaining two operating flow ' paths to the reactor). *
- a. Establish 1 LPI loop in,iecting into the reactor vessel' ' y _
with 1 HPI. loop operating, taking suction from the operating LPI-pump discharge (see OP' A.S. Section-4.2). (Preferred HPI pump is P-238A).
- b. Open the decay heat loop suction valves inside the reactor building, HV-20001 and HV-20002. e
- c. Remove cisarance and. rack in' breaker l:2A179, then 1 throttle open HV-20003 to obtain at least 40 gpm flow 1 to the reactor building sump as indicated by FI-20001, g located on the H2PS panel in the control room. gf
- d. If a minimum of 40 gym flow cannot be obtained, pro- !
coed to Step 7.3. 7.3 Alternate method for establishing dilution flow to the RV.
- a. Remove clearance' and' rack in breaker 2B279,. then close .
. HV-23801, high pressure injection stop to -"D" cold leg.
( --j J hecinn co-101 DATE: -3 P AGE ' 46 8-10-82
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SWNP.20007.2(3 43)' , 3ASCOCK & WILCOX NUMSER U f1LifY POWER GENER AflON Divi $10N ,
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- b. Open HV-23802, . hign pressure injection to pressurizer spray stop valve..
- c. Throttle open SFV-23810 to provide some ' flow when starting a HPI pump. Minimum allowable flow is 105 gym.
- d. Open the decay heat system supply. valves HV-26008: & 'l
-1 HV-26007 to the HPI suction and thel decay heat system (01). "
crosstie .vaives HV-26046 & . HV-26047 . if the opposite , decay heat system 'is in operation. e, Start the HPI pump and throccle SFV-23810 to provide a
' minimum of 105 gym flow to the pressurizer (105 gym 're- )
quired for HPI' pump continuous operation) . l
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J CP-14 'Section CP-101
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o i i 3- . EFFECTIVE DATE 06-19-87 Rev. 4 1 { CP.101.
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A 11RGE LOCA HAS OCCURRE AND THE CORE FLOOD TANK IS EMPTYING . I 1.0 VERIFY SFAS ACTUATION
.1 CBS System must run for ats least 22 minutes i following a _ IACA. D/FF. 1
.2 A-500A or A-500B must run for' at least 24 hours -
( following a IACA. _ EQ3 A CF line break is evident, if one CF tank blows down immediately, but not both, and there is LPI flow to the affected. CF nozzle and 0 LPI flow, . with ' RCS pressure greater than 240 psig, to the other , loop. For a CF line break, RCS pressure will remain I greater than 800 peig for approximately 2.5 minutes.
- 2. 0 DETERMINE IF RUPTURE IS CORE FI40D LINE BREAK BY OBSERVING ,
CF TANK LEVEL AND LPI FI4W.. l i g .1 CF Una Break - Both DNPs Runninn J e i
.1 2 a CF line break'is' suspected i ma y -
1
.1 Verify unaffected LPI train pump is running.
.2 Verify flow path from 31tST to unaffected j CF line is established. j
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.3 Close affected train LPI injection valve. ' .
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.4 Stop the affected train LPI pump. l N.Q E If CF line break. RCS pressure .will remain greater than 240 psig for approximately 7 minutes.
i.e., no LPI flow should exist in unaffected loop with RCS pressure 240 psig. Diff 3 Rev. 4 . ( CP.101-1 1 CP-15
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J-- . .- - . _ . . .. .. . . . . . . ? D)ff n 3 1 2.2 CF Tins Break - One DHP Rinnni,gtg
.1 If a CF line break is suspected and the unaffected LPI loop pump is not operating, establish LPI flow to the UNAFFECTED loop through cross connect valves, HV-26046 and HV-26047.
.2 Limit HPI flow to 525 gym per pump.
Balance flow through each nozzle.
.3 Limit LPI flow to g 3,000 gym.
.4 on the affected CF line by ;
Isolate closing the LPI loop (A CF Line) or STV-26006 (B CF Line) SFV-26005 f
.5 HP1 pumps should -be stopped if, with' only one DHS pump available LPI flow is21500 gym for at least 20 minutes. ,
4.>. f3.0 .I122[ LPI F14Y REACHES 21,000 GPM IN EACH LUG - p/gg
.1222[ RACE IN THE RESPECTIVE CFT OUTLET VALVE BREAEER ,'
(CFT "A" - 2D228 /' CFT "B" - 2D229) AMD CLOSE THE CP"I $ ISOLATION VALVES (CFT "A" HV-26513 / CP"Y "B". HV-26514) TO' j PREVENT NITROGEN INTRODUCTION INTO THE RCS. - t 4.0 2 THE RCS PRESSURE STABILIZES 'ABOVE THE MAXIMUM OPERATING PRESSURE FOR LPI t}P 4d
.12H2[;
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.1 2 there is heat tran=h h OTSGe D/F#
.12H2[ go to CP.10 p 3.0] '
1
.2 2 there is JiQ heat transfer to OTSGs
.1252i go to CP.104. . d 5.0 CONTROL HPL (RULE 1 and 2) 6.0 .Yi22[ LPI FLOW HAS BEEN GREATER THAN 1,000 GPM IN EACH INJECTION LINE FOR AT LEAST 20 MINUTES .12H2[ HP1 SHOULD BE TPRMINATED.
7.0 _1122[ THE BWST IDW LEVEL ALARMS AHD E LPI HAS EQI BEEN 21,000 GPM FOR AT LEAST 20 MINUTES .12H2[ ( "
.1 Open HV-26007 (low pressure injection to HPI Pump P-238A). gg
.2 Open HV-26008 (low pressure injection to HP1 Pump P-238B).
g 1 s v Rev. 4 CP.101-2 CP-16 4
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4 +- 8. 0 .EEN THE BWST LO-LO LEVEL ALARMS l THEN Of ff h1 Check RB emergency sump indicating ugnts 7 E.2 E HPI pump- operation is stin required , pp 12EN verffy OPEN LPI to HPI pump isolation valves
.HV-26007 and HV-26008.
8,
.3 Open Reactor l BuiMing emergency' sump valves to the LPI suction headers, within 4 minutes of receipt of alarm. .
j
.4 Close valves. SFV-25003 and SFV-25004 to isolate the BYST.
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If injection flow is both 'HPI in the piggyback OM mode and from LPI then as RCS pressure decreases HPI } .i flow will increase, and may need to be throttled _back to prevent exceeding.500 gym per pump. 9.0 E LPI high flow alarm is received'
.TBZH ' throttle valves 3 (Loop A); and SFY-26040 .
(Imop B) to limit flow to . gym to prevent pump runaut. 1 O t F~F / O 10.0 ISOLATE MAJOR REACTOR BUILDING LINE PENETRATIONS. w . . j .1 2 core cocung is being maintained by the HP!/LP!/CPT systems 32EN stop the ATW pumps AND close the following valves to inolate the OTSGs. OTSG A Valve Name OTSG B . ( IV-20515 MFW ISOL HV-2051h rV-4uan uru mTvP FV-20530 i PV-20563 TURBINE BYPASS PV-20566 i PV-20571A PV-20571B ADV ADV PV- 20562A PV-20562B E D/ff - ,j PV-20571C ADV PV-20562C 13 Irv-2082'? Arv coh"to:., W-2as23 ( 1rV-20531 ArY i?Oh " to. , 'rV-20Me EV-20s77 AN !rAc c : IV-20578 ( I V-20581 AN 'A C:C IV-205823 P V-EUDol . TJKas 32 ljYPA33 PV-40564 HV-20570 MSS- LINE TRAP HV-20571 HV-35070 MSS LINE TRAP HV-35069
. MV-20569 MSS TO AUX FWP HV-20596 -
HV-20597 MSS TO REHEATERS HV-20596 HV-20585 MSS TO AUX STEAM HV-20560 HV-20587 MSS SAMPLE HV-20588 I HV-32243 MSS TO PEGGING - . HV-20611 OTSG Blowdown
-+ HV-20609 OTSG Blowdown HV-20610 q k Rev. 4 CP.101-3 4
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CP-17 l
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l ! (_ ., 4[1.0l MONITOR REACTOR BUIIIING FOR HYDROGEN.PER OF A.52 Following a LOCA. ensure adequa.te; hydrogen. mixing by periodically.
.1 l activating the emergency cooling 'or containment building sprays -
. over a 30 day period or until containment building. sampling indicates hydrogen production or concentration is no longer a j hazard.
12.0 ESTABUSH LONG-TERM C00UNG. . O - 4 14
.1 Close EMOV. )
.1 2 EMOV does not close M close EMOV block valve (HV-21505). ,
)
.2 Close pressurizer vents EV-21528. HV-2152'2. HV-21515 and HV-21517.
.3 E Open, close Hot Les High Point vents EV-20533. HV-20534; HV-20579, and EV-20580.
.4 Complete secondary plant shutdown per B.4.
.5 Continus LPI cooling until further instructions are given. q l
( .8 2 any of the followins occur ,
.M StartQ RB coolers with maximum NSCY and NSRYb ,
./ / . -
.1 RB pressure is greater than or equal to 4.psig. j
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.2 RB temperature is arentar than or eaual to h< =h temperature limit Q207), or RB temperature indication is :nsQ N C/F'F
.3 RB radiation is greater than the high radiation _ limit.
10 l
.4 RB He concentration is greater than or equal to. '!
3.5 percent. I CAUTION DO NOT ESTABUSH A FI4Y PATH IN ANY SYSTEM ISOLATED BY SFAS WITHOUT REVIEY OF THE POTENTIAL RELEASE OF RADIOACTIVE GAS OR UQUID.
.7 Monitor gas and particulate activities and radiation levels to .
l determine if penetration areas and emergency pump. rooms are safe 4- for personnel entry. l k - ,i Rev. 4 CP.101-4 i CP-18
.) <
I p t' . _ 4 -> 12.8 Sample the RCS fluid for baron concentration: to ensure that the i RCS is not being diluted.
.1 E the LRCS is . being diluted ..
.M check for leaks into -the RB that could be diluting the RB Sump water.
M One spray additive tank should provide a pH of 9.3. The 'second tank is available for pH adjustments.
.9 Sample periodically the RB sump recirculation water'.for ' pH.
Maintain pH at 9.3 - if CBS . is ' in use.'
.10 Monitor reactor building'for hydrogen. Verify: hydrogen purge -
blowers are operable.
.11 Establish makeup water to the spray ponds.
M
~
Intermittent spray operation will reduce drift losses. _
.1 E makeup is unavailable M cycle NRY-041 and NRY-042 spray . pond' 4 interlock valves, as necessary to maintain spray-pond ' outlet temperature between 84*F and 94'F.
I 13.0 ESTABLISH DILUTION FLOW TO THE RV.
.1 As soon as practicable within seven- (7) days, establish dilution flow to the reactor vessel to prevent baron, l precipitation by one of the following ~ steps: (13.2 or 13.3) 4
.2 The following lineup -is the preferred method, for. establishing .
dilution flow to the RV. (This method provides the additional reliability of maintaining two operating flow paths' to the- , ) reacto r.) i
. 1
.1 Establish 1 LPI loop injecting into the reactor vessel i with 1 HPI loop operating, taking suction from the operating LPI pump discharge (see OP A.8, Section 4.2).
(Preferred HPI pump is P-238A.) . 62 Remove clearance and rack-in breakers 2A171 and '2B107,3 l then open the decay neat loop sucuon vatves Instae C/##' the reactor building, HV-20001 and HV-20002. gC
.3 Remove clearance and rack in breaker 2A179, then throttle open HV-20003 to obtain at least 40 gym flow i
. to the reactor' building sump as indicsted by F1-20001,'. '
' located on the H2PS panel in the . control room.
-4 Ra'r. 4 CP.101-5 CP-19 i
9
~-
~..m ,z ..........
,.......,..,.-.,..y.7
..,j ;. , ; q.. . ,%
(' , 4+ 3. 2 . 4 E RB Yater level approaches 5 feet as read on ' p g.g l l LIT-20509A/B or LIT-20510A/B 2 2-
.IHEN rally open valve HV-20003.
.3 Alternate method for establishing' dilution now to the RV. )
i
.1 Remove clearance and rack in breaker 2B179. I
.2 Close HV-23801, high pressure injection stop to "D" d cold leg.
.3 Open HV-23802, high pressure injection to pressurizer _ ,
spray stop valve. ; 4 Throttle open STV-23810 to provide some flow when starting an HPI pump. Wimum allowable flow is.105 gpm.
.5 Open the decay heat system supply valves HV-28008 and -
HV-28007 to HPI suction. l
.1 2 the LPI pump in operation and the HPI pump to be started are of opposite trains
.TEZE open HV-26048 and HV-26047, Decay Heat System crosstie valves.
I .8 Start an HPI pump and throttle SFV-23810 to provide a minimum of 105 gym flow to the pressurizer (105 gpm required for HPI pump continuous operation). h _, i e l i l ( END Rev. 4 " i CP.101-6 CP-20
i ATOG TO E0P COMPARISON
'- CP.102 DIFFERENCE 1 - ATOG step 2. E0P step 2:
.The E0P's provide additional guidance en which section of B.4 to'go to depending upon the' operability of RCP's. This is a- clarification over the AT0G CP.
DIFFERENCE 2 - E0P step 3.1: Reference to the computer point does not exist in ATOG. Th'is is a calculation cf
- i. tube-to-shell o.T that SMUD has added to the Bailey 855 computer. system. :It performs the function of the procedural tube-to-shell: calculation and frees the operator .
to perform other functions. DIFFERENCE 3 - ATOG step 3.2. E0P step 3.2: AT0G step 3.2 reads: "3.2 When the A T. as determined in step 3.2 above...".. It should read "3.2 When the A T. as determined in step 3.1 above...". -The E0Ps are correct in their referencing of steps. . ( DIFFERENCE 4 - ATOG step 3.2. E0P step 3.3: ATOG specifies pressurizer-vent valves for RCS depressuriztion. E0Ps specify the l EMOV. The E0P utilizes the EMOV because it is-more effective at' reducing pressure, I than are the pressurizer vents. Utilization of the EMOV is allowed by the TBD. Reference TBD (III.G.2.7.). DIFFERENCE 5 - ATOG step 5. E0P step 5: See Difference 1. l l (. . CP-21
SWNP.20007 2(3.33; SA8 COCK & WitCOX UTILifY POWER G EN E R AflO N OlVISIO N NUMSER <
]
TECHNICAL DOCUMENT 74-1127469-01 Q ( }j i CP-102 NORMAL C00LDOWN 4
.j 1.0 START RCP's. -
ll 1 1.1 g any ' RCPs are running, THEN go to Step ' 2.0, otherwise - continue. 1.2 . E natural circulation is in progress , "THEN start RCP's j .l per OP A.2, RCP System. Ona operating RCP per loop is a 1
- desired. )
~
D IFF 1-2.0' E TWO OTSG's ARE IN SERVICE, THEN GO TO 'OP 'B.4 OTHERWISE CONTINUE. SECTION 5.0] 3.0 PREPARE FOR COOLDOWN.WITH A DRT OTSG. j 3.1 Calculate the existing tube to shell 4T for the dry OTSG. . Entna % 11 t/c #. AT = - T eoid (01)- number of T/C's -1 AT = F. 'This'value eust not exceed + 100F. (01) ] blFF 3 1 3.2 When the AT, as determined in above, .is <100F, open the bypass valves in the operable OTSG and commence I cooldown. DO NOT exceed 100F tube to shell AT on the dry OTSG. l 3.3 If reactor coolant flow is by natural circulation, use the i auxiliary spray from the HPI system if spray water to PZR l-g7y aT is < 410F or Jase the PZR vent valves- (HV-21515,] q QV-21517) todepressurizetheRCSJ 4.0 EA SMALL BREAK LOCA HAS OCCURRED, THEN GO TO CP-103 STEP 11.0, OTHERWISE CONTINUE.
"pgpp: J
( 5.0 TO .0P B.4 SECTION 5.0. - Section CP-102
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DATE: 3-1 -PAGE 48
.. 1 EFFECTfVE DATE 06-22-87
[ CP.102 Rev. 2 l NORMAL COOLDOWN a 1.0 START RCPs. i
)
.1 2 -any RCPs are rimning 1 M go to Step 2.0, otherwise continue. 1 a
k +- .2 E natural circulation is in progress - 4 M start one . RCP per loop per OF A.2, if possible. -l otherwise continue. . pg 2.0 E_ cwe OTSGs ARE IN SERVICE .
& RFs ARE OPERATING M GO TO OF B.4, SECTION ' 5.0. d 1 e E RCPs ARE HQ.I OPERATING, M GO, TO OP B.4 SECTION 8.0.
a
+
- 3. 0 COOLDOWN WITH A DRY OTSG.
.1 Calculate the existing tube to shell A T' for the dry OTSG.
6T= sum OTsc shall' T/C - Teold number of T/Cs ; I y aT= *P This value must not exceed + 100*F. . 2 ' OR hmputer point G-613 ( A OTSG) and G-614 (B.'OTS . Dgg 1
.2 Whed open the theTurbine A T, asbypassdetermined valves.in@tep 3.f\ahave.
tu 1. 7perable umuisanu. < 1007, - D@) . commence cocidown. DO . NOT exceed 1007 tube . to shell' A T on the dry OTSG.
.3 2 reactor coolant flow is by natural circulation M
.1 2 the spray water to PZR AT .s; 410*F j M depressurize the RCS with Aux Spray from HPl.
i
.2 2 spray water to nzr A T > 410 r MQapressurize the RCS via the EMOV] DiPir- 9 4.0 E A SMALL BREAK LOCA HAS OCCURRED ,,
M GO TO CP.103. STEP 11.0, OTHERWISE CONTINUE. q DtFF 5.0 ('E ON NATURAL CIRCULATION GO TO 'B.4, SECTION 6.0, OTHERWISE - 3 l GO TO B.4, SECTION 5.0. M
'i . Rev. 2 CP.102-1 CP-23 ,
t
. - . . - - . 1 - . ~ -.
l I i AT0G TO E0P COMPARISON r CP.103 4 1 DIFFERENCE 1: EFIC level changed from 379" to 381" based on the latest EFIC design information. DIFFERENCE 2: Added new step 1.3 "IF the high point vent valves have been opened as an ICC action,- leave open until RCS is subcooled OR the Decay Heat System is in operation with RCS pressure <140 PSIG." This is T requirement of the TBD (IV.E.2.2). l DIFFERENCE 3: Table 1 of AT0G was deleted in revision 1. Maintaining OTSG pressures, levels and RCS cooldown rate are expected operator actions and are emphasized throughout the E0Ps. DIFFERENCE 4:
,- Refer to CP.101 Difference 1.
DIFFERENCE 5. Starting the RCP in the' loop. with the operable OTSG is the recommended method of restoring heat transfer per TBDqection III.C.3.5. DIFFERENCE 6: The phrase "If RCP(s) cannot be restarted" was added to step 9 to complement step
- 7. This is a procedural enhancement to reduce operator confusion. l DIFFERENCE 7:
Changed requirement for closing CFT outlet valves from indicated level at zero feet to the respective LPI flow reaching 1,000 gpm. This is a recommendation of the TBD (IV.B.5.1) to prevent isolation of the CFT outlet valves at the wrong time due to post-accident containment environmental effects on the CFT level instrumentation. s CP-24 _ _ . _ _ _ . . . _ , . I
{ 1- . ATOG TO E0P COMPARISON s CP.103 DIFFERENCE 8: This step states " Prior to RCS being cooled to 280*F and 250 psig, sample the primary. coolant for isotopic-analysis and notify the Nuclear Ops. Manager of results before.
~
.I placing the LPI/DHS in a recirculation mode". AT0G has'this step after one that. d indicates the RCS at 150 psig. Earlier sampling is-desirable.since DHR>can be placed in-service at 250 psig RCS pressure.
DIFFERENCE 9: 'j
-)
Changed "150 psig" to "140 psig" and added "... OR when adequate SCM isl established".. LI These changes were made to comply with the TBD (TV.E.2.2). ) j DIFFERENCE 10. E0P CP.101 step 12.2 closes the EMOV and EMOV block after the RCS pressure has~ been reduced to 140 psig. At this point the plant is transitioning from HPI cooling to LPI/DHS cooling. s DIFFERENCE 11: 1 ATOG CP.103 step 11 states " SELECT LPI/DHS OR NATURAL CIRCULATION.COOLDOWN. IF LP!/DHS C00LDOWN IS SELECTED, THEN GO TO STEP 13.0, OTHERWISE CONTINUE'WITH OT5G COOLING." This step implied that the cooldown could be' completed with OTSG's without having to use LPI/DHS if use of the R.B. Emergency Sump water is undesirable. f This is not possible since LPI/DHS is necessary for inventory control, either directly or through " piggyback". CP.103 now utilizes LPI/DHS cooling on sump recirculation if necessary. l DIFFERENCE 12:
]
AT0G CP.103 step 12.4 states "WITH RCS PARAMETERS STABLE DO NOT SHIFT LPI SUCTION TO THE SUMP UNTIL THE DECISION HAS BEEN MADE TO COMPLETE C00LDOWN WITH LPI/DHS. ALTERNATE C00LDOWN METHOD CAN BE IN ACCORDANCE WITH OP B.4, SECTION 6, NATURAL CIRCULATION C00LDOWN." This step no longer applies due to change described in ! Difference 11. I i l DIFFERENCE 13: ! This step was added to E0P CP 103 to ensure pump suction. was not aligned to'the BWST if BWST lo-lo level alarm was spurious. (. l CP-25 1 _._ ._. ._. _ 1
.p .
, :. . J i
nl
~
ATOG TO E0P COMPARISON ~ '(%
., CP.103 .!
1 l
.i DIFFERENCE 14: j Refer to analysis:of CP.101 Difference-10. ]
DIFFERENCE 15: , Step 16 of E0P CP.103 was rewritten to clearly describe.how LP[/HPI piggyback'is . to be established without requiring the. operator to refer to'another/proce' dure. ] Limits for runout for both HPI and LPI pumps are stated. The ope'rators'are directed to check the R.B. Emergency Sump level indicating lights to. ensure the LPI pump suction was not aligned to the.R.B. sump if the BWST lo-lo level alarm was spurious. E0P CP.103 differs from ATOG CP.103 in' that it allows both HPI' pumps to be operated in the piggyback mode concurrently. Refer to TBD/EOP comparison for TBD section. ! IV.B.7.2 for justification. DIFFERENCE 16: E0P CP.103 added step 18.2.3 " VERIFY ANY OPERATING HPI/ MAKEUP PUMP HAS A SUCTION-
,. SOURCE OTHER THAN LPI." to ensure a suction source is alw'ays. maintained, DIFFERENCE 17i Valve DHS-001 was renumbered to HV-20005.
DIFFERENCE 18: Step 18.8 of E0P CP.103 was revised to remove the reference to the RCP jog start '; method in OP B.4. section 6. since no'such method exists in OP B.4. I DIFFERENCE 19: q 1 Step 19.3 of E0P CP.103 was revised to dd. rect the operator to Casualty Procedure j C.12 " Loss of Decay Heat Removal System", since this is the appropriate procedure ] for the given plant conditions. J 1 l i e ! l {s :] CP-26 H 1 o, .;
l i
.ATOG TO E0P COMPARISON
( CP.103 , j
. DIFFERENCE 20: I E0P CP.101 step 20 directs the operator to CP.101_ step 12. ATOG CP.101'ste.p 20 directs the operator to CP.101 step 5. The actions of ATOG CP.101 step'5 are i performed in E0P CP.101 step 10.
]
ACTION: j Change CP.101 step 12 to CP.101 step 10 in step 20 of E0P CP.103 to conform to ATOG. IMPLEMENTATION: . Pre-startup. l s t k CP-27
, ._. ---.a- .
. . . . . . - . . . . . . ~ ~ , - - -. .
tWNP.20007.2(3.83) . - - BA6 COCK & WILCOX UTlWTY POWER GENERATION OlVl$1CN - NUMBER
.( TECHNICAL DOCUMENT 74-1127469-01 I
CP-103 - l TRANSIENT TERMINATION FOLLOWING AN OCCURRENCE THAT LEAVES THE RCS SATURATED WITH OTSG(S) REMOVING HEAT
.I 1.0 VERIFT THAT HEAT TRANSFER IS BEING CONTROLLED.
]
Verify maximum HPI flow (see Specific Rule 1). 1.1 1.2 Raise SG levels e inches high range (manually or with EFIC). D/f.* (01) f 2.0 IF,THE CORE FLOOD TANKS ARE EMPTYING, THEN GO TO CP-101. 3.0 ENSURE THE CFT ISOLATION VALVES (HV-26513 AND HV-26514) REMAIN OPEN. I 4.0 BEGIN C00LDOWN OF RCS. gg 4.1 Increase OTSG steeming by opening the TBVs or ADVs. J ,
>}( IF necessary to maintain OTSG ' pressure, OR OTSG level, ORl
/
.2 - -
s : RCS cooling, THEN bypass EFIC AND cake manual control o per Table 1. (01) 4.3 Verify that OTFC continue to provide heat sink for the RCS-by: . o
- a. Remaining pressurized AND
- b. Incore T/C temperature decreases as .0TSG pressure is lowered.
4.4 Continue saturated cooldown by decreasing OTSG pressure. 1 4.5 If the RCS does not cooldown as the OTSG are. depressurized, THEN bump a RCP to rees t al,lish heat ~ transfer via natural circulation. . 4.6 WHEN the BWST level reaches 10 ft. level, THEN begin makeup to the BWST with borated water.
- k
)- 5.0 IF, HEAT TRANSFER TO THE OTSG(s) CANNOT 3E MAINTAINED, THEN GO TO CP-104 CP-28 Section CP-103 j
_DATEe 1-1-RA I ._ _ l p a C E_ _ _ .. . _. . 1
q nWur. mar.ns.am
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SABCOCK & witt0x . UTILITY POWER QENGEATION DIVISION , NUMBER TECHNICAL DOCUMENT- - 7A_1127469-00' ) '( 6.0 F THE RCS BECOMES SUBC00 LED, THEN START A- RCP. - 6.1 Determine that both. incore T/C's and' hot- leg -RTD's; indicate subcooled conditions.
.2 Preferably start RCP B or D.
M/ #
~s.
7.0 F TFE RCS REMAINS SUBC00 LED AFTER STARTING THE ' RC PUMP, . THEN GO 10 CP-105, OTHERWISE CONTINUE. 8.0 IF FOR ANT REASON THE RCS BECOMES SDPERHEATED, _THEN GO TO SECTION LCC. = g,py GP
.0 I_F, THE -RCS StiBC00 LED MARGIN- IS RESTORED : ' DURING TEIE : liATURAD CIRCULATION C00LDOWN, THEN GO TO CP-105, OTHERWISE CONTINUE.
'10.0 WHEN THE CORE FLOOD TANK LEVELS ~ DECREASE TO THE LOW-LOW LEVE -;
t, .
.. t SETPOINT, THEN RACK IN . BREAKERS 2D228 'AND 2D229 .AND CLOSE.'CFT .
ISOLATION VALVES HV-26513 AND ' HV- 26514 _ TO ' PRE!/ENT - NITROGEN DUCTION INTO THE RCS. D/jagar, 11.0 WREN RCS DEPRESSURIZES TO LESS TRAN THEN CLOSE ALL HIGH : POINT VENT VALVES (HY20533, HV20534, HV20535, AND HV20536). pj g
//
2.0 SELECT' LPI/DHS OR NATURAL CIRCULATION C00LDOWN. IF LPI/ S C00LDOW IS SELECTED, THEN GO TO STEP 13.0 OTHERWISE CONTINUE WITH OTSh COOLING- - . DHrF
.1 Prior to RCS being cooled to 280F anc! 250 psig, sample th primary coolant for isotopic analysis and notify the plant .J superint'endent. of results before placing ' the LPI/DHS in service. ;D}ff With KG3 parameters stable, do not shift LPI ' suc tion to
{ 12.2 the sump until the decision has been made ' to complete . cooldown with LPI/DRS. Alternate cooldown method can be 3 s . in accordance with 0F B.4, Section 6, . Natural' Circulation) . j.1 ooldown. - section CP-103
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DATE: 10-8-82 . PAGE 50? ____u__ m. m__.____________h
e l . . . SwNP.20007 2(3.33) . , BASCOCK & WILCOK UTI6 17Y POWER GENERAfloN DIVISION NUM8tR _
/g TECHNICAL DOCUMENT 74-1127469-00 i
13.0 WHEN LPI FLOW HAS BEEN IN EXCESS '0F 1000 GPM IN EACH INJECTION LINE FOR AT LEAST 20 MINUTES, 'STOP HPI PUMPS AND CONTINUE, OTHERWISE GO TO STEP 16.0. 14.0 TRANSFER LPI SUCTION TO RB SUMP. 14.1 WHEN the BWST lo-lo-level alarm actuates (minimum time 1/2 to I hour), THEN transfer LPI suction to RB sump within 4 minutes of receipt of alarm.
- a. Open valves HV-26105 and HV-26106 to supply water from the RB emergency sump to the DH suction headers.
- b. Close valves SFV-25003 AND SFV-25004 to isolate the BWST. I
- c. E DH high flow alarm is received, THEN throttle valves SF-26039 (Loop A) and SW-25040 (Loop B) to r below h gpm per pump to prevent pump runout.
D /F~f" " i w /9 15.0 GO TO STEP 18.0. i l 16.0 g THE CONDITIONS OF STEP 13.0 ARE NOT MET BEFORE THE BWST I , DirF LO-LO-LEVEL ALARM ACT ATES (MINIMUM TIME 1/2 TO 1 HOUR), THEN: fg
- a. Align one HPI pump to take suction from the RB sump using the LPI system to provide HPI suction,
- b. Stop second HPI pump if running,
- c. On BWST lo-loll evel, shift one HPI pump suction from the RWST to the operable DHS pump discha ge.
- 4. Align the operable DHS pur2p suction to the RB sump in accordance I with OP A.8, Section 4.2.
17.0 ESTAdLLSR CONDITIONS FOR LPI COOLING. 17.1 Continue HPI/LPI " piggyback" mode until RCS pressure is 250 psig. 17.2 Maintain 250 ps'ig and continue cooldown until adequate subcooling margin is established. J et n P-103 CP-30 DATE: g_g_g PAGE 51
, i .
swNo.20cor.2(s.s 1 ] sASCSCK & WILCCK .. UTILifY Powta OENERATION DIVt$lCN NUM4tR TECHNICAL DOCUMENT 74_1127469-00' ) (. . 18.0' WHEN ADEOUATE SUBC00 LING MARGIN IS ATTAINED, THEN ESTABLISH LPI/ DER
\
COOLING. ] 18.1 IF, F two . decay heat trains are , operable , THEN ' continue ' with j Step 18.5. .IF only one decay heat train is operable,' THEN continue with Step 18.2. - 18.2 WHEN the HPI/LPI piggyback operation has been suppling at least 1000 gym to each loop for 20 minutes 'AND, duringl ,
'this time the RCS pressure has been less than the . maximum I i
pressure for LPI operation alone, THENS !
- a. Verify that the LPI to RCS valves - (SFV-26005 *and
-26006) are open. -
)
- b. Establish normal makeup as required. :1
- c. Close LPI to HPI valves (HV-26007 and -26008).
18.3 When two DH systems are operable, THEN follow Steps 18.5 ; through 18.6. 18.4 Until two DH systems are operable, continue with Step I @p.h 18.8. , _ CAUTION DO NOT ESTABLISH A FLOW PATH IN ANY-SYSTEM ISOLATED BY.THE SFAS 1 WITHOUT REVIEW OF THE POTENTIAL RLEASE OF RADIOACTIVE GAS OR LIQUID. 18.5 Open the DH Loop A suction manual isolation from.reac IFF vessel valve (DHS-001). , 18.6 Establish core cooling with the LPI Loop A in the DHS mode - in accordance with 0F A.8, Section 4 at 1000 spa. p 18.7 WHEN DH system -flow has been greater than 1000 gym in each line for at least 20 minutes, THEN: (1) Trip RCP's if running, . (2) Establish both LPI systems, in DHR mode, (3) Establish overpressure protection.
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._.) ?
Section CP-103 ! DATE: CP-31 10-8-82 PAGE .52 l
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8WNP.20007 2(3 43)- ~
.I SASCOCK & WILCOX UTILITY POWER GENERAflCN OlVISION NUMBER
( TECHNICAL DOCUMENT 74-1127469-0t. 18.8 Maintain seal water flow to all RCP's in anticipation of inumediate restart should LPI flow be interrupted (one D/Ff RCP/ loop if required). Should RCP restart be required, /S use the jog start method described.in OP B.4, Section 6g 19.0 CONTINUE COOLDOWN ON LPI SYSTEM. - 19.1 When on DHS . flow, core aT is monitored by comparing' DHS - pump inlec ,and cooler outlet temperature or incore thermocouple and cooler. outlet t.aspe rature. 19.2 Continue RCS cooldown to 140F with' core cooling provided by DES and- RCS pressure controlled by HPI and/or. pressurizer control. 19.3 g LPI flow is interrupted AND RCP flow is not avai.lable , THEN oncinue RCS cooldown in. sccordance with OP B. ection 6. jg gq 19.4 With core cooling provided by LPI, . place OTSG 's - in wet j layup as conditions permit. Bypass EFIC, if necessary, AND (01h.
. stop AFW pumps. Ensure at least one AFW pump is available for restart.
19.5 g adequate subcooling margin is lose, THEN . align .one LPI pump to BWST or RB sump. Maintain maximum flow until [i adequate subcooling margin is regained. 20.0 ESTABLISH LONG TERM COOLING PER CP-101' AT D/II 20 k 3 _~ l
.CP-32 Section CP-103 1
.~ * ' ama I -. .l.. n a e e _,c . . .. _ .
.... . . ,. 2 .. . . . _ . . . _ , ,.-. . . , m _. .. ;. ,
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I _ .i
' EFFECTIVE DATE 06-22-87
' i .. CP.103
' Re v. - 4 1 l
TRANSIENT TERMINATION F011DWING AN OCCURRENCE THAT '! TRAVES TME RCS SATURATED Y1TH OTSG(S) WFMOVING MEAT 1.0 VERIFY THAT, HEAT TRANSFER IS BEING CONTROLLED.
.1 Verify znaximum HPI flow (RULE 1).
~
.2 Vartfv O'"SG 1evels at, or increasing to, "ECC SETPOINT"-
G 381" rr r g D / 7 F' / _ 4-> .3 2. the High Point Vent valves have been opened as .an ICC D/fF action, leave open until RCS' is subcooled DE the. Decay . [ g' 4 k Heat System is in operation with RCS pressure .s; 140 psig. J 2.0 2 THE CORE FI4OD TANES . ARE EMPTYING 4 IEDI GO TO CP.101. 3.0 ENSURE THE CFT ISOLATION VALYES (HV-26513 AND HV-26514) REMAIN OPEN.
- 4. 0 BEGIN C001DOWN OF RCS. )
t g, .1 Increase OTSG steaming by opening the TBVs or, ADVs. j t j
" .2 Verify that OTSG(s) continue to provide heat sink for the RCS by: )
_. q
.1 Re==ining pressurized !
l AND I
.2 Incore T/C temperature decreases as OTSG pressure is lowered.'
.3 Continue saturated cooldown. by decreasing OTSG pressure. ,,
.4 2 the BCS does not cooldown as the OTSGs are depressurized THIX bump a RCP to reestablish heat transfer via natural )
circulation. 1 5.0 2 HEAT TRANSFER.TO THE OTSG(S) CANNOT BE MAINTAINED THEN GO TO CP.104. 6.0 2 THE RCS SUBC00 LING MARGIN IS RESTORED .3 JED[ START A RCP.
.1 Determine that both Incore T/Cs and hot leg RTDs indicate subcooled conditions. j If only one OTSG is available then start one RCP -in that loog . 'A Rev. 4 5 CP.103-1 CP-33 i
, .. . . . . . .. -. . .. . . . . , . . 1 . . , . ... .,_........,...s,...
- . ~ .
- . . - . . - . . . . . , . . . . . . . . . . ...._.. . . . , . - .w.. . *- ....:.. ..- .-
l - ( 7.0 2 THE RC5 REMAIN 5 SUBCOOLED AFTER STARTING .THE RCP M START A SECOND RCP AND GO TO CP.105, OTHERTISE CONTINUE. 8.0 2 FOR ANY REASON THE RCS BECOMES SUPitRWEATED M GO TO E.07 "ICC". pjgg 9.0 2 TH'E RCP(5) CANNOT BE STARTED, AND LTHE SUBC00 LING h MARGIN 15 RESTORED DURING THE NATURAL CIRCULATION C00LD0YN M GO TO CP.105, OTHERTISE CONTINUE.
+ F10.0 M LPI FI4Y REACHES 21,000 GPM IN EACH LINE M RACE IN THE RESPECTIVE CFT OUTLET VALVE BREAEER gjpg '
(CFT " A" . 2D228 / CFT "B". - 2D229) AND, CLOSE THE CFT - IBOLATION VALVE. (CFT "A" - HV-26513 / CIPT ~B" - HV-26514) . TO PREVENT NITROGEN INTRODUCTION INTO THE RCS. CAlEElH Do NOT ESTABUSH A F14Y PATH FROM THE' REACTOR BUILDING IN ANY ISCLATED SYSTEM YtTHOUT REVIEY OF THE POTENTIAL RELEASE OF RADIOACTIVE GA5 OR LIQUID.
/ LLO PRIOR TO RC5 BEING COOLED '!V 280'F AND 250 PSIG, 5 AMPLE THE 7gDIFF !
PRDLARY COOLANT FVR ISOTOPIC ANALYSIS AND NOTIFY THE NUCLEAR (' OPS. MANAGER OF RESULT 5 BEFORE PLACING THE LP1/D IN A RECIRCULATION MODE. h . _. 12.0 Y nt'ft M Dr.r- ,6iu-a= To fN 40 PSIG QE YHF'.4 q LAJEQUATE SCM 15 mmABLasuzu md D/#'# 1
*/ i
.1 Close all High Point Vent valves (HV-20533 HV-20534, /
EV-20679. HV-20580 HV-21528. and HV-21522) ' D/Ff (2 Close the EMOV and EMOV Block valve (HV-21505)) g 13.0 YHEN LPI FI4Y HAS BEEN IN EXCESS OF 1,000 GPM IN EACH INJECTION LINE FOR AT LEAST 20 MINUTES, STOP HPI PUMPS 4 AND CONTINUE, OTHERTI5E. GO TO STEP 18.0. , I l 1 Rev. 4 '! CP.103-2 CP-34 l
. - ..~:.< ; .. < <-
__-_ .3-
.y -
3- gy 7. A' . s , ., 4-> 14.0 TRANSFER LPI SUCTION TO RB SUMP. .
.1 IIEN the BWST lo-lo level alarm actuates. (minimum time i 1/2 to 1 hour) 1
'I]EE within 4 minutes 'of. receipt - of alarm 1 i
p,pf . (.1 Check RB Emergency Sump level indicating; light]s - jg
.2 ' Open' valves HV-26105 and HV-26106 to supply water - 'I from 'the RB emergency sump to the DH suction header.
.3 Close valves SFV-25003 AND SFV-25004: to isolate the BWST.
E DH high flow alarm is received =
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.TIEE throttle valve W-26039 (Loop A) and SFV-26040 (Loop B) to below 0 gym per pump. to prevent pump runout.-
Z)/4**F 1 15.0 GO TO STEP 16.0 4 ~ 16.0 E..THE CONDITIONS OF STEP 13.0 ARE NOT M' ET BEFORE THE ' BWST LO-LO-LEVEL ALARM ACTUATES (MINIMUM TIME 1/2 TO 1 HOUR)- ] M I [ .1 Within four minu.tes, (piggyback), with LP1 align HP1 suction- to take from suction from RB emergency sumpLPIasl follows: Open HV-26105 ' and HV-26106, RB emergency. sump to LP! j [U .1-suction- headers. T
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.2 Open HV-26007' and NV-26006 LPI to HPI suction isolations (piggyback).
.3 Cheek for RB emergency sump level indicating lights.
.4 Close SFV-25003 and SFV-25004 to isolate BWST.
.5 Verify 'HPI flows less than 500 gym per pump.
.6 Verify LPI injection flows less than 3,000 gym per pump.
D/ff 17.0 ESTABLISH CONDITIONS FOR LPI COOLING. /3
.1 Continus HPI/LPI " piggyback" mode until RCS pressure is 250 psig.
.2 Maintain 250 psig and continue cooldown until adequate subcooling ,h wi. margin is established.'
1 i k, Rev. 4 I CP.103-3 a l CP-35 -! I
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3 1 ( , 4+ 18.0 MN ADEQUATE SUBC00 LING MARGIN IS ATTAINED M ESTABUSH LPI/DHR C00MNG. ,.1
.1 E two decay heat trains are operable. THEN go to Step 16.5. . E only one decay heat train is operable, M continue with Step.18.2. ,
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.2 MN the HP1/LPI piggyback operation has been supplying at hast 1000 gym to each loop for 20 minutes M during tha time the RCS pressure has been less than the maximum pressure for LPI operation alone ;
IEEN -{
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.1 Verify that the LPI to RCS valves (SFV-26005 and. SFV-26006) I are open. . y i
.2 Establish normal' makeup as required. ^
.3 Verify any operating 'HPI/ Makeup Pump has a suction source M/EF other than LPL 4
.4 Close LPI to HPI valves (HV-26007 and HV-28008).
.3 .IEEN two DH systems are operable
.IHEN follow Steps 18.5 through 18.6.
( .4 Until two DH systems are operable, so to Step 18.8. CA1TITON DO NOT ESTABUSH A FLOY PATH FROM THE. REACTOR BUILDING IN ANY ISOLATED SYSTEM WITHOUT REVIEY OF THE POTENTIAL RELEASE OF RADIOACTIVE GAS OR UQUID. ,
.5 Open the DH Imop A[ suction isolation valve' HV-20005] _
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.6 Establish core cooling with the LPI Loop A in the' DHS mode f in accordance with OP A.8, Section' 4. j
.7 .IEEN DH system flow has been greater than 1000 gym in each line for at least 20 minutes IHEN
.1 Trip RCPs if running.
.2 Establish both LPI systems, in DHR mode.
+ .3 Establish overpressure protection.
Rev. 4 CP.103-4 s CP-36 j l
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4 >- 18.8 Maintain seal water flow. to all' RCPs in anticipation of immediate restart. Should 1.PI flow be interrupted start one i 1 RCP/ loop if required. - 19.0 CONTINUE. C00LDOWN ON LPI SYSTEM.-
.12 DHR pump inlet and cooler outlet temperatures are not available .T102i use RCS. thermocouple (Incore and . loop) to prevent exceeding cooldown limits.
.2 Continue RCS cooldown to 140*F .with core cooling provided by' DHR. and RCS pressure controlled by. HPI and/or pressurizer control
.3 E LPI flow is interrupted MD RCPs are not available p/FF
'I222[ go to C.12. " Loss of Decay Heat Removal System".
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.4 With core cooling provided .by LPI. pla'ce OT5Gs in wet layup as conditions permiL Stop AFY pumps. Ensure at least one- ATY pump is available for restart.
.5 2 adequate subcooling margin is lost . TIE 2[ align one .LPI '
pump to BW57 OR R3 sump. Maintain maximum flow until adequate subcooling margin is regained.
-(e 20.0 ESTABLI5H LONG TERM COOLING. PER CP.101. STEP 12.0.
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i 1 l, b END ( Rev. 4 i CF.103-5 CP-37 m.
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ATOG TO E0P COMPARISON I g. CP.104 l DIFFERENCE 1: [ 1 1 E0P CP.104 step 1.1 references Rule 2, but AT0G CP 104 step 1.1~does not. The ) reference to Rule 2 is simply additional direction that will provide more I complete information to the operator regarding HPI operation. 1 DIFFERENCE 2: I E0P CP.104 step 1.2 was added to provide better continuity of action when entering CP.104 from E.07, ICC. The requirements of this step are those j recommended in the TBD (IV.E.2.1). ! DIFFERENCE 3: I E0P CP.104 step 3.0 does not exist in the AT0G CP.104. This step was added , to ensure proper action would be taken if the RCS became superheated since, ! because the RCS is already in a saturated condition, there is some likelihood a superheat condition could evolve and CP.104 was not designed to address a superheat situation. 1 DIFFERENCE 4:
)
E0P CP.104 step 7.1 states as part of its direction "...AND cooldown rate is I
<100"F/Hr. THEN go to step 10.0. The corresponding AT0ii CP.104 step states l is part "... but voids are trapped in high points of loops". This change was I made to ensure the operator doesn't attempt to recover OTSG heat transfer when !
its unnecessary due to the amount of HPI injection required. This change was made as part of incorporating the recommendations of TBD section III. B.3.5. ] DIFFERENCE 5: E0P CP.104 step 7.2 states in part "The RCS is saturated...". This statement is not part of the corresponding ATOG CP.104 step. This statement of condition was added to provide more specific information regarding the plant condition ' that would apply for this step. OlFFERENCE6: The direction of E0P CP.104 step 8.0 differs from that of ATOG CP.104 step 7.0 in that it directs the operator to a different loc,ation in CP.103. This results in two additional CP.103 steps being encountered: step 8.0 which gives direction
's CP-38
_ _ _ _ _ _ _ _ _ _ _ _ _ . . - _ _ ___m_
ATOG TO E0P COMPARISON r' CP.104 DIFFERENCE 6 (Con't): ) if the RCS reaches a superheat condition and step 9.0 which gives direction ,
. if RCS SCM is regained. Addressing these additional steps provides necessary I direction to the operator that may apply as he proceeds within CP.103. The direction of E0P CP.104 step 8.0 is therefore considered more appropriate when transferring to CP.103.
DIFFERENCE 7: E0P CP.104 step 9.0 is titled differently than the corresponding ATOG CP.104 step (8.0). This wording change was made to more accurately describe the intent of the substeps. DIFFERENCE 8: i E0P CP.104 step 9.3 specifies 381" vs. 379" for the correct OTSG 1evel to be maintained. E0P CP.104 direction is correct and reflects the current EFIC system design / operation. Refer to A.51, Auxiliary Feedwater System, for further information on EFIC.
' DIFFERENCE 9:
The direction of AT0G CP.104 step 9.0 is distributed throughout steps 11.0, 13.0, 17.0 and 18.0 of E0P CP.104. The E0P steps provide the same direction as those in AT0G, but at the completion of certain actions rather than before any heat transfer restoration steps are taken. DIFFERENCE 10: AT0G CP.104 steps 10.0, 11.0, and 12.0 provide direction for restoring heat transfer. The corresponding steps in E0P CP.104 are also 10.0. 11.0 and 12.0 however, the specific direction is somewhat different. The'EOP CP.104 steps were written to agree with the actions specified for restoring heat transfer in E.04, Loss of Heat Transfer, thereby providing consistency of direction i between these two procedures. The E.04 actions are based on the recommendations of TBD sections III.G.2.2.4 and III.G.2.2.5. l CP-39 1
l J ATOG TO E0P COMPARISON CP.104 , J DIFFERENCE 11: The condition for allowing an RCP start even if the RCS is saturated in E0P - CP.104 step 14.0 is not specified in the corresponding.ATOG CP.104 step. This . clarification was added to ensure the operator understood it was the intent of the CP.104 step to start an RCP, if possible, regardless of RCS SCM since this action would be contrary to the requirement that adequate SCM must exist to start and run an RCP. Refer to analysis of TBD III.C.2.7/3.5 difference
#S.
4 OIFFERENCE 12: The required DTSG level of ATOG CP.104 step 13.0 is different from that of E0P CP.104 step 14.0 in that the E0P step specifies to start an RCP in a loop with the highest OTSG level (if possible) while the ATOG step only requires an OTSG level greater than 24". The E0P step direction is more appropriate since the effectiveness of the OSTG as a heat sink to collapse RCS voids is directly related to the level within, f i I l CP-40 E-_-------_---
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S ABC0 CK & wtLCOX . UTitlTY Powet GENERATION DIVISIO N - ' NUMSER TECHNICAL DOCUMENT 74'-1127469-00 g :I f ' CP-104 h
'ly TRANSIENT TERMINATION FOLLOWING AN OCCURREF E THAT LEAVES q THE RCS BEING COOLED BY HPI COOLING -
1.0 ,IF THE RCS .IS' SATURATED, THEN ENSURE MAXIMUM HPI' FLOW. - 1.1 See Specific Rule 1. 2.0 OPEN OR VERIFY OFEN EMOV-AND EMOV BLOCK VALVE (HV-21505).- 3.0 WHEN THE RCS.SUBC00 LED MARdIN IS ESTABLISHED, THEN;
- a. Start a RCP AND
- b. Control HPI per Specific Rule 2. a 4.0- IF THE RCS IS SATURATED, THEN ENSURE THE CFTs VALVES REMAIN OPEN. ,,
5.0 TF, THE RCS SUBC00 LED MARGIN IS- ESTABLISHED AND THE. RCS
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DEPRESSURIZATION IS BEING CONTROLLED, THEN ISOLATE THE CORE FLOOD TANKS. 5.1 WHEN the RC system pressure reaches 675 to 700 psig, THEN rack in breakers 2D228 and 2D229 AND close the core flood. isolation valve (HV-26513 and'26514). 5.2 Open AC supply switches at MCC-S2D2 and cag, in accordance: with OP A.4. (f
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CP-41 Section CP-104 DATE: PAGE 54 10-8-82 - __ _ -. ____.-2... i
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$WNP.20007 2(3.33) l 4ASCOCK & WILCOX
. UTILifY POWER GENERAflON OtVISION NUMBER pTECHNICAL DOCUMENT 74-1127469-01 j
6.0 IF AT ANY TIME-
- a. THE INCORE T/Cs INDICATE THAT THE RCS SUBC00 LING MARGIN IS REESTABLISHED WITH' FW AND- SGs STILL AVAILABL[E BUT VOIDS ' ARE]
.CRAPPEDINHIGHPOINTSOFLOOPS u OR s
- b. FW TO OTSGs IS RESTORED AFTER ENTERING CP-104 WITHOUT FW, j THEN FOLLOW STEPS 8.0 THROUGH 13.0. _j i
(O GO TO CP-103 STEP.10 9 DiF F 6 ,
.0 ESTABLISH CONDITIONS NEEDED TO RESTORE HEAT TRANSFER) D FF 7 i
{ IF the RCS is NOT subcooled using core exist T/C's OR hoc 8.1 leg RTDs THEN ensure maximum HPI flow. 8.2 g NO RCPs are running, THEN try to get at least one RCP ready for bump. } 8.3 Ensure that SG levels are being maintained a 379 inches j high range. ggp g (O L) ; 9.0 g AT ANT TIME, WHILE PERPORMING STEPS 10.0 THROUGH 13.0, NATURAL N CIRCULATION IS REGAINED, THEN
- a. IF, the RCS is subcooled as indicated by both incore T/Cs and hoc 'j leg RTDs THEN go to CP-105.
I {
- b. I_F, the RCS remains saturated , THEN go to CP-103. I 9.1 Natural circulation is verified by:
- a. Thot and IC T/C's (average of 5 highest) indicate
' subcooling and decreasing.
. b. Primary IC T/C temperature decreases when secondary pressure la decreased.
btFF C I s Section CP-104-3-1-84 _ _ ___f AGE
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BWNP.20007.2(5 83) { i
. SAsCCCE & WILCCX .
UflLITY POWER GENtRATION DIVISICM ' NUMSSR - TECHNICAL DOCUMENT .74-1127469-01; A - C biff 10-1 10.0 LOWER OTSG PRESSURE TO INDUCE HEAT TRANSFER." , j
' 10.1 Lower OTSG . pressure 4 . by . adjusting TBVs or ADVs,=lwhiler esintaining OTSG l' eve l, until' secondary Tsac 'is 40 , to 60F.
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lower than core exit - thermocouple temperature. Maintain- ,q this 0TSG pressure.
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10.2 IF, necessary to maintain OTSG . pressure,f 0R OTSG level,{0R ' ~ RCS cooling, THEN bypasa EFIC . AND take manual control - of'. AFW per Table 1.
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11.0 IF, RCPs cannot be bumped, THEN CONTINUE! COOLDOWN WITH ' STEP- 1.0' through 7.0 0F THIS SECTION. , 12.0 USE PUMP BUMPS TO INDUCE HEAT TRANSFER. 12.1 Determine RCP operability per OP A.2. 12.2 Bump a RCP , which is capable' of being started, in a . loop ..... I with OTSG level at the low level' limit'or greater. h -
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12.3 Allow RCS pressure to stabilize within *20 patg. 1
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. 12.4 Rapest Steps 12.2 through '12.3 for operable RCPs that have j not been bumped. Allow 15 minutes between ptmp bumps. W - all operable RCPs have been bumped and heat . transfer HAS l NOT been reestablished, THEN continue.with Scep 13.0.
'i 13.0 FURTHER LOWER OTSG PRESSURE TO INDUCE HEAT TRANSFER. l 13.1 IF,at least one hour has passed since reactor trip and any RCPs are capable of being started, THEN start and run one ,
RCP, pre ferably in a loop with OTSfGlevel greater. than]. , U I1. (24". f e 14.0 IF RCS MAINTAINS SUBC00 LING MARGIN THEN GO TO CP-105. IF ~RCS REMAINS SATURATED THEN CONTINUE COOLDOWN PER STEPS 1.0 THROUGH .7.0.
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Section CP-104 DATE: PAGE' 3-1-84 , 56
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' EFFECTIVE DATE 07-10-87
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Rev. 4 CP.104 TRANSIENT TERMINATION FOLLOWING AN OCCURRENCE'THAT LEAVES THE RCS ET'TNG COOf E BY HPI COOLING I 1.0 ~ E THE RCS IS SATURATED M ENSURE MAXIMUM HPI FLOW.
.1 Follow Rule 1 D gre tl: ,1
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DtFF .2 2 the High Point Vent valves have been opened as an ICC 2, action M leave open until RCS is subcooled M the Decay Heat System is in operation with RCS pressure i140 psig. . 2.0 OPEN OR VERIFY OPEN EMOV (PSV-21511) . AND EMOV BLOCK VALVE
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(HV-21505). DtFF (3.0 m FOR ANY REASON THE RCS BECOMES SUPERHEATED .
.l 3 L M GO TO ' E.07, ICC . .I
- 4. 0 .ME THE RCS SUBC00 LING MARGIN IS ESTABLISHED .I M
v .1 Start a RCP M y .
.2 Qontrol HPI per Rule 2.- ;i ~
5.0 2 THE RCS IS SATURATED ; M ENSURE THE CFTs ISOLATION VALVES REMAIN OPEN. 6.0 E THE RCS. SUBC00IlNG MARGIN IS ESTABLISHED M THE
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RCS DEPRESSURIZATION IS BEING CONTROLLED - M ISOLATE THE CORE FLOOD TANKS. j
.1 JHEN the RC system pressure reaches 675 to 700 psig M rack in breakers 2D228 and 2D229 M close '
the core flood isolation valve (HV-26513 and HV-26514).
.2 Rack out breakers 2D228 and 2D229 and tag in accordance with OP A.4.
7.0 2 AT ANY TIME: ]
.1 THE INCORE T/Cs INDICATE THAT THE RCS SUBC00HNG MARG:N IS '
lNTABL151MD YlTH N AND SGs S"ILL AVAILABLEJM COOL)OYN) 4 >MF QATE 5 < 100*F/HR, M GO TO .nw 10.a. y N 8 i
.2 CTHE RCS IS SATURATED M)FW TO OTSGs IS RESTORED AFTER J ENuauNG CP.104 WIHTOUT FW, M GO TO STEP 9.0.
Rev. 4 CP.104-1
- CP-44
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.h h0 GO TO CP.103. STEP 8.0.3 DIFF lo 60 PREPARATION TO REST' ORE HEAT TRANSFEQb g prp 7
.1 2 the RCS is M subcooled'. using incore T/Cs QE hot leg KTDs M. ensure maximum HPI flow. ,
1 E HQ RCPs are running M try to - get at least
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.2 i one RCP ready for bump.
.3 2 the RCS is saturated ensure that SG 1evels b u-F %
are being maintained a 381 EFIC levet _ 10.0 2 RCPs ARE OPERABLE M GO TO STEP 12.0 OTHERWISE CONTINUE. 11.0 RESTORE HEAT TRANSFER WITHOUT RCPs.
.1 Iower OTSG pressure until secondary Tsat is 40 - 607' lower than Incore temperature.
.2 2 the RCS is subcooled
.1 Open the Hot bg HPVs and maintain RCS pressure.
I .2 Lower OTSG pressure until secondary Tsat is 90-1007 h
. Iower than Incore temperature. ..
.3 Verify OTSG 1evel is at 381" EFIC level ;
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.3 2 the RCS is saturated ']
.1 Maintain OTSG Tsat is 40-807 lower than Incore temperature.
.2 Verify OTSG 1evel is at 381" EFIC level ,
h E heat transfer has been established M go to step 16) DIFF 9
.5 2 heat transfer has E heen established M close the Hot lag HPVs, if open, and continue cooldown with steps 1.0 through 8.0 of this procedure.
12.0 RESTORE HEAT TRANSFER WITH RCPs
.1 lower OTSG pressure until secondary Tsat is 40 - 807 -
lower than incore temperature. (. _. Rev. 4 CP.104-2 CP-45 ._ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ ______--___-__._.__m._
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.( 12.2 E the RCS is subcooled M l
.1 Verify closed TBVs and ADVs. .
1 I
.2 Start .Q1E RCP. Preferred starting sequence- is D, B,~ A. C.
.3 Iower OTSG pressure until secondary Tsat' is 40-607 lower j than Incore . temperature. j i
.3 E the RCS is saturated 50.3 A BUMP MEANS START THE PUMP, A110W STARTING CURRENT TO DIE OFF. THEN ALLOW THE PUMP TO RUN FOR 10 SECONDS BEFORE STOPPING. ]
.1 Bump one RCP every 15 minutee until all operable RCPs have been bumped. -
.2 - Iower OTSG preneure until secondary Tiat .is 90-1007 lower than Incore temperature.
DIFF ) L3.0OTHERTISE 2 HEAT TRANSFER IS ESTABLISHED M GO TO STEP .!o g CONTINUE. DH16.Q rpr 11 ,( 14.0 2 AT LEAST ONE HOUR HAS PAMMED SINCE Hr' TRIP AND A'iYMP j IS CAPABLE OF BEING STARTEDL EVEN IF RCS IS SATURArsg7 Tf4EN 5" ART AND RUT C NE RCP r==:=w>wLY IN Tus wur wnaas hag /THE OTS gp Lu .ui 1= wm> , .i LEVEL.
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15.0 2 HEAT TRANSTER HAS NOT BEEN. ESTABLISHED M CONTINUE C00LDOWN YITH STEPS 1.0 THROUQH 8.,0. OF THIS PROCEDURE. 16.0 .M HEAT TRANSFER HAS BEEN ESTABLISHED M ADJUST 1 TBV / ADV POSITION TO CONTROL C00LDOWN RATE -Y! THIN LIMITS. y L7.0 2 ADEQUATE SCM EXISTS (G IDELINE NO.10F E.02) M i GO TO CP.105, OTHERWISE CONTINUE.
- 1 18.0 GO TO CP.103.
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(.~ Rev. CP.104-3 CP-46
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'. ATOG TO E0P COMPARISON CP.105 DIFFERENCE 1: s Step 1.0 of ATOG CP.105 directs the operator to close HPVs, if open.
CP.105 of the EOPs has had this step deleted (Rev. 3) because it would - not apply for those E0Ps that direct the operator to CP.105. This is because specific direction regarding operation of the HPVs has been-directly incorporated into these E0Ps. The related E0Ps and applicable steps are: ! E.04, steps 11.2, 11.4, 11.5 E.06, steps 14.2, 19.1, 19.1.2, 22.2 DIFFERENCE 2: EOP CP.105 provides extra direction to step for adjusting HPI flow to j ensure operator remembers there are other applicable limits he must J also observe.
, DIFFERENCE 3:
I E0P CP.105 requires normal makeup be reestablished as well as normal letdown in order to allow one operator to have total volume control at one station. Otherwise, two operators vould be required: one at HIRC for letdown and one at H2SFA/B for HPI-DIFFERENCE 4: ! ATOG CP.105 has the operator close the EMOV and then reestablish let- 1 down. E0P CP.105 is reversed to provide a method for reducing RCS pressure, if necessary, when the EMOV is closed without having to adjust HPI. Again, this enables one operator to have total control, thereby preventing inadvertent difficulties due to coordination / communication problems. DIFFERENCE 5: ATOG CP.105 step 4.4 direction is essentially ide.ntical to step 4.1. No corresponding E0P CP.105 step exists because it is deemed unnecessary. DIFFERENCE 6: E0P CP.105 contains extra direction for the operator to ensure all pressurizer vents are closed both normal and ' emergency.' This direction is a precautionary measure to ensure all pressurizer fluid discharge paths that allow non-recoverable mass be lost from the RCS ( are isolated. CP-47 - - - , - - _ _ _ _ _ - - _ - - - - - _ _ - - - - - - - , - - - - - _ _ - _ - - _ _ _ _ . - - _ - _ . - - _ - - - - - - - .- - - - . _ - - - - - - - - - -J
1 il ATOG TO E0P COMPARISON CP.105
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DIFFERENCE 7: 4 E0P CP.105 contains extra direction.for RCS pressure control methods available that is not contained in ATOG CP.105. This E0P CP.'105 step j acts to summarize for the operator what pressure control l methods. ] should be available,to him so'he can ensure actual plant conditions :.' agree in this respect to those recognized for use in'the procedure. DIFFERENCE 8: EOP CP.105 steps 5.'2, 5.3'and 5.4 provide specific direction for steam = bubble formations not found in ATOG'CP.105. The EOP.CP.'105 directs the operator to continue cooling down which, in addition to providing, desired direction for overall plant control, will enable a pressurizer bubble to be formed earlier, j Direction to control SCM is presented as a reminder.to the operator since, due to the simultaneous operations being performed at this time, it will bear close watching. Per E0P CP.105 pressurizer bubble formation is allowed once an RCS-to-pressurizer temperature difference of at least 50*F is attained. This ensures adequate SCM once the bubble is. formed. The ATOG CP.105 compares RCS temperature to a corresponding saturation temperature for' ( existing RCS pressure. This method won't necessarily ensure adequate SCM after bubble formation because the pressurizer may not be'in equilibrium. If system pressure is being held up because of volume control a bubble could be formed at too low a pressure, possibly violating SCM requirements and resulting in full HPI initiation once again. DIFFERENCE 9: i EOP CP.105 contains a CAUTION concerning operation of HPI mini-flow ! valves and the MUT outlet valve. The addition of this CAUTION was to address, in part, the incorrect equipment operations that took place
]j during the December 1985 transient that resulted in equipment damage. J Its presence is to provide plant specific direction that is outside the scope of ATOG.
DIFFERENCE 10: ATOG CP.105 directs that a pressurizer level of 220" be established following bubble formation while E0P CP.105 correctly requires 100" to comply with plant specific requirements for the mode of operation in effect. i s CP-48 J lj
ATOG TO E0P COMPARISON CP.105 DIFFERENCE 11: ATOC CP.105 steps 8.1 and 8.2 require a 30'F subcooling margin be maintained during the cooldown and, if not, then. maintain maximum HPI. E0P CP.105 provides specific direction for how to control SCM as.well as all applicable pressure limits to be followed. If the direction of ATOG CP.105 were followed the Fuel-in-Compression limits, at the least, would be violated during some portions of the cooldown. DIFFERENCE 12: ATOG CP.105 requires isolation of letdown in step 8.3, however, E0P CP.105 only requires letdown icolation if required to maintain SCM. By allowing the operator use of normal letdown, his control of the ,. solid RCS is enhanced, thereby reducing the potential for large pressure I swings that may result in loss of the controlled solid plant evolution l (e.g. losing SCM). i DIFFERENCE 13: ATOG CP.105 step 8.4 directs the operator to specific Rule 2 which addresses HPI Flow Control. There is no corresponding E0P CP.105 step because this direction is incorporated in E0P CP.105 step 7.0. ( DIFFERENCE 14: E0P CP.105 step 8.4 containa extra direction not found in ATOG CP.105 1 > for a cooldown procedure reference if RCPs are not operating. It is possible to go through CP.105 on natural circulation if RCPs cannot be run, thus it is proper this guidance exist for this situation. 1 ! CP-49
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8WNP.20007.2(5 43)- BASCOCK & WILCOX uittifY POWER G ENER A flC N 04 VISION NUMt ER
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74-1127469-00 ,(. TECHNICAL DOCUMENT CP-105 TRANSIENT TERMINATION FOLLOWING AN OCCURRENCE THAT MAY REQUIRE PRESSURIZER RECOVERY SOLID PLANT C00LDOWN WITH OTSG REMOVING HEAT AND RCS SUBC00 LED 1.0 E THE HIGH POINT VENT VALVES. HAVE BEEN OPENED, THEN CLOSE ALL RIGH g POINT VENT VALVES (HV 20533, HV 20534, HV 20535, HV 20536). .
.1 2.0 IF THERE IS A BUBBLE IN THE PRESSURIZER, GO TO - CP-102, 0THERWISE
. . CONTINUE.
3.0 START RCP's. 3.1 E any RCPs are running, THEN go to Step 4.0, otherwise . continue. I 3.2 E natural circulation is in progress, THEN start RCP's per OP A . 2 ,. RCP System. One operating RCP per loop is desired. f _ 4.0 CONTROL HPI FLOW. I
.s j 4.1 Adjust HPI flow to remain as hose as possible to the adequate subcooling margin in the RCS. --
4.2 close or verify closed EMOV and EMbV block valve - (HV-21505). 4.3 Establish letdown flow. IFF 4.4 controt HPI .nd leedown etow co remain as close possible to the adequate subcooling margin. 1 i 5.0 IF THE DECISION IS MADE NOT TO TRY TO ESTABLISH A BUBBLE IN THE PRESSURIZER, THEN PROCEED, WITH A SOLID PLANT C00LDOWN, STEP 8.0. 6.0 ESTABLISH A BUBBLE IN THE PRESSURIZER. 6.1 Turn on all available pressurizer heaters. A Section CP-105 CP-50 DATE: 10-8-82 PAGE 57
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l sAscocK & WILcox-UTILITY POWER GENERAllCN DIVI $lON NUM$tt l TECHNICAL DOCUMENT 74-1127469-00. D ( 1 pgp 6.2- Monitor the increase in pressurizer water temperature until pressurizer. temperature reaches saturation for the existing RC pressure. At this point, lower pressurizer level to form a steam bubble. f D\PF 6.3 When a bubble is established in the pressurizer, lowerthe) pressurier level to approximately 220 inches [ , 7.0 GO TO CP-102. ) 1 I
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CP-51 f Section CP-105 DATE: 10-8-82 PAGE 58 h
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BASCDCE & WILCOX UTILITY POWtt GENERAflON DIVIS10N NUMSER
-{ECHNICAL DOCHENT 74-1127469-01
--SOLID PLANT COOLDOWN 1
1
.i 8.0 CONTROL HPI.
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Maintain the RCS about 30F colder than the adequate sub- (01) 3 tFF '[8.1 cooling margin by chroetling HPz. SC
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8.2 . E the RCS temperature cannot be maintained about 30F colder than the adequate subcooling . margin, THEN maintai maximum HPI flow. [ 8.3 Close letdown isolation valve (SFV-22009) . h4 See Specific Rule D gp p: 9 .0 BEGIN C00LDOWN. 9.1 Using small incremental steps, open the turbine bypass valves to attain a cooldown rate such that adequate subcooling margin is not violated. 9.2 Further adjustment . of HPI flow and . turbine bypass valve J'
,/ position should be accomplished so as to maintain the. ~
cooldown race less chan 100F/hr while maintaining adequate i subcooling margin. 9.3 ga small break LOCA has occurred THEN continue with . i CP-103 STEP 11.0 as necessary. e. , 9.4 Continue cooldown while attending to overall plant cool- 'I down per OP B.4, Section 5.0.
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,j CP-52 Section CP-105 nCru- . .. _
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' EFFECTIVE DATE
, 06-22-87 "I ~ Rev. 3 '
CP.105 TRANSIENT TERMINATION F011DWING AN OCCURRENCE THAT MAY. I REQUIRE PRESSURIZER RECOVERY SOLID PLANT C00LDOWN.. wrrg OTsc R1rMOVING MEAT AND 'RCS SUBC001 kn 3* 1.0 2 THERE IS 'A BUBBLE IN THE PRESSURIZER M GO TO CP.102, OTHERWISE CONTINUE. 2.0 START RCPs.
.1 2. any RCPs - are running M go to Step '.3.0, otherwise continue. ,
.2 2 natural circulation is in _ progress AHD.RCPs are operable M start .one RCP per loop, per OP 'A.2,'.
otherwise continue. 3.0 CONTROL HPI FIDY. D IFF Calm 0N d PRIOR TO THROTI' LING HPI FIDW BELOW'105 GPM PER PUMP, HPI MINIFLOW VALVES STV-23845, STV-23646 AND MAKEUP TANK OUTLET STV-23508 MUST
/
n ( BE OPEN. ] j 4( Adjust HP1 flow to remain as close as possible to the
.1 .
adequate subcooling margin in the RCSJwhile observmg ypp1 - - Q m ena rusi-m-compression n=ts. (RULE 6) :
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hpp . Establish letdown /gakaup flow 3gpp 3' i i .3 Close or verify closed. EMOV and EMOV block valve (HV-21505). [.4 Close or verify closed, pressurizer vent valves HV-21515 l DiFF- , I and MV-21517.
.5 Close or verify closed ' pressurizer vent valves HV-21528 -
1 and MV-2tS22 on panel H2SP. , b Control RCS SCM wiU1:
.t HPt throttung. 'D )FF 7 l
.2 Makeup / letdown flowrate. h 4,- .3' OTSG cooling. j 4.0 2 THE DECISION IS MADE HQI TO TRY TO ESTABLISH A BUBBLE IN THE PRESSURIZER. M PROCEED WITH' A SOLID '
PLANT C00LDOWN, STEP 7.0. (. Rev. 3 -- CP.105-1 CP-53 I l
l
, J 3* 5.0 ESTABLISH A BUBBLE:IN' THE PRESSURIZER.
.1 Turn on all available pressurizer heaters. _
Control RCS SCM. ! f.2
.3 Continue cooling down the RCS, DO NOT exceed 100*F/hr.
D \fF DO NOT violate PTS limite (RULE. 6). Q
.4 Monitor. pressurizer temperature and incore temperature.
.1122[ pressurizer water temperature is 2 50* 1 above Incore temperature, lower pressurizer level to form -
a steam bubble.
.5 .E122[ a bubble is established in the pressurizer. lower DtFF 10 pressurizer level to approximately.100 inches.
6.0 GO TO CP.102.
- 7. 0 CONTROL HPI.
RULE 2)) :DiFF 13
- [.1 Maintain adequate SCM while observing PTS and } .
Fuel-in-compression limits. -
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.2 Control RCS SCM with:
(
.1 HPI throttling. )l F F .d 1 ;g _
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.2 Makeup / letdown flowrate. .
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.3 OTSG cooUng. .l
.3 Jose letdown isolation valve SFV-22009[necessary to) DIFF 11 4 r.am ausquai.e succooung margm.7 l
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, Rev. 3 i
' CP.105-2 c- !
CP-54 l
l b, 8.0 BEGIN C00LDOWN.
.1 Using small incremental steps, open the turbine bypass valves to attain a cooldown rate such that adequate subcooling margin is not violated.
.2 Further .adfustment of HPI flow and turbine bypass valve position should be accomplished so as to maintain the cooldown rate less than 1007/hr while maintaining adequate subcooling margin.
.3 E a small break LOCA has occurred, IEEN continue with CP.103, Step 11.0 as necessary.
3 -> .4 to overall plant Continue coeldown cocidown ner OP R4.while attending Section 5.0 (RCPs operating) or
<r Qction 8.0 (RCPs HQI operatingg g J
'Y e
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i d i e CP-55 END k Rev. 3
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CP.105-3 I % .....___________._-__._.__m._.___
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i ATTACHMENT-3 E0Ps Writers Guide l AP 2.24 s 4 l l l l' l l 1 i I u _ _ _ _ _ _ _ . _ _ _ _
Ll-j t
' EFFECTIVE DATE:
11-20-87. f Rev.1 -
]
WP0936P- l D-0026P AP.2.24 l EMERGENCY OPERATING PROCEDURES WRITERS GUIDE , l 1 1.0 PURPOSE i i 14 The purpose of this document is: ,l j
. to provide administrative and technical guidance in'the preparation of E0Ps.
. to facilitate a simple consistent format that can be easily read and followed by the operator.
. to ensure Emergency Operating Procedures (EOPs)-Consistent with the g l
- Emergency Operating Procedures Technical Basis Document (T80).
2.0 REFERENCES
i 2.1 Guidelines for the g Preparation of Emergency Operating Procedures NUREG' 0899 2.2 Emergency Operating Procedures Writing Guideline INP0 82-017, July 1982 [ 2.3 Rancho Seco Writer's Guide, AP.2.10, Rev. 0 2.4 Verification of Emergency Operating Procedures, AP.2.05, Rev. 0 2.5 Validation of Emergency Operating Procedures, AP.2.06, Rev. 0 14 2.6 Operations Procedures, AP.23.06, Rev. 1
+ 2.7 Emergency Operating Procedures Technical Basis ~ Document. ;
i j 3.0 DEFINITIONS E0Ps procedures that govern the plant operation during emergency , conditions and specify operator actions to be taken to return 'the plant ' to a stable condition. Contingency action - operator actions that should be taken in the event a stated condition, event or task does not produce the expected result. Rev.1 AP.2.24-1
gg f { 4.0 PREREQUISITES None 5.0 PRECAUTIONS 5.1 Where there are differences between this procedure and AP.2.10, this procedure shall supersede AP.2.10. 14 5.2 This writers guide is intended to produce a procedure which is concise and clear. If required application of one or more provisions in this procedure to a step or a part of an E0P doesn't produce the intent, then deviations are allowed. Deviations shall be identified in writing by the E0P writer and approved or, an individual basis by the Project / Procedures Operations Superintendent. (See Enclosure 8.1) 6.0 PROCEDORE 6.1 Maintain the Technical Basis of the E0P's Policy. The E0Ps have been written based on technical information including the B&W Technical Basis Document (TBD) and the Rancho Seco Abnormal Transient Operating Guildeline ( ATOG). The reference document shall be the TBD: E0P actions which are deviations from the TBD shall be identified, justified, and appreved with an appropriate basis; such as additional 3 evaluation, site specifics, training, B&W advisories, or experience using the E0Ps. There are E0P actions in addition to those of the TBD which are written to site specific requirements. These actions are not deviations from the TBD. These do not require justification as discussed above although it is desirable to document the basis for these actions. 6.1 .1 Documentation and Approval of the E0P Basis 6.1 .l.1 A document titled " Rancho Seco E0P Technical Basis" (EOP-TB) shall be maintained which implements the above Policy. This document includes a Logic Comparison and Text Comparison which assures that, and documents how the E0Ps implement the intent of the TBD. 6.1 .l.2 Logic Comparison This is a comparison of the TBD logic to the E0P logic. This may be accomplished by comparison of TBD and E0P flow ;
- charts or other suitable methods.
Re v .1 AP.2.24-2
I I PROCEDURE (Continued)
.d 1+ 6.1 .l.3 TBD to E0P Content Comparison This is a comparison showing how the TBD text actions are implemented by E0P stcps. Comparison shall be made to the j following TBD parts
- i I
. III Diagnosis and Mitigation ]
. IV Equipment Operations 1
- V Specific Rules Comparison of parts I " Introduction" and II " Symptom j Approach" is not necessary because they present an overview !
of the remaining parts. The final part is VI, " References." ) 6.1 .l.4 Description of Change l This section describes the reason for every change made to j the E0Ps by a revision. This section should " stand alone" ; so that future procedure writers clearly understand why changes were made, thus assuring that future revisions do not inadvertently alter the E0P intent. ] 6.1 .1.5 The E0P-TB shall be prepared by the Operations Procedures and Projects Superintendent, and approved by the Manager, Nuclear Operations Department.
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6.1 .1. 6 The E0P-TB shall be updated and approved concurrently with each E0P revision. 6.1 .2 E0P Revision Process -i E0P revision may be prompted by changes to the TBD or other E0P basis, operating experience, plant modifications, etc. 6.1 .2.1 The TBD and other E0P bases do not integrate all operating procedures, plant specific design, operator training, shif t manning and all other operator actions, thus the E0P writers must apply the technical basis appropriately in the E0PS. ) l 6.1 .2.2 Writing Process 6.1 .2.3 Prepare the draf t E0P revision, including flow chart, if any. 6.1 .2.4 Prepare a revised E0P-TB. 6.1 .2.5 Proceed with E0P approval per AP.2 process, simultaneously obtaining E0P-TB approval. i Rev.1 AP.2.24-3 i i
1 a 1 PROCEDl'RE (Continued) 6.2 EGP Designation and Numbering o 1++ Each procedure shall be uniquely identified.- This identification permits easy' administration of the process of procedure preparation, review, revision, distribution, and operator use. j ( 6.2 .1 Procedure Designation q 14' Designation of the emergency operating procedure'shallsbe E. Rules'
- shall be designated by the word " Rule" followed by a single digit.
6.2 .2 Procedure Numbering . 14 A sequential number'will fol' low the procedure designator.' Example: Procedure Designator
- E 0,,1 + Sequence Number.
- Rule Designator'
- Rule le Sequence Number-6.2 .3 Revision Numbering and Designation i
.g 6.2 .3.1 Two digits following.the abbreviation "Rev" will be used to designate the revision level'of the emergency operating.
procedure. Example: " Abbreviation + Rev 01 e' Revision Level" 6.2 .3.2 To identify revisions to th'e text'of,an E0P,'a change arrow I will be located in the left margin alongside the text-change,' preceded by'the Rev. number. 6.2 .3.3 Upon issuance of a new revision,'the arrows in.the margin.of the previous revision will be omitted. 6.2 .4 Page Identification and. Numbering Each revised page shall be numbered with the alpha numeric identification of the procedure followed by the page number. :A period will separate the alpha numeric identification number. A l dash will separate the alpha numeric identification number and page L number. i 6.2 .5 Title The title shall be a clear unique title that includes.the scope of the procedure to make it easier for an operator'to' identify a'given procedure, and will be located'at the top of each operator action, page of the procedure and preceded by its E0P number. I I Rev.1 AP.2.24-4 1 1 L__-______-_-_-____-____=___ .. _ _. -Y
PROCEDUREE (Continued)
.i' 6.3 Fo rmat A two page format will be used except for E.01, "Immediate Actions".
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The right page will contain the actual procedural steps which are' to be performed by the plant operators in order to control and mitigate plant transients. The left page will contain supplemental-information which is not required for the performance of the procedure, but may. enhance. the operator's understanding of it. ; 6.3 .1 Cover Page ,. 6.3 .l.1 The cover page will contain the emergency procedure alpha numeric designator.and title at the top of the page. 6.3 .1.2 The cover page may.show a figure of a typical _SPDS trace for a heat transfer upset which would require the-use of the procedure. Procedures which are not entered as a result'of an SPDS trace, such as E.06 "SGTR", will have no figure on the front. 6.3 .l.3 E.01, "Immediate' Actions" consists of only one page and will not have a cover sheet. 6.3 .2 Information Page-6.3 .2.1 Tdeleftpageinthetwopageformatwillbelabeled "Information Page" at-the top of the page. : 6 1++ 6.3 .2.2 The information page may contain information which is useful as training material, provides supplementary information-about procedural steps, highlight applicable rules, and- , display figures which illustrate SPOS traces typical of i those accompanying,the applicable transients. l 1++ 6.3 .2.3 The informational steps should be located directly across the page from the procedural step it relates to, as'much as- ' possible. They will also be numbered to match the procedural step to which they apply. , 6.3 .3 Operator Actions Page 6.3 .3,1 The~right page in the two page format will be' labeled at the tcp of the page with the alpha numeric. designation of the procedure and the procedure title. i 6.3 .3.2 The required operator action will.be provided on the right page. The steps will be provided in short, concise, identifiable instructions that give appropriate directions; to the user. Rev.1 AP.2.24-5
d j PROCEDURE (Continued) 6.3 .3.3 The main steps of the' procedure will be~ printed in RED' extra large capital letters. The more detailed substeps will-be .l printed in normal size letters with black ink. The intent' of the large red lettering is to emphasize the main . action
]
=1 14 of the step or the entry condition for substeps. The substeps are' written in more detail should the operator need m
+- that to perform the main step.
6.3 .3.4 Cautions shall be' printed in blue capital'1etters with' a blue. box enclosing the caution. This. emphasizes.the caution and decreases the possibility of it being overlooked if the reader branches to a step after the caution. 6.3 .3,5 Headings and status information wil1~be on the.right page' with a line above and below them. They will be in all capital letters. 6.3 .3.6 Steps will be numbered in arabic numerals with indentation for each level of substeps. (except STATUS steps and the 14 associated are numbered per Section 6.3.3.8. EXAMPLE: 1.0 Start an HPI pump....
- 1. IF...............
- 2. THEN.............
2.0 Verify............... ) 6.3 .3.7 Status steps describe the plant conditions which exist at .;' that point in the E0Ps and may be provided as necessary to aid.the operator in following the procedure. Typical places to consider placing a STATUS is at' a major branch point (ie. just prior to "GO T0" statement), at step "gone to" if several GO T0 steps point there, and at the end of procedure branches. 6.3 .3.8 Status steps normally will carry th'e same step number as the-associated action step, but with a different digit'after the I decimal to distinguish it. EXAMPLE: "GO TO Step" 23.0 STATUS: The RCS is SATURATED with the OTSGs removing heat. 23.1 GO TO E.04 Step 7. EXAMPLE: "Gone to Step"
7.0 STATUS
The RCS is SATURATED with the OTSGs removing heat
+ 7.1- INITIATE HPI i
a Rev.1 AP.2.24-6 '
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I PROCEDURE (Continued) .
,j 14 EXAMPLE: "GO TO in a Substep" 18.0 INITIATE HPI COOLING
.1 Open.EMOV Block Valve. 3
.2 -Open EMOV- ]
.3 STATUS: Core Cooling,is provided by j HPI Cooliag. d
+ .3.1 GO TO E.04 Step 7.0 ,
6.4 Writing Instructional Steps ! I 6.4 .1 Instruction Step Length and Content Instruction ste'ps'will be concise and precise. Conciseness denotes brevity; preciseness means. exactly defined. Thus,. instructions should be short and exact. This is easily stated, but not so easily achieved. General guidelines to be used in meeting these objectives are as follows.: 6.4 .1.1 Instruction steps should deal with only one' idea. 6.4 .l.2 Short, simple sentences should be.used in preference to long, compound, or complex sentences. 6.4 .1.3 Three or more evolutions should be prescribed in a. series of stdps, with each step made as simple as practicable. 3 6.4 .1. 4 Objects of operator actions should be specifically stated. This includes identification of. exactly what is to be done and to what. 6.4 .1. 5 For instructional steps that involve an action verb relating to three or more. objects, the' objects will be. listed. 6.4 .1.6 Limits should be expressed quantitat'ively.whenever possible. 6.4 .1.7 Mandatory sequence of steps is assumed unless otherwise i stated. (Ref. 2.6 "Use of E0Ps") ! 6.4 .l .8 Identification of components and parts should be complete. List the noun name (or. standard abbreviation), number and i' 14 verify that they agree with Control Room labeling. ' Major components may not need to include all label information'if doing so would clutter the procedure in a way'to slow or interfere with operator understanding and if there is- il minimal chance for error. l EXAMPLE: Start RCPs A and B '! is preferred over .
- START RCP P210A and P210B.
Rev.1 AP.2.24-7 : l
r , k, PROCEDURE (Continued). 6.4 .1.9 Instruction content should be written to communicate to -s the user. 6.4 .1.10 Expected results of routine tasks need'not be stated. (
'6.4 .1.11 When actions are' required based upon rece'ipt of an annunciated ~ alarm, list the setpoint of thel alarm for ease 4 of verification.
6.4 .l.12 When requiring resetting or. restoration'of'an alarm or trip, j list the expected results immediately following the- ) resetting or restoration if it would_be beneficial to the j operator. a 6.4 .1.13 WhenconsideredbeneficialTtothe.userforproper ~ l understanding and performance, ' describe the system response l time associated with p'erformance.of the instruction. 6.4 .l.14 When system response dictates >a time frame within which the instruction must be accomplished, pre. scribe.such time. ! frame. If possible, however,. avoid using time to initiate 1 operator actions. Operatctr actions should be.related to i plant parameters. 6.4 .l.15 When anticipated system response may adversely affect. .j ins'trument indications, describe-the conditions that will likely introduce. instrument error and.means of. determining )- if instrument error has occurred within the procedural steps or with a caution statement.~ 6.4 .l.16 When additional confirmation of system response-is. considered necessary, prescribe the backup readings to be i made. .l 6.4 .2 Contingency Actions 4 6.4 .2.1 Contingency actions will be presented, when applicable, following detailed action. The need for contingency action occurs in conjunction with tasks involving verification, observation, confirmation,'and monitoring. Contingency-actions will most frequently be.in an "IF-THEN"
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. format. Exceptions to'this for:nat will need written i justification for the procedure history file. ;
~Rev.1 !
AP.2.24-8'
a n 1 PROCEDURE. (Continued) l Use of Logic Terms 6.4 .3 6.4 .3.1 The logic terms:AND, OR, NOT, IE, IF NOT, WHEN, and THENiare'
!often necessary to describe precisely a set.of conditions ors q sequence of actions. When logic. statements are used, logic: a terms will be highlighted.so.that all the conditions are clear-to.the operator. Emphasis will be achieved by using: ,
capitalization and underlining. All letters;of the logic j-terms shall .be capitalized and the' words will be underlined. if they are used within a sentence. Logic' terms that; stand. l by themselves will be capitalized only.
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6.4 .3.2 The use of AND and OR within the same action shall be
- avoided. When ' AND and OR are used together, the logic can be very ambiguous.
6.4 .4 Use of Cautions 6.4 . 4 .1 Cautions shall extend across the page prior to the steps to which they apply. A caution cannot be used instead of an instructional step (it cannot contain an action step). It should be used to denote a potential hazard to equipment or personnel associated with the subsequent instructional step. 6.4 .5 Use of Notes 6.4 .5.1 If additional information other .than cautions is desired to support.an action instruction, a note may be used. A note shall present information only, not instructions, and shall be entered on the information page~ opposite the procedural 14 step. .The note should be numbered to match the step to
+ which it relates.
6.4 .6 Calculations 6.4 .6.1 Mathematical calculations shall not be used in E0Ps. If a value has to be determined in order to perform a procedural 14 step, a chart or graph shall be used. The one. exception is is the calculation of offsite dose relating to OTSG isolation
- limits in E.06.
l l l l Rev.1 ! AP.2.24-9 -i _ _ _ _ _ _ _n
a PROCEDURE (Continued) 6.4 .7 Plant Instrumentation Values 6.4 .7.1 When presenting instrumentation values, provide a band'if possible (tolerance or limit). Values shall be presented in the same units as those displayed on the instrument to'be-used and should be compatible with the operators ability to read the instrument. 6.4 .7.2 Always use conservative values within the precision of the- . operator to read it. Example: If an upper engineering limit is 22.75 psig, however the operator can only read 22'.7 or 23 psig on the meter with precision, then use the limit of 22.5 6.4 .8 Component Identification With respect to identification of components,.the following rules are to be followed: 6.4- .8.1 Equipment, controls, and displays will be_id'entified by 14 their noun names (or standard abbreviations) and by their equipment. identification number except as noted in 6.4.1.8
+ of this procedure.
6.4 .8.2 The names of plant system titles are_ emphasized'by initial capitalization. When the word " system" is deleted from the title because of brevity and is understood because of the 4 context, the title is also_ emphasized by initial capitalization. I 6.4 .8.3 If the component is seldom used or it is felt that the component may be difficult to find, location information may I be given in parentheses following the identification, or in i an information page note. s 6.4 .9 Use of Underlining 6.4 .9.1 Underlining will be used for emphasis, primarily for logic l terms. 6.4 .10 Referencing and Branching to Other Procedures or Steps Rev.1 AP.2 24-10 ,
I a PROCEDURE (Continued) E
- 6.4 .10.1 Referencing .(Refer to, In Conjunction with...) implies that an additional procedure or additional steps Will be used'as a supplement to the procedure presently being used. H 14 Referencing 2in: E procedures is not' allowed. The operator. If must perform the E. procedure without using other procedures q (except rules).
+
6.4 .10.2 To minimize potential operator confusion,' branching'will be.- used when the' operator is to leave one' procedure or step and use another procedure or step. Use the key words "go'to." Therefore, the operator will know to-leave the present step and not return until directed. 6.4 10.3 Use quotation marks to emphasize the title of the referencedD or branched procedure. Example: Go to E-01, "Immediate Actions". 6.4 .11 Level of Detail 6.4 .11.1 Too much detail in E0Ps should be avoided in the: interest of being able-to effectively execute the instructions ~in a timely manner. The level of detail required is the detail that a recently licensed operator would desire'during an emergency condition. 6.4 .12 The following action VERB INSTRUCTIONS should be used in writing g E0Ps. 6.4 .12.1 For power-driven rotating equipment, use Start, Stop. 6.4 .12.2 For valves, use Open, Close, Throttle.Open, Throttle Close, 1+ Throttle. (Ref. 2.6 "Use of the term Throttle and
- Terminate")
6.4 .12.3 For power distribution breakers, use Synchronize and Close, Open. 6.4 .12.4 For control switches with a positional placement that establishes a standby readiness condition, the verb " Place" should be used, along with the engraved name of the desired , position. Positional placements are typically associated I with establishing readiness of automatic functions and are typically labeled AUTO or NORMAL. j] Example: " Place the GLAND SEAL AIR COMPRESSOR Control Switch (515) in AUTO." i Rev,l. AP.2.24-ll 3
PROCEDURE (Continued) l ' 6.4 .12.5 For multiposition control switches that have more than one position for a similar function, placement to the desired , position should be specified. Example: " Place DIESEL FIRE PUMP SELECTOR Switch to TEST' No. 2." 6.4 .12.6 Standard practices for observing for abnormal results need not be prescribed within procedural steps. For' instance, observation of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps. 6.4 .13 Graphs, Tables, etc. 6.4 .13.1 When information is presented using graphs, charts, tables, and figures, these aids must be self-explanatory, legible, and readable under the expected conditions of use and within the reading precision of the operator in units common to operator and his instrumentation. 6.4 .14 Units of Measure 6.4 .14.1 Units of measure on figures, tables, and attachments should be given for numerical values that represent observed, 14 measurement data, or calculated results. A slant line
- should be used instead of "per".
1 Examples: ft/sec, lbs/hr. The objective is to ensure that conversions do not have to be made by the operator. 6.4 .15 Titles and Headings 6.4 .15.1 Capitalization should be used for references to tables and figures, titles of tables and figures within text material, and column headings within a table. 1 Examples: Refer to Figure 201 for.............
. . . . . . .as shown in Table 201, Equipment i Power Supplies, the........
6.4 .16 Figures, Table, and Attachment Numbering 6.4 .16.1 Sequential arabic numbers should be assigned to figures, tables, and attachments in separate series. The sequence ; should correspond with the order of their reference in the i text. The symbol "#" and abbreviation "No," are unnecessary and should not De used. The number alone suf fices. Examples: Figure 1 Table 1, Attachment 1. Rev.1 a AP.2.24-12
I PROCEDURE (Continued) 6.4 .16.2 Page identification for attachments should consist of a . block of information that identifies (1) procedure number, 1 (2) attachment number, (3) page number, and (4) revision ! number. Page numbering of attachments should meet the requirements of 3.2.4. 6.5 Mechanics of Style . l l 6.5 .1 Punctuation l 6.5 . l .1 Punctuation should be used only as necessary to aid reading j and prevent misunderstanding. Word order should be selected j to require a minimum of punctuation. When extensive ! punctuation is necessary for clarity, the sentence should be { rewritten and possibly made into several sentences. . i 6.5 .2 Numerical Values The use of numerical values should be consistent with the following rules: 6.5 .2.1 For numbers less than unity, the decin.al point should be . preceded by a zero. l 1
. Example: 0 .1.
6.5 .2.2 The number of significant digits should be equal to the number of significant digits available from the display and the reading precision of the operator ~. 6.5 .2.3 Acceptance values should be specified in such a way that addition 'and subtraction by the user is avoided ,1f possible. This can generally be done by stating acceptance values as limits. Examples: 510'F maximum, 300 psig minimum, 580' to 600*F. Avoid using . 6.5 .2.4 Engineering units should always be specified for numerical l values of process variables. They should be the same as l those used on the control room displays. { Example: psig instead of psi. l l R e v'.1 AP.2.24-13 l
' PROCEDURE (Continued).
t 6.6 Tvoing Format 6.6 .1 General' Typing Instructions For emergency operating procedures, the following ' general requirements'are to be followed. 1 -+ 6.6 .1.1 Paper size should be 8-1/2 x 11 inches ("A" size).except
- Flow charts. .,
White paper;is to be used. 6.6 .1.2 6.6 .1.3 Procedures are.to.be typed,'or prepared on a plotter. N ~ 6.6 .l .4 Character size shall be consistent between headings,. cautions, substeps, etc. Characters may be scaled to fit in graphs and.other special areas. They should be sized for
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optimum clarity. 14 6.6 .1.5 Flow charts should fold out so the entire chart is visible with the Binder closed. (i .e. the lef t most 81/2 x-'11 page
+ is blank) 6.6 .2 Page Arrangement 6.6 .2.1 Pabemarginsaresetfromthepaperedge. 1/2 inch should be maintained between the text and: paper edge except.for the binder side where 1-1/2 inch should be used.
[ 6.6 .2.2 Page identification information (refer to Subsection 2.4). should be centered and 3/4. inch above the bottom of.the page. 6.6 .2.3 Horizontal lines shall be inserted between procedural steps 1 -* to aid the operator's movement through the procedure except. there shall be no horizontal line between STATUS and the , e associated step. ]
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6.6 .2.4 Line spacing shall be configured for optimum clarity. q 14 6.6 .2.5 Cautions and Status statements shall be on the'same'page as the associated action steps, q 6.6 .2.6 If at all possible each step, including substeps, should start.and end on the same page. If not possible the statement "This step continued on next page" should be'added
- at the bottom of the step /page. a 6.6 .3 Graphs , Tables , etc.
Figures include graphs, drawings, diagrams, and illustrations. The, following rules are established. ~ , Rev.1 A P . 2. 24-14
._ _ - _ _ _ _ _-______=w
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-l PROCEDURE..(Continued) ,
f 6.6 .3.1 The figure number and its title:are' placed above the~ figure-fiel'.d 6.6- .3.2 The-figure field should be of sufficient size to offer good readability. .( 6.6 .3.3 The essential message should be clear;; simple presentations are preferred. 6.6 .3.4 Grid lines of graphs should be a minimum of 1/8-inch apart, q l 6.6 .3.5 Labeling of items within-the figure should be accompanied by q arrows pointing to the item. .j l 6.6 .3.6 The itsms within the figure should be. oriented naturally .I insof ar as possible. For instance, height-on a graph.should be along'the vertical axis. 6.6 .3.7 In general, items within the figu~re should be lab'eled. i 6.6 .3.8 All line in figures should be reproducible. 6.6 .4 Tables should be produced using the following rules. 1 6.6 .4.1 Type, style and size should be the same as that.for the rest j of the procedure. , g 6.6 .4.2 The table number and title should be located abovetthe table field. i 6.6 .4.3 A heading should be entered for each column and centered within the column; the first letter of words in the column .I headings should be_ capitalized. 6.6 .4.4 Horizontal lines should be placed above and below the. column j headings; vertical lines, while desirable, are not necessary
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or required. 1 1 6.6 .4.5 Tabular headings should be aligned as follows: 6.6 .4.5.1 horizontally by related entries 6.6 .4.5.2 vertically by decimal point for numerical' entries - 6.6 .4.5.3 vertically by first letter for word entries; however, > run-over lines should be indented three' spaces 6.6 2 4.6 . Spacing between ho'rizontal entries suffices to segregate such entries. Rev.1 AP.2.24-15 _j
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( I PROCEDURE' (Continued) 6.6 .4.7 There should not-be a' vacant celluin.the' table. . ' I f - no' ' en t ry ;
.is necess'ary, "N.A." should be entered to' indicate'not. l applicable. l 1.+e 7.0 RECORDS -) 4 14 " Rancho Seco E0P. Technical Bases" document and to revisions ;shall' bei
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+ . submitted to Records' Management' for each E0P Revii s on. ]
8.0 ENCLOSURES 1 -++ 8.1 E0P Writers Guide Deviations i s s , 5
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i 1 Rev.1 AP . 2. 24-16 , j q
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1 i t ij ENCLOSURE 8.1 E0P WRITERS GUIDE DEVIATIONS: , ( E0P Number Justification: s
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( Submitted by Date Approval Date .; i ENCLOSURE 8.1 PAGE 1 0F 1 1 l END Rev.1 AP . 2. 24-17
i i l l l 4 j l i ATTACHMENT 4 1 E0P Validation and Verification Procedures j AP 2.06 and AP 2.07 4
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1 EFFECTIVE DATE j 08-18 i Original i WP0960P- I D-0028P. ( I AP.2.06 ) J VALIDATION OF EMERGENCY OPERATING' PROCEDURES 1 1.0 PURPOSE 1.1 .To ensure that the Emergency Operating Procedures (EOP) are compatible with the plant, operator training, and successfully mitigate emergency conditions. 1
2.0 REFERENCES
2.1 Emergency Operating Procedures Validation Guidelines INP0 83-006, July 1983 2.2 Component Verification and System Validation' Program AP.53, Rev. 0 ) 2.3 Verification 6 of Emergency Operating Procedures AP.2.05, Rev. 0 2.4 Guidelines for the Preparation of Emergency Operating Procedures, f ' l f' - NUREG - 0899, August 1982 I , g 3.0 DEFINITIONS 3.1 E0P Operational Correctness - A characteristic of E0Ps that indicates i the degree to which the E0Ps are compatible with plant responses, hardware, and the shift manpower to manage emergency conditions in the plant. i 3.2 E0P Source Documents - Documents or records upon.which E0Ps are based. j 3.3 E0P Technical Accuracy - A characteristic of E0Ps that indicates the degree to which proper incorporation of generic and/or plant-specific j technical information from E0P source documents and plant hardware has ' been made. i 3.4 E0P Usability - A characteristic of E0Ps that indicates the degree to' which the E0Ps provide sufficient and understandable operator information to manage emergency conditions in the plant. I l 3.5 E0P Validation - The evaluation performed to determine that the actions 1 specified in the E0P can be followed by trained operators-to manage the y emergency conditions in'the plant. I AP.2.06-1 I L-__--_-___
PROCEDURE '(Continued) .I
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6.2' Complex scenarios, adequate to~ bring critical safety. functions into. -] play, are necessary to. fully challenge the validity of a proposed procedure or procedure change. The scope of the scenario, its"use, and even the need for it, are determined by the Projects / Procedures Operations - Superintendent. 6.3 Through the validation process,'the elements of the Control Room Design. Review,-Human Factor Consideration,-specific equipment compatibility (e.g.. SPOS,.IDADS, EFIC), Operator Training, are all tested for proper interfacing as an integrated. system with the E0Ps. 4 6.4 . Validation may be performed'before or afte'r procedure approval (PRC, Nuclear Operations Manager) and validation can be performed in < conjunction with AP.2.05 (Verification of Emergency Operating. Procedure). 6.4 .1 Validation shall be re-performed on the E0P anytime a discrepancy is found during the verification process ( AP.2.05), if verification was not completed prior to sslidation. 6.4 .2 If validation is performed before approval, validation' comments may be incorporated into the draf t procedure prior .to approval. Final . validation of the approved procedure is cequired and shall be ' appropriate to the nature of changes made since the pre-approval validation, per 6.1. f .. 8,' 6.5 The Table Top Validation participants should consist of, but not be
' restricted to: \ )
6.5 .1 Projects / Procedures Operations Superintendent, 6.5 .2 E0P author, 6.5 .3 SRO certified Training Dept. member, 6.5 .4 Shift Supervisor from an on-shift' crew,- -l 4 6.5 .5 Assistant Shift Supervisor from an on-shift crew. 6.5 .6 Documentation of the Table Top Validation will be' accomplished by completing Record 7.1. Record 7.1 will contain the title (s) of the E0P being validated, a scenario, n<sme of members participating in validation, and the major points of the discussion. ) 1 6.5 .7 The Projects / Procedures Operations Superintendent will . lead the ' l Table Top Validation. He is responsible for providing the scenario j
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that will properly exercise the E0P to completion. He may. request the input of anyone that he feels could aid in developing a realistic scenario. 6.5 .8' Each scenario will be listed ori a separate Record 7.1. The e Projects / Procedures Operations Superintendent is responsible for
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i i the retention of all Record 7.ls for records. l AP.2.06-3 ,
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j 1 PROCEDURE (Coritinued) 6.7 .3 The' validation should be conduc'ted by three (3) observers as.a minimum number (the Projects / Procedures Operations Superintendent- ! and/or his' designees) and'a Rancho'Seco licensed operating team.- .
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l 6.7 .4- Each scenario will be evaluated per. Record-7.3. . Each observer will j conduct his own evaluation. 1 6.7 .5 The operating crew will not be. informed of the scenario.before the exercise. After the simulator session is complete, the observer.. q and crew will meet and discuss and evaluate the E0P adequacy of i each scenario run during the' simulator session. 6.8 Th'e E0P writer is responsible for the resolution of identified deficiencies. 6.8 .1 The Projects / Procedures Operations Superintendent.is responsible for ensuring all deficiencies.and resolutions are documented and. retained as a record of the Validation process. 6.9 Verification and Validation will~be considered ~ complete upon completion of Record 7.4 in AP. 2.05 and Record 7.5 of AP. 2.06. Significant' changes and/or revisions to any.of the Emergency Responsibility Capability function (i'.e., Physical Plant / Control Room, Training, EOF, E0P) in order to resolve a discrepancy may in itself require repeating the previous Verification.and Validation steps. This determination is 4 the responsibility of the Projects / Procedures Operations Superintendent. . 6.10' The Projects / Procedures Operations Superintendent has th'e responsibility of completing Record 7.5. The following items, as applicable,.will be attached to Record 7.5. 6.10 .1 Table. Top Validation. 6.10 .2 Walk-Through Validation. 6.10 .3 Simulator Validation. 6.10 .4 Discrepancy Resolutions 7.0 RECORDS 7.1 Table Top Validation 7.2 Walk-Through Validation, pages 1.through 3 7.3 Simulator Validation, pages.1 through 7 j i AP.2.06-5 t 1 1
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RECORD 7.1 TABLE TOP VALIDATION
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E0P Date Page of 1 i Scenario
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Names of Personnel Attending Discussion' i i i l Major Coments: < \ 1 1 1 Coments Resolved / Table Top Validation Satisf actory
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Projects / Procedures Operations Superintendent Date RECORD 7.l PAGE 1 of 1 AP.2.06-7 ,
RECORD 7.2 (Continued) l i WALK-THROUGH VALIDATION l
.3 Are the labeling, abbreviations, and location information as provided in the E0P sufficient to enable the operator to find the needed equipment?
Coments :
.4 Is the E0P missing information needed to manage the emergency condition?
Coments: ; (' .5 .Are the contingency actions sufficient to address the symptons? Coments:
.6 Are the titles and numbers sufficiently descriptive to enable the operator i to find referenced and branched procedures?
Coments : i i RECORD 7.2 PAGE 2 of 5 ) AP.2.06-9 1 I
RECORD 7 2 (Continued) ! WALK-THROUGH VALIDATION ! 1
.11 Are there alternate success paths that are not included in the E0Ps?
i Comments: j l 1
.12 Can the information from the plant instrumentation be obtained as i specified by the E0P? !
Comments: l l - 1
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.13 Is information or equipment not specified in the E0P required to )'
, accomplish the task?
't Comments: !
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.14 If time intervals are specified, can.the procedure action steps be ,
performed on the plant within or at the designat?d t~ime intervals? l Comments: l RECORD 7.2 PAGE 4 0F 5 AP.2.06-11 , 1 _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - . _ _ _ _ _ _ _ . .J
RECORD 7.3 SIMULATOR VALIDATION E0P Date Page of Scenario (Operating Crew is not to know the scena.-io.) ; I l l l ! 1 Evaluation Performed By Observer Crew
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.1 Are instructional steps sequenced so as to minimize operator shifting unnecessarily between panels?
I Comments: h i RECORD 7.3 PAGE.1 0F 7 ) I l AP.2.06-13 j l l l _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ .J
. RECORD 7 3 (Continued)
SIMULATOR VALIDATION
.6 is the intent or goal of the procedure clearly understood?
Comments:
.7 Is there smooth transition among procedures during referencing or branching?
Comments: (i
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.8 Are entry conditions and symptoms unique for the E0P so as to aid operator?
Comments:
.9 Do steps correspond to plant conditions?
Comments: ,.~ RECORD 7.3 PAGE 3 0F 7 ' AP.2.06-15 l __ _ ___ _ A
a s 2 1 I RECORD 7.3 (Continued) SIMULATOR VALIDATION !
.14 Are figures and tables clear and easily understood?. !
Comments:
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.15 Are. abbreviations and nomenclature clear and easily understood?
Comments: __,
. .16 Are instrument scales accurately and appropriately specified when needed 1 I and are they in the same unit'as the instrument and readable by the i operator? -\
Comments:
.17 Are there any communication difficulties caused by the procedure?
Comments: g- RECORD 7.3 PAGE 5 0F 7 AP.2.06-17 .
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- a; RECORD 8.7" (Continued)
' SIMULATOR. VALIDATION
.22 Overall Comments:
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l Resolution Satisfactory (Evaiuator) Projects / Procedures Operations Superintendent Date i' RECORD 7.3 PAGE 7 0F 7
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AP.2.06-19 1' ' I' r c
RECORD 7.5 VALIDATION COMPLETION E0P Title E0P Number Discrepancies Validation Initial No. OK No. OK No. OK No. OK Table Top I I Control Room Walk-Through l k: i s Simulator Date this E0P Approved for use by PRC All Validation has been satisfactorily completed for implementation. Projects / Procedures Operations Superintendent Date RECORD 7.5 PAGE 1 0F 1 (~ - END AP.2.06-21
4: EFFECTIVE DATE 08-18-87 Original. WP3795P D-0C25P AP.2.07 VERIFICATION OF EMERGENCY OPERATING PROCEDURE s l 1.0 PURPOSE - 1.1 The purpose of AP 2,07 is to verify the written correctness of the Emergency Operating Procedures as provided by AP 2.24, the Emergency-Operating Procedure Description and Format. 1.2 To verify the technical accuracy of the Emergen~cy Operating. Procedures when compared to Technical Bases Documents.
2.0 REFERENCES
2.1 NUREG 0737, Supplement 1 to Requirements for Emergency Response Capabilities 2.2 Emergency Operating' Procedures Verification Guideline (INPD 83-004), I March 1983 2.3 E0P Description and Format AP 2.24 l 2.4 Technical Bases Documents l l 3.0 DEFINITIONS 3.1 E0P Verification - The evaluation performed to confirm the written correctness of E0Ps and to ensure that the generic and/or plant specific technical aspects have been properly incorporated. 3.2 E0P Source Documents - Documents or records upon which E0Ps are based. 3.3 E0P Written Correctness - A characteristic of E0Ps that indicates the degree to which proper incorporation of information from the plant - specific writers guide for E0Ps and other appropriate administrative policies has been made. 3.4 E0P Technical Accuracy - A characteristic of E0Ps that indicates the i degree to which proper incorporation of generic and/or plant-specific l technical information from E0P source documents and plant hardware has been made.
,n AP.2.07-1 S
o c PROCEDURE- (Continued) 6.3 Verification Steps 6.3 .1 The verification will be: conducted in 4 separate steps. 6.3 . l .1 Written correctness 6.3 .l.2 Technical accuracy 6.3 .1. 3 Task Analysis ', 1 6.3 .l .4 Overall assessment and final approval 6.4 Written Correctness 6.4 .1 Written correctness verification shall be conducted by the Nuclear. Training Superintendent of Operations or his responsible designee. 6.4 .2 Verification of written correctness will be accomplished by completing Record 7.1-which is divided into.(5) areas. 6.4 .3 Each of the (5) areas shall be evaluated IAW Enclosure 8.2. 6.4 .4 Each discrepancy will be numbered and documented on Record 7.5 and listed on Record 7.1. I 6.4 .5 All discrepancies shall be. resolved and documented on Record 7-.5 and listed on 7.1 before written correctness is acceptable. 6.5 Technical Accuracy 6.5 .1 Technical accuracy verification- shall be. conducted by the STA Supervisor or his responsible designee. 6.5 .2 Verification of technical accuracy will be accomplished by. completing Record 7.2 which is divided into (4) areas. 6.5 .3 Each of the (4) areas shall be evaluated IAW' Enclosure 8.3 6.5 .4 Each discrepancy will be numbered and documented on Record 7.5 and listed on Record 7.2. 6.5 .5 All discrepancies shall be resolved and documented on Record 7.5 and listed on 7.2 before. technical accuracy is acceptable. 6.6 Human Factors Correctness 6.6 .1 The Human Factors Team will verify that instruments and controls-are available to carry out the procedure and that the procedure / hardware interface is acceptable, e-AP.2.07-3 l-
RECORDS (Continued) 7.5 EOP Verification Discrepancy Sheet 7.6 E0P/ Technical Bases Documents Deviation 8.0 ENCLOSURES 8.1 E0P Source Documents 8.2 Verification Criteria Checklist for Written Correctness 8.3 Verification Criteria Checklist for Technical Accuracy y -~ . , e 1 4 l
- AP.2.07-5
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-RECORD 7.2 E0P VERIFICATION OF TECHNICAL ACCURACY E0P Title E0P Number Revision EVALUATOR (print)
Discrepancy Sheet (s) No. OK No. OK No. OK No. OK No. OK No. OK No. OK No. OK k ( The Acceptable shall be initialed after all discrepancies for Area have been resolved. ' Area Acceptable Areas Initial Entry Conditions ; l Instructional Steps, Cautions Notes, Information Quantitative Information I i Plant Hardware Information Technical Accuracy discrepancies resolved: Signature Date (Evaluator) AP.2.07-7 i i
. i RECORD 7.4 l
OVERALL VERIFICATION ASSESSMENT l AND FINAL VERIFICATION COMPLETION 1 E0P Title i 4 E0P Number Revision EVALUATOR (print) Overall Assessment l Acceptable shall be initialed after all comments and d'rcrepancies have been resolved. Assessment Acceptable (Initial) No. OK No. OK No. OK No. OK I i l l \ l ; (Acceptable shall be initialed etc. as on record 7.1) j l Acceptable Date 1 l ....................................................... ..................... i VERIFICATION Each step must be signed by the Projects / Procedures l l- COMPLETION Nuclear Operating Superintendent indicating each j verification has been completed by the responsible personnel.
- 1. Verification of written correctness (Record 7.1)
- 2. Verification of technical accuracy (Record 7.2)
- 3. Task Analysis and Verification (Record 7.3) ,
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- 4. Overall Verification assessment (Record 7.4)
All actions required by the verification have been completed. Nuclear Operations Superintendent Date Projects / Procedures
.f-AP.2.07-9
RECORD 7.6 E0P/ TECHNICAL BASES DOCUMENT DEVIATION E0P: Rev. Step No. E0P Statement:
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i Technical Bases Documents Statement: 1 1 i f (~' Explain Deviation:
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I 3 1 E0P Writer: Date 1 A P. 2. 07 -11
ENCLOSURE 8.2 VERIFICATION CRITERIA CHECKLIST FOR WRITTEN CORRECTNESS A. Lea
.1 Legibility
.1 Are the straight and proper dimensions on all procedure pages? i
.2 Are the text, tables, graphs, figures, and charts legible to the evaluator. ,
.2 E0P Format Consistency
.1 Do the following sections exist in each E0P:
Section 1 - TITLE Section 2 - OPERATOR ACTIONS
.2 15 the operator actions section presented in a single column format?
.3 Identification Information i
.1 Is the procedure title descriptive of the purpose of the procedure? "
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.2 Does the first page correctly pro 0ide the following:
.1 procedure title ,
.2 procedure number
.3 revision number
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.3 Does each page correctly provide the following: I i
procedure designator
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.2 revision number
.3 page numbers i
.4 Does the procedure have all its pages in the correct order.
l l ENCLOSURE 8.2 PAGE 1 of 3 A P. 2. 07 -13 .,
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ENCLOSURE' 8.2 (Continued) VERIFICATION CRITERIA CHECKLIST:FOR WRITTEN CORRECTNESS
.3 .16 ~ Are numerical values properly written?
.17. Are values specified in such a way that. mathematical operations are not required of the user?
.18 Is a chart or graph provided in.the, procedure for'necessary operator calculations.
.19 Are units'of measurement in'the E0P the same as those used on' equipment?
.4 Procedure Referencing"and Branching
. 1 .Do the referenced and branched procedures identified in the EOPs '
exist for operator use? ', ] 1
.2 Is the use.of referencing minimized? I
.3 Are referencing and branching: instructions correctly worded? 'l I
.1 "go'to" (branching), .
(. .2 " refer to" (referencing)
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.4 Do the instructions avoid routing \ users past important information such as cautions preceding steps?
.5 Are the exit' conditions compatible with the entry.co'nditions;of the referenced or branched procedure? .,
.5 Plant Specific Nomenclature 'I
.1 Are the acronyms used standard .and understood by.the operators?
.2 Is the name of the' equipment the name usually used:by the operator.
L .3 Does the equipment named actually exist? > I
.4 Components, are they identified by the noun name and equipment.
number? a i I L
-ENCLOSURE 8.2 PAGE-3'of 3-i AP.2.07-15 1
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g. ENCLOSURE l8.3- (Continued) VERIFICATION CRITERIA CHECKLIST FOR TECHNICAL ACCURACY.
.1 .5 'Are differences between the licensing commitments and the E0Ps or.
EPGs documented?
.2 Quantitative Information. !
.1 Do the quantitative values, including tolerance bands,'used'in'the E0P comply with applicable E0P source document? ,
.2 .Where the EPG values are not used in the E0P, are the E0P values computed accurately?
l When calculations are required by the E0P, are equations presented
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!- .3 with'suf ficient information for operator use?
.3 Plant Hardware Information-
.1 Is the following plant hardware specified' in the E0P available for )
operator use and accurately named: j
.1. equipment l,;
.2 '. controls.
.3 indicators -
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.4 iristrumentation -
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i e i j l ENCLOSURE 8.3.PAGE 2 of 2 ENDS AP.2.07-17 -' k}}