View source for 3F0903-03, NRC Inspection Report 50-302/02-05, Triennial Fire Protection Inspection, August 23, 2002

{{Adams
| number = ML032550348
| issue date = 09/05/2003
| title = NRC Inspection Report 50-302/02-05, Triennial Fire Protection Inspection, August 23, 2002
| author name = Young D
| author affiliation = Progress Energy Florida, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000302
| license number = DPR-072
| contact person = 
| case reference number = 3F0903-03, IR-02-005
| document type = Letter type:
| page count = 34
}}

=Text=
{{#Wiki_filter:B Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating Ucense No. DPR-72 Ref: 10 CFR 50, Appendix R September 5, 2003 3F0903-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555l0001

==Subject:==
Crystal River Unit 3 - Manual Operator Actions for Fire Protection

==Reference:==
Crystal River Unit 3 - NRC Inspection Report 50-302/02-05, Triennial Fire Protection Inspection, August 23, 2002 (ML022390719)

==Dear Sir:==

The purpose of this letter is to provide the NRC with information on the use of post-fire safe shutdown operator actions for Crystal River Unit 3 (CR-3). This information is being provided to initiate regulatory activities for approval of a licensing basis for the use of operator actions for the protection of safe shutdown capability following a fire.
The issue of NRC approval of post-fire manual operator actions for Appendix R HI.C2 fire areas was identified during an internal assessment of the CR-3 Fire Protection Program in June 2002.
The issue was documented in the CR-3 corrective action program, and work initiated on a technical study to validate the manual operator actions necessary to respond to a fire and ensure safe shutdown of the plant. Subsequently, NRC Inspection 02-05 initiated an unresolved item (URI 50-302/02-05-01) based on the NRC not having approved the manual operator actions for three CR-3 fire areas.
The CR-3 effort to address this issue involved a validation of the operator action times as well as the limitations imposed by the conditions resulting from a fire. To verify that operator actions would be successful in achieving safe shutdown functions, a timeline for plant system response was developed to define required manual operator action completion times. The system response was ascertained from formal calculations, engineering evaluations, or evaluations of simulator exercises. The validation of manual operator actions included:
* staffing
* emergency lighting
* environmental (temperature, humidity) conditions
* accessibility
* priority of actions
* procedural guidance and training.
Progress Energy FTrda, Ic.
Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428

U.S. Nuclear Regulatory Commission                                                       Page 2 of 3 3F0903-03 In the process of evaluating individual manual actions the CR-3 approach to preventing spurious actions due to fire damage from affecting the ability to meet the safe shutdown requirements in Appendix R has evolved. The previous approach to dealing with spurious actions was reactive in application, i.e., if a spurious action were to occur during post fire shutdown operations, then instructions were available to respond via manual operator intervention. The new approach is to proactively take Control Room and local actions to protect safe shutdown functions before spurious actions can adversely affect safe shutdown capability per Appendix R, I.G CR-3 has substantially completed the technical study portion of the latest Fire Study revision and has validated the operator actions which successfully ensure that safe shutdown functions are performed. The results of the Fire Study as they relate to post-fire operator actions are shown in Attachment A. The attachment is organized according to the function to be preserved or the spurious effect to be prevented. Accomplishing the activities in the Attachment A table may require one or several discrete safe shutdown actions depending on the specific fire area.
Attachment B contains the evaluations used to support the validated manual operator actions in Attachment A.
Work is proceeding to accept the results of the revised Fire Study in accordance with the CR-3 design control program. A small number of unresolved items remain which are being tracked within the corrective action program. For the unresolved items, compensatory actions are in effect in accordance with the CR-3 Fire Protection Plan assuring continued protection of safe shutdown capability.
This change in post-fire safe shutdown operation has been reviewed and accepted by the CR-3 Plant Nuclear Safety Committee. Implementation is accomplished through revised Abnormal and Operating Procedures. This strategy for post-fire safe shutdown operations is believed to be far superior to previous procedures.
Progress Energy Florida requests that the NRC review the information contained in this letter and to notify Mr. Sid Powell, Supervisor, Licensing and Regulatory Programs (352 5634883) as to actions necessary for approval to include the safe shutdown process outlined herein in the licensing basis for Appendix R compliance for CR-3.
No Regulatory Commitments are made in this letter.
Sincerely, Dale E. Young Site Vice President Crystal River Nuclear Plant DEY/rmb

U.S. Nuclear Regulatory Commission                                                Page 3 of 3 3F0903-03 Attachments A. Manual Operator Action Validation B. Calculations and Analysis Supporting Safe Shutdown Methodology xc:    Regional Administrator, Region II Senior Resident Inspector NRR Project Manager

PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR -72 ATTACHMENT A MANUAL OPERATOR ACTION VALIDATION

U.S. Nuclear Regulatory Commission                                                                                    Attachment A 3F0903-03                                                                                                              Page 1 of 15 The following table presents the validation of manual operator actions in OP-880A, Revision 3, "Manual Operator Action Validation,"
that are taken proactively when a fire exists in the noted Fire Zone. The table is presented in sections for each of the systems and for each of that system's functions needed to ensure that safe shutdown of the plant can be achieved.
The table is divided into the following columns:
FUNCTIONS - Groups of manual tasks to achieve a performance objective (e.g., Function "EF-2" is to prevent excessive emergency feedwater flow). Achievement of the functions may require one or several discrete operator tasks depending on the fire zone affected.
FIRE ZONE - Those Fire Zones where a fire could cause spurious actuation of equipment.
OP-880A PRESCRIBED ACTION - Summary of manual operator actions required to be performed proactively in a prioritized order.
Operator Action Time - The validated time for an operator to perform the required actions in "s" (seconds) and "n" (minutes).
The longest series of tasks for each function were time validated and compared to the analytical requirements. Where the Analytical Time Limit is '5 8 hrs", the manual operator action was not specifically validated in the field due to the extended time available to perform the action.
Analytical Time Limit - The time within which the required actions must be performed in order to achieve safe shutdown of the plant in "min" (minutes) and "hrs" (hours). These times are derived from the referenced Evaluation that is contained in Attachment B to this submittal or a document that is directly referenced.
COMMENT - Any clarifications necessary to the complete understanding of this table.

U.S. Nuclear Regulatory Commission                                                                    Attachment A 3F0903-03                                                                                              Page 2 of 15 Operator Analytical FUNCTION      FIRE ZONE       OP-880A PRESCRIBED ACTION           Action     Time                COMMENT Time      Limit Emergency Feedwater System Alignment EF-1          CC-108-107    De-energize automatic valves and     7m 15s   10 min     Hydraulic limit is to prevent reliance CC-108-108    manually position to ensure proper            [Eval 13]  upon HPI/PORV cooling. Only one CC-124-111    flow path.                                               valve must be de-energized and opened.
EF-2          CC-108-102    Prevent uncontrolled EFW flow:       i5m 25s  30 min     Analytical Time Limit is based on CC-108-103
* De-energize and manually position           [Eval 15]  two OTSG case.
CC-108-104        automatic valves CC-108-107    OR                                                       Operator Action Times start at CC-108-108
* Trip EFW pumps                                         conclusion of EF-1.
CC-108-109 CC-124-111 CC-124-115 CC-124- 116 AB-95-3 TB-95-200B IB-95-200C rIB-119-201 EF-3          CC-108-102    Manually transfer suction from EFT-2 N/A      > 8 hrs CC-108-103    /CDT-1 to hotwell                             [Eval 91 CC-108-104 CC-108-105

U.S. Nuclear Regulatory Commission                                                         Attachment A 3F0903-03                                                                                   Page 3 of 15 Operator Analytical FUNCTION      FIRE ZONE        OP-880A PRESCRIBED ACTION             Action    Time     COMMENT
_ _ ____________ __ _ __ __________ _ _ _T    ime    Lim it EF-3          CC-108-106 (cont)        CC-108-107 CC-108-108 CC-108-109 CC-108-110 CC-124-111 CC-124-112 CC-124-113 CC-124-114 CC-124-115 CC-124-116 CC-124-117 CC-145-119 AB-75-4 AB-75-5 AB-95-3 AB-95-3E AB-95-3AA AB-119-6 AB-119-7 AB-119-8 IB-95-200B IB-95-200C IB-119-201 TB-95-401 TB-95400A TB-95-400E

U.S. Nuclear Regulatory Commission                                                                Attachment A 3F0903-03                                                                                          Page 4 of 15 Operator Analytical FUNCTION     FIRE ZONE      OP-880A PRESCRIBED ACTION        Action     Time                 COMMENT Time      Limit EF-3          TB-119-403 (cont)        TB-145-400F RB-95-301 RB-119-302 EF-4          CC-108-103    Determine EFT-2 and CDT-I level  N/A      > 8 hrs IB-95-200B    with tank pressure                        [Eval 9]
IB-95-200C IB-119-201 EF-5          CC -108-103   Remove EFP-1 and -3 from service N/A      > 8 hrs    This is a long-term contingency CC-108-104                                              IEEF   action to prevent EFT-2 overheating.
CC-108-108                                              005]
CC-108-109 CC-124-1i1

U.S. Nuclear Regulatory Commission                                                                                Attachment A 3F0903-03                                                                                                          Page 5 of 15 Operator Analytical FUNCTION      FIRE ZONE       OP-880A PRESCRIBED ACTION                      Action     Time                 COMMENT
_ _ ___ _ _T           _ _ _ _ _ _ im
_ e   L imit Make-Up (High Pressure Injection) System Alignment MU-1          CC-124-111    Isolate Letdown flow path locally               27 m     30 min     EC 50624 will improve access
[Eval 5]
Total Operator Action Time based on priority given to EF-1 and -2.
MU-2          CC-108-102    Align Make up flow path by de-                  22m 30s 4 hrs       For AJ3-95-3, Operator Action Time CC-108-103    energizing valves to prevent spurious                    [Eval 14]  does not include the 1-hour necessary CC-108-104    operation and manually positioning                                  to suppress a fire in that Fire Zone.
CC-108-105    valves to ensure proper flow path.
CC-108-106    This includes manually controlling CC-108-107    make up flow at HPI valves when CC-108-108     system is restarted.
CC-108-109 CC-108-110 CC-124-111 CC-124-115 CC-124-116 CC-124-117 AB-95-3 AB-119-6 MU-3          CC-108-109     Starting Make up pumps by manually              18 m    4 hrs      Total Operator Action Time would CC-124-111     closing pump beakers                                    [Eval 14]  include MU- 1,-2, and -3 as well as EF-1 and -2 based on staff

U.S. Nuclear Regulatory Commission                                                                     Attachment A 3F0903-03                                                                                               Page 6 of 15 Operator  Analytical FUNCTION       FIRE ZONE     OP-880A PRESCRIBED ACTION           Action      Time                 COMMENT Time        Limit assignment and priority. The total is MU-3                                                                                 -70 minutes which remains well (cont)                                                                               within the 4 hr limit.
Main Steam System Alignment MS-1          CC-108-102    Manually control ADVs to control    N/A       > 8 hrs CC-108-103    RCS cooldown                                  [Eval 16]
CC-108-104 CC-108-105 CC-106-108 CC-108-107 CC 108-108 CC-108-109 CC-108-110 CC-124-111 CC-124-112 CC-124-113 CC-124-114 CC-124-115 CC-124-116 CC-124-117 CC-145-119 AB-75-4 AB-75-5 AB-95-3

U.S. Nuclear Regulatory Commission                                                   Attachment A 3F0903-03                                                                             Page 7 of 15 Operator     Analytical FUNCTION       FIRE ZONE    OP-880A PRESCRIBED ACTION    Action        Time       COMMENT Time          Limit MS-1           AB-95-3E (cont)         AB-95-3AA AB-119-6 AB-119-7 AB-119-8 IB-95-200B IB-95-200C IB-i 19-201 TB-95-401 TB-95-400A TB-95-400E TB-119-403 TB 145-400F RB-95-301 RB-119-302 4             1                           I          .4.            a

U.S. Nuclear Regulatory Commission                                                        Attachment A 3F0903-03                                                                                  Page 8 of 15 Operator Analytical FUNCTION        FIRE ZONE        OP-880A PRESCRIBED ACTION             Action     Time Time       Limit Feedwater System Alignment FW-1            CC-108-102    Turn off FW booster pumps if any FW I N/A         >8 hrs CC-108-103    block valves fail to close                        [Eval 27]
CC-108-104 CC-108-105 CC-108-106 CC-108-107 CC-108-108 CC-108-109 CC-108-110 CC-124-111 CC-124-115 CC-124-116 CC-124-117 AB-95-3 AB-119-6 IB-95-200B IB-95-200C lB-119-201
             -1             &                                      a          a

U.S. Nuclear Regulatory Commission                                                                     Attachment A 3F0903-03                                                                                               Page 9 of 15 Operator Analytical FUNCTION       FIRE ZONE     OP-880A PRESCRIBED ACTION              Action      Time              COMMENT Time       Limit Ventilation System Alignment VI            CC-108-106    Line up and start Appendix R cooling   6m        60 min    Operator Action Time is from CC-CC-108-108                                                     [Eval 16] 108-109.
CC-108-109 CC-108-110 CC-108-111 CC-124-114 CC-124-117 CC-145-119 AB-199-6 V2            CC-108-109    Operate CC Chiller at Switchgear        1m       2 hrs
[Eval 16]
V-3           CC-108-102    Open doors between TB 119 and LB       N/A       >8 hrs CC-108-103    119 to provide natural circulation to            [Eval 16]
CC-108-104    provide access to ADVs CC-108-105 CC-108-106 CC-108-107 CC-108-108 CC-108-109 CC-108-110 CC-124-111 CC-124-112                                                   .

U.S. Nuclear Regulatory Commission                                                                 Attachment A 3F0903-03                                                                                          Page 10 of 15 Operator Analytical FUNCTION       FIRE ZONE                    OP-880A PRESCRIBED ACTION        Action     Time    COMMENT
_________                                                     Time      Limit V-3             CC-124-113 (cont)          CC-124-114 CC-124-115 CC-124-116 CC-124-117 CC-145-119 AB-75-4 AB-75-5.
AB-95-3 AB-95-3E AB-95-3AA AB-119-6 AB-119-7 AB-119-8 B-95-200B IB-95-200C B-95-201 TB-95-401 TB-95-400A TB-95400E TB-119403 TB-145400F RB-95-301 RB-119-302 V-4a            CC-108-105                  Ventilate A battery charger room N/A      > 8 hrs I__                                        [E val 16]

U.S. Nuclear Regulatory Commission                                                         Attachment A 3F0903-03                                                                                  Page 11 of 15 1Operator Analytical FUNCTION       FIRE ZONE       OP-880A PRESCRIBED ACTION        Action    Time           COMMENT I
:___________I                              [ Time      Limit V-4b          CC-108-107     Ventilate the following areas:    N/A      >8 hrs o Corridor El 108 and Battery              [Eval 16]
Charger Room B o Battery Charger Room A and Battery Charger Room B o Battery Charger Room A and Inverter Room B o Inverter Room A and Inverter Room B o 4160 V Switchgear Room A and Inverter Room B o Stairwell and Corridor El 108" o Stairwell and Corridor El 124' A         I  ___________________________                          J~~~~

U.S. Nuclear Regulatory Commission                                                                        Attachment A 3F0903-03                                                                                                 Page 12 of 15 Operator Analytical FUNCTION       FIRE ZONE     OP-880A PRESCRIBED ACTION                Action     Time                 COMMENT Time      Limit Electrical System Alignment EL-1          CC-108-107    Prevent spurious tripping of ES 4160v    2m 30s   30 min     Operator Action Time based on CC-108-108    bus lockouts                                      [Eval 16]  operator coming from MUV-49.
CC-108-109 CC-124-111 CC-145-119 EL-2a         CC-108-102    Cross-tie ES 480V busses to support      TBD      30 min     Analytical Time Limit is based on restoration of ventilation (AHF-54A)              [Eval 16]  alignment to CHHE-lB.
EC/ED 54293i Operator Action Time will be based on guidance being developed for stripping loads on the 480V busses.
EL-2b         CC-124-111    Cross-tie ES 480V busses to support      TBD      4 hrs,     Operator Action Time will based on restoration of DC power (VBIT-A, -C)              [SBO       guidance being developed for calc]      stripping loads on the 480V busses.
EL-3          AB-95-3       Align power to CHHE-2 and CHP-2          TBD      60 min     CHHE-2 limiting CC-108-103                                                      [Eval 16]
CC-108-109                                                                 Operator Action Time will be based on guidance being developed for stripping loads on the 480V busses.

U.S. Nuclear Regulatory Commission                                                                    Attachment A 3F0903-03                                                                                             Page 13 of 15 Operator  Analytical FUNCTION       FIRE ZONE     OP-880A PRESCRIBED ACTION           Action      Time                 COMMENT Time        Limit Component Closed Cooling System Alignment CCC-1         CC-108-106    Starting RWPs, SWPs, and DCPs by    5m        2 hrs      RW/SW limiting. Longer time CC-108-109    manually closing pump beakers                 [Eval 11]  available for other systems.
CC-124-111 Operator Action Time is for travel time and manual start of a single pump.
CCC-2a        CC-108-103    Manually align SW cooling to RB     N/A       > 8 hrs    NCR 103111 CC-108-109                                                  [Eval 16]
CCC-2b        CC-108-102    Manually Isolate CI cooling to RB   N/A       N/A        EC/ED 53098 CC-108-105 CC-108-106 CC-108-109 AB-95-3 AB-119-6 CCC-2c        CC-108-102    Manually Align cooling to AHF-IC    N/A       > 8 hrs    NCR 1031 11 CC-108-104                                                  [Eval 16]
CC-108-106 lB-1 19-201 RB-95-301 RB-119-302

U.S. Nuclear Regulatory Commission                                                                                            Attachment A 3F0903-03                                                                                                                     Page 14 of 15 Operator Analytical FUNCTION     FIRE ZONE                    OP-880A PRESCRIBED ACTION                      Action     Time                COMMENT v__ _a__
__ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___  T ime      Limit Decay Heat (Low Pressure Injection) System Alignment DH-la         CC-108-108                 Preserve BWST contents. Isolate and             NA       N/A        AP-880 will promptly isolate DHV-CC-124-117                 de-energize valves in flow path from                                34/-35. Removing power and manual AB-95-3                    BWST to RB sump.                                                    positioning will be retained in OP-AB-119-6                                                                                       880A as a contingency action.
NCRs 102599 and -102600 DH-lb         CC-108-108                 Transfer contents of RB Sump to                 N/A      N/A        NCRs 102599 and -102600 CC-124-117                 BWST AB-95-3 AB-1 19-6 DH-2          AB-95-3                    Manually start DH pump                          N/A      > 8 hrs CC-108-106                                                                          [Eval 10]
CC-124-111 DH-3          CC-108-102                 Manually align valves to establish              N/A      > 8 hrs CC-108-103                 DHR                                                      [Eval 10]
CC-108-104 CC-108-105 CC-108-106 CC-108-107 CC-108-108 CC-108-109

U.S. Nuclear Regulatory Commission                                           Attachment A 3F0903-03                                                                    Page 15 of 15 Operator Analytical FUNCTION      FIRE ZONE     OP-880A PRESCRIBED ACTION  Action    Time     COMMENT Time      Limit DH-3          CC-108-110 (cont)        CC-124-111 CC-124-112 CC-124-113 CC-124-114 CC-124-115 CC-124-116 CC-124-117 AB-75-4 AB-75-5 AB-95-3 AB-95-3E AB-95-3EE AB-119-6 IB-95-200B IB-95-200C IB-195-201 TB-95-401 TB-95-400A TB-95-400E TB-119-403 TB-145-400F RB-95-301 RB-119-302

PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR -72 ATTACHMENT B CALCULATIONS AND ANALYSIS SUPPORTING SAFE SHUTDOWN METHODOLOGY

U.S. Nuclear Regulatory Commission                                                                               Attachment B 3F0903-03                                                                                                         Page 1 of 14 The following table contains the evaluations noted in Attachment A. Note that only the evaluations from the draft Fire Study that support the manual operator functions in Attachment A are included.
The table is presented in columns as follows:
Evaluation No. - The evaluation identification number used in the draft Fire Study and noted in Attachment A.
Recovery Time / System Adequacy Description - A description of the success and timing of the given operator action.
References - The source documents used to determine the success and timing of the given operator functions.

U.S. Nuclear Regulatory Commission                                                                                 Attachment B 3F0903-03                                                                                                           Page 2 of 14
                                          .~~~~~~~~~~~~~~~~~~~~Rfrne Evaluation No.            -
Recovery Time/System Adequacy Description        -
References          -
5       MUP Suction Flow Alignment          In the event of an Appendix R fire scenario, the     Calculation M94-0053, Revision 7 MUT is isolated in order to prevent gas binding (Action Time to isolate letdown - of the operating MUP.                                  Calculation F97-0017, Revision 0 30 minutes to isolate MUV49)
Calculation M94-0053, "Allowable MUT-1               Calculation M96-0011, Revision 0 Indicated Overpressure vs. Indicated Level, Section V.12 "Appendix R Concerns," addresses        Calculation M95-0009, Revision 0 two cases involving failure of MUV-143 (Hydrogen supply solenoid valve). Case 16            Calculation M97-0042, Revision 0 assumed letdown was in service through the event.                                               OP-402, Revision 125, Makeup and Purification'System In this case, it was found that MUV-58 is required to be opened, the MUT and letdown isolated           Calculation M03-0006, Revision 0 within approximately 73 minutes to prevent gas from being entrained in the operating MUP. Case 16 assumes the Reactor is at full power and cooldown has not started (with 8 hour hold time).
The second is Case 15 where letdown was not in service, MUV- 143 failed open and the MUT required isolation within 19 minutes to prevent gas entrainment of the operating MUP.
CR-3 no longer operates with hydrogen lined up to the MUT. Hydrogen (and nitrogen) are manually isolated to prevent uncontrolled pressurization of the MUT when the

U.S. Nuclear Regulatory Commission                                                         Attachment B 3F0903-03                                                                                    Page 3 of 14 Evaluation No.       Recovery Time/System Adequacy Description         References 5                                  corresponding solenoid valves fail open during a (cont)                             postulated Appendix R fire. Only manual gas additions are made using a dedicated operator.
Maximum fill pressures based upon tank level to prevent gas entrainment of the MUP header are provided in OP402.
Letdown should still be isolated to insure maintenance of pressurizer level. Based upon a normal operating level of 220" and a normal letdown rate of 45 gpm, operator action in the first 30 minutes would yield a letdown loss of 1350 gallons. 'At 12.2 gal/in in the pressurizer, this yields a net change of -110" or a new level of 110", sufficient to remain on scale.

U.S. Nuclear Regulatory Commission                                                                     Attachment B 3F0903-03                                                                                                Page 4 of 14 Evaluation No.      Recovery Time/System Adequacy Description                      References 7      BWST Drain down             In the event of an Appendix R fire scenario,        Engineering Evaluation EEE                                    charging from the BWST via at least one high-       004, Revision 0 (Action Time - Per NCR     pressure injection flowpath will provide borated 102600)                    water. Due to spurious valve (DHV-42/43)            NCR 102600 operation, the potential exists to drain the BWST into the containment sump. This could result in a loss of BWST water to support RCS inventory control and boration.
This potential has been addressed as part of the change of the normal position of DHV-34 and 35.
This ensures the ability to refill the BWST in the event of inadvertent draindown.
Additionally, an analysis was performed (EEE                                    004) to determine that it is acceptable to run a DH pump without cooling for a sufficient duration
(<1/2 hour) to restore BWST volume.

U.S. Nuclear Regulatory Commission                                                                            Attachment B 3F0903-03                                                                                                      Page 5 of 14 Evaluation No.          Recovery Time/System Adequacy Description                      References 9      Condensate Inventory             From calculation F97-0010:                           Calculation F97-0010, Revision 3
* The depletion time of EFT-2, with the (Action Time - 17 hours to align         minimum volume of 150,000 gallons, is EFP-1/2 to alternate suction             approximately 17 hours.
supply)
* The EFW requirement to meet natural circulation cooldown to 280"F is 862,000 gallons.
Calculation F97-0010 also addresses hold times related to available condensate inventory and cooldown rates. Safety Assessment for AP-990, Revision 09 also addresses condensate inventory.   .
10     Cooldown using one DH Pump       Ensure that a single DH pump and heat                Calculation F97-0017, Revision 0 and Heat Exchanger.              exchanger can support achieving and maintaining cold shutdown.                                       EDBD Tab 6/3, Revision 15 (Action Time > 8 hours to initiate DH cooling)         Calculation F97-0017 titled, "Appendix R Cooldown," identifies that a single train of Decay Heat (DH) can complete a cooldown to cold shutdown within 69 hours. (Satisfying the 72 hour Appendix R requirement).
DH is initiated at 64 hours (280TF RCS) and runs a total of 5 hours to bring RCS from 2800 F to 200TF.
Therefore, the DH pumps, DH pump cooling (DC) and DH heat exchangers are required to be operable prior to 64 hours.

U.S. Nuclear Regulatory Commission                                                                            Attachment B 3F0903-03                                                                                                      Page 6 of 14 Evaluation No.         -
Recovery TIme/System Adequacy Description                   References 11      Alignment of Equipment Cooling Ensure that safe shutdown can be achieved using       Calculation F97-0017, Revision 0 Systems:                           the minimum available cooling water pumps and determine the need to isolate non-essential loads EDBD Tab 6/3, Revision 15 (DH Decay Heat Closed Cycle         on the NS CCC System to support necessary         System)
Cooling (DC) System             cooling and/or prevent pump runout. The time to establish cooling is based on the equipment that  EDBD Tab 6/6, Revision 9 (DC (Action Time - 64 hours to         the system cools. Cooling shall be established    System) assure DC is operable)             prior to start of essential equipment.
EDBD Tab 6/12, Revision 8 (RW
* Nuclear Services Closed         Decay Heat System (DH)                            System)
Cycle Cooling (SW) System       Calculation F97-0017 identifies that cooldown from 2800F (DH is placed in service) to 2000 F is ED Tab 6/2, Revision 17 (MU (Action Time - 4 hours             not required until 64 hours, which is the end of  System) maximum or prior to starting the   ADV cooldown. Therefore, any repairs or MU pumps)                          manual actions needed to align the system are required to be completed within 64 hours. For (Action Time - 2 hours             the DH system, the Decay Heat Closed Cycle maximum or prior to starting the   Cooling System (DC) system provides cooling Chillers)                          and the Nuclear Services and Decay Heat Sea Water System (RWP-3A/B) provides cooling to
* Nuclear Service and Decay       the DC system. Therefore, the DC and RW Heat Sea Water (RW) System      systems must be operable within 64 hours.
(Action Time - 64 hours to         Make-up System (MU) assure RWP-3A or RWP-3B is         Evaluation 14 identifies that the Make-up system operable)                          is not required to be started until 4 hours following a spurious actuation that would cause (Action Time - 2 hours             the loss of HPI. The Nuclear Service Close Cycle maximum to start RWP-2A/B or       Cooling System (SW) provides cooling to the

U.S. Nuclear Regulatory Commission                                                           Attachment B 3F0903-03                                                                                      Page 7 of 14 Evaluation No.      Recovery Tlme/System Adequacy Descriptlon          References 11      prior to start of Chillers)  MU pump motors and lube oil coolers and the (cont)                               Nuclear Services and Decay Heat Sea Water (Action Time - 4 hours       System (RW provides cooling to the SW system maximum to start RWP-2A/B or (RWP-2A/B). Therefore. SW and RW cooling prior to start of MU pumps)  systems are to be established prior to starting the MU pumps.
Control Complex Cooling (CH)
Evaluation 16 identifies that the Control Complex Chillers (CHHE-lA/B) are to be operating within 2 hours following a trip due to a fire. The Nuclear Service Close Cycle Cooling System (SW) provides cooling to the CC chillers and Decay Heat Sea Wate System (RW) provides cooling to the SW system (RWP-2A/B).
Therefore. SW and RW cooling system are to be established prior to starting the Chillers.

U.S. Nuclear Regulatory Commission                                                                          Attachment B 3F0903-03                                                                                                    Page 8 of 14 Evaluation No.         Recovery Time/System Adequacy Desciption          -
References 13      Time to Restore Emergency    Following a postulated fire, Emergency                Drawing 205, 208 series drawings Feedwater                    Feedwater flow may need to be manually                associated with EFIC/EFW established using the Emergency Feedwater (Action Time - 10 minutes to pumps or Auxiliary Feedwater pump.                    B&W Analysis 86-1173989-01 preclude reliance upon HPI-PORV cooling)                EFIC Circuitry is independent of the control          EM-225D room/cable spreading rooms, therefore for alternate shutdown scenarios EFIC establishes the               OE16404 Emergency Feedwater Flow automatically.
For all other fire areas, losses can be 1)mitigated from the Control Room, or 2) result in the loss of flow to only one Steam Generator. Time constraints to provide positive control include:
* 10 minutes to establish EFW to preclude BPI /PORV cooling
                                           * < 5 hours to establish some flow to dry OTSG to prevent exceeding tube-to-shell delta T

U.S. Nuclear Regulatory Commission                                                                               Attachment B 3F0903-03                                                                                                         Page 9 of 14 Evaluation No.             Recovery Time/System Adequncy Description                        References References 14     Time to restore Makeup and        Following a postulated fire, make-up must be           Calculation F92-0002, Revision 1 minimum flow recirculation lines established before unrecoverable conditions are reached, and ideally, while pressurizer level          Calculation E90-0088, Revision 3 (Action Time - 4 hours to regain remains in the indicating range.
control of make-up)                                                                      Calculation M97-0064, Revision 3 M97-0064 looks at pressurizer level versus Tave.
Per this calculation, a drop in Tave of 30'F results in a pressurizer level decrease from 220" to 56".
Per F92-0002, Attachment 3, Tave drops 120 F over a 4-hour period. Based on this information, there is sufficient volume in the pressurizer to make up for shrinkage of the RCS and for any minor system leakage over a 4-hour period if make-up is unavailable. Therefore, it is expected that pressurizer level will remain in the indicating range.
Therefore, there are approximately 4 hours to regain control of make-up, if the plant maintains a hot standby condition until make-up control can be regained. Minimum flow recirculation lines shall be established prior to start of Make-up pumps.

U.S. Nuclear Regulatory Commission                                                                          Attachment B 3F0903-03                                                                                                   Page IOof 14 Evaluation No.           Recovery Time/System Adequacy Description                     References 15     Time to Isolate Emergency       Uncontrolled EFW flow into a Steam Generator        Calculation MSC-0482-5500-035-Feedwater (EFW)                 could result in an overfill condition into the Main 001 Steam lines. Calculation MSC-0482-5500-035-(Action Time - 30 minutes with 001 was performed and presented in letter FCS-2 OTSGs)                        6721, dated 7/18/85.
(Action Time - 17 minutes with Gilbert/Commonwealth analyzed the potential 1 OTSG)                        effects of uncontrolled Emergency Feedwater flow to the OTSGs. It was concluded that if both OTSGs are being fed then it would take approximately 30 minutes to fill and, if only one OTSG is being fed, it would take approximately 17 minutes.
16     Impact of Loss of HVAC          The following ventilation systems are credited:     Calculation H97-0004 Systems Calculation M97-0052 (Action Time - 30 minutes to
* Normal Control Complex HVAC (CHHE-start normal CC return and           lA/B)                                          Calculation F97-0010 supply fans, 2 hours to start chillers CHHE-lA/B)                                                                 Calculation H97-0001, Revision 7 (Action Time - 60 minutes to    a   Appendix R Chiller (CHHE-2)                     Calculation E89-0088, Revision 1 start App R Chiller and AHF-    U1 EFIC Room HVAC (AHF-54B) 54B)
(Action Time - See write-up for
* IB Ventilation times to open doors)

U.S. Nuclear Regulatory Commission                                                          Attachment B 3F0903-03                                                                                    Page 11 of 14 Evaluation No.         Recovery Time/System Adequacy Description        References 16      (Action Time - 4 hours for RB
* RB Fans (cont)  fans)
Ref NCR 103111 (Action Time - N/A for DG
* DG room fans Room Fans)
Control Complex and EFIC Room HVAC -
Fire in Battery Charger Room B (in conjunction with Case I of H97-0004 and H97-OOO1)
With normal control complex coolingj (CHBE-1A/B) available:
o Start one supply fans (AHF-17A/B), one return fan (AHF-19A/B) and one EFIC Room Cooler (AHF-54A/B) in 30 minutes.
o Start one Chiller (CHHE-1A/B) and one Chilled Water Pump (CHP-1A/B) in 120 minutes.
                                          -   Open door between Battery Charger Room A and Inverter Room A within 12 hours of verifying a fire in Battery Charger Room B.
* Loss of Ventilation to all Fire Areas in the Control Complex (in accordancewith Case 2 of H97-0004)
The Appendix R Chiller (CHHE-2) and Air Handling Unit (AHF-54B) must be in service

U.S. Nuclear Regulatory Commission                                                     Attachment B 3F0903-03                                                                              Page 12 of 14 Evaluation No.      Recovery Time/System Adequacy Description      References 16                                    within 60 minutes from confirming a fire and (cont)                                loss of normal ventilation.
* Fire in 4160 V Switchgear Room B (in conjunction with Case 3 of H97-0004 and H97-0001)
With normal control complex cooling available:
o Start one supply fans (AHF-17A/B), one return fan (AHF-19A/B) and one, EFIC Room Cooler (AHF-54A/B) in 30 minutes.
o Start one Chiller (CHHE-1A/B) and one Chilled Water Pump (CHP-lAIB) in 120 minutes.
                                      - Within 10 hours, open the following doors:
o Corridor El 108 and Battery Charger Room B o Battery Charger Room A and Battery Charger Room B o Battery Charger Room A and Inverter Room B o Inverter Room A and Inverter Room B o 4160 V Switchgear Room A and Inverter Room B o Stairwell and Corridor El 108 o Stairwell and Corridor El 124

U.S. Nuclear Regulatory Commission                                                          Attachment B 3F0903-03                                                                                   Page 13 of 14 Evaluation No.       Recovery Time/System Adequacy Description          References 16                                 Intermediate Building HVAC - Calculation M97-(cont)                             0052
                                   . Open door H-201 and H-202 between the TB and IB within 8 hours.
Opening the doors at T = 9 hours will result in a plant cooldown delay of 1 hour (time for room to cool to 138TF for personnel access to open ADVs for plant cooldown). From F97-0010, the time to cold shutdown, with an 8-hour delay, is 68 hours. An additional delay of 1 hour will extend this to 69 hours, which is still within the 72-hour requirement.
Diesel Generator Rooms:
No time to restore was calculated because fans for credited DG are available or Off-site power is, credited.
RB Fans:
Engineering judgment was previously used to demonstrate that RB temperature was acceptable for a 9-hour period. A formal analysis will be generated to validate/ document this judgment.
SBO analysis E89-0088 evaluates RB temperature effects for a 4 hour period. Engineering judgment was previously used to demonstrate that RB temperature was acceptable for a 9-hour period. A formal analysis will be generated to validate/
document this judgment. See NCR 103111.

U.S. Nuclear Regulatory Commission                                                                     Attachment B 3F0903-03                                                                                              Page 14 of 14
                                      .~~~~~~~~~~~~~~~~~~Rfrne Evaluation No.       Recovery Time/System Adequacy Description                    References 27      FW Booster Pump (FWBP)      The Feedwater Booster Pumps are rated for 12,760   OPS-4-68 FW Operation following Main FW gpm at 710' TDH at 305'F. Normal full power Pump trip ;                 suction pressure for the booster pumps is about    Drawing 302-081 FW 60 psig and normal discharge pressure is about (Action Time > 8 hours to   300-350 psig (actual pressures are load            Byron Jackson Manual (FW Booster discontinue FW Booster Pump dependant).                                        Pumps) operation)                  Whether at full power or post-trip, the OTSGs are at over 900 psig and1000 psig. The FWBPs will      AP-990, Revision 9 not be able to feed the OTSGs at > 350 psig. As flow from the FWBPs decreases to < 3000gpm, the recirculation valves to the deaerator (FWT-1) open and the pumps operate in recirculation mode to FWT-I.
The FWBP recirculation valves FWV-47 and -48 are air-operated valves located on the 145' level of the Turbine Building, beside FWT-1. The valves fail open on a loss of instrument air or a loss of power to the associated valve actuator solenoid valve.
The FWBP pumps will trip if FWT-I level drops below 2 feet-1O inches.
Main Feedwater Line Isolation (MFLD closes FWV-14 and FWV-15 which prevent the FWBPs from overfilling the steam generators when OTSG pressure is below 350 psig.
No action times are required for FWBPs.}}