View source for ET 09-0007, Submittal of License Amendment Request for Deviation from Fire Protection Program Requirements

{{Adams
| number = ML090771269
| issue date = 03/04/2009
| title = Submittal of License Amendment Request for Deviation from Fire Protection Program Requirements
| author name = Garrett T
| author affiliation = Wolf Creek Nuclear Operating Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000482
| license number = 
| contact person = 
| case reference number = ET 09-0007
| document type = Letter type:ET, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 148
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:W0LF CREEKNUCLEAR OPERATING CORPORATION Terry J. Garrett Vice President, Engineering March 4, 2009 ET 09-0007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

==Subject:==
Docket No. 50-482:                 License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements Gentlemen:
Pursuant to 10 CFR 50.90, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to the Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). This license amendment request is seeking approval by the Commission, pursuant to License Condition 2.C(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). Specifically, a deviation from certain technical requirements of 10 CFR 50, Appendix R, Section III.G.2, as documented in Appendix 9.5E of the WCGS Updated Safety Analysis Report (USAR), is requested regarding the use of operator manual actions in lieu of meeting circuit separation protection criteria.
Attachment I provides the evaluation and justification for the proposed license amendment.
Attachment II provides markups of USAR Appendix 9.5E. USAR Appendix 9.5E provides a design comparison to 10 CFR 50 Appendix R. Attachment III provides a list of regulatory commitments. Enclosure I provides a revision to E-1 F9900, "Post-Fire Safe Shutdown Manual Actions," which is identified by interim document number WIP-E-1F9900-004-A-1. WIP-E-1F9900-004-A-1 will be released as a new revision to E-1F9900 based on approval of this license amendment request. E-1 F9900 is incorporated by reference in USAR Appendix 9.5B, "Fire Hazards Analysis."
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831            A.*'
An Equal Opportunity Employer M/F/HC/VET

ET 09-0007 Page 2 of 3 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. The amendment application was reviewed by the WCNOC Plant Safety Review Committee. In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated Kansas State official.
WCNOC requests approval of this proposed amendment by March 1, 2010. Once. approved, the amendment will be implemented within 90 days of receipt.
If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr.
Richard D. Flannigan at (620) 364-4117.
Terry J. Garrett TJG/rlt Attachments: II      Evaluation of Proposed Change III  Markup of USAR Pages List of Regulatory Commitments

==Enclosure:==
I    WIP-E-1F9900-004-A-1,     "Post-Fire Safe    Shutdown  Operator  Manual Actions" cc:  E. E. Collins (NRC), w/a, w/e T. A. Conley (KDHE), w/a, w/e V. G. Gaddy (NRC), w/a, w/e B. K. Singal (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

ET 09-0007 Page 3 of 3 STATE OF KANSAS                  )
COUNTY OF COFFEY )
Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
Vice P'resident Engineering SUBSCRIBED and sworn to before me th                   day of frae(rA             2009.
GAYLE SHEPHEARD                  Notary 0ublic~t~~
A      Notary Public - ltate of Kansas My Appt. Expires '!,2--//20//I Expiration Date

Attachment I to ET 09-0007 Page 1 of 9 EVALUATION OF PROPOSED CHANGE

==Subject:==
License Amendment       Request    for Deviation from Fire Protection Program Requirements
: 1.     

==SUMMARY==
DESCRIPTION
: 2.      DETAILED DESCRIPTION
: 3. TECHNICAL EVALUATION
: 4.      REGULATORY EVALUATION 4.1     Applicable Regulatory Requirements/Criteria 4.2     Precedent 4.3     Significant Hazards Consideration 4.4     Conclusions
: 5.      ENVIRONMENTAL CONSIDERATION
: 6.      REFERENCES

Attachment I to ET 09-0007 Page 2 of 9
: 1.     

==SUMMARY==
DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License NPF-42 for the Wolf Creek Generating Station (WCGS).
The proposed amendment would revise the Renewed Facility Operating License to deviate from certain WCGS Fire Protection Program requirements. The reason for this amendment is to allow the performance of operator manual actions, in certain cases, to achieve and maintain safe shutdown in the event of a fire outside of the control room. in lieu of meeting the circuit separation protection requirements of 10 CFR 50, Appendix R, Section III.G.2 referenced in Appendix 9.5E of the Updated Safety Analysis Report (USAR).
: 2. DETAILED DESCRIPTION The WCGS Fire Protection Program is described in USAR Section 9.5.1 and Appendices 9.5A through 9.5E. Historically, Appendix 9.5B provided the Fire Hazards Analysis. The Fire Hazards Analysis is now located in E-1F9905. Appendix 9.5B of the USAR incorporates by reference the following:
* E-1 F9905, Fire Hazards Analysis
* E-1 F9900, Post-Fire Safe Shutdown Manual Actions
* E-1F9910, Post-Fire Safe Shutdown Fire Area Analysis
* XX-E-013, Post-Fire Safe Shutdown (PFSSD) Analysis
     " M-663-00017A, Fire Protection' Evaluations for Unique or Unbounded Fire Barrier Configurations USAR Appendix 9.5E provides a design comparison to 10 CFR 50 Appendix R and how WCNOC compares with the specific requirements of 10 CFR 50 Appendix R.
During the 2005 NRC Fire Protection Triennial Inspection, WCNOC received a green non-cited violation (NCV) of License Condition 2.C(5), "Fire Protection (Section 9.5.1, SER; Section 9.5.1.8, SSER 5)," for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The NRC inspection report concluded that a green NCV of License Condition 2.C(5) existed because WCNOC credited the use of operator manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2.
WCNOC submitted letter WM 06-0013 (Reference 6.1), denying the NCV as a change in the interpretation of WCNOC's licensing basis. The NRC concluded in letter dated July 25, 2006 (Reference 6.2), that the use of operator manual actions is not within the WCGS current fire protection licensing basis. The NRC staff considered the current WCGS fire protection program to provide a reduced level of protection to assure post-fire safe shutdown from that&#xfd; in the fire protection program approved in License Condition 2.C(5)(a) and, therefore, did not meet the criteria of License Condition 2.C(5)(b) for an allowable change not requiring prior NRC approval.

Attachment I to ET 09-0007 Page 3 of 9 The NCV received for this issue during the 2005 NRC Fire Protection Triennial was re-categorized to an apparent violation with enforcement discretion. The enforcement discretion identified in the referenced NRC letter was consistent with that published in the March 6, 2006 Federal Register Notice (Reference 6.3) regarding operator manual actions. This Federal Register Notice withdrew the proposed rule from 10 CFR 50 Appendix R to codify the acceptability of operator manual actions in lieu of compliance with the separation requirements of Appendix R Section III.G.2. WCNOC accepted the apparent violation and is complying with the following requirements for maintaining enforcement discretion through March 5, 2009:
* Implement compensatory measures and initiate corrective actions within 6 months of the publication date of the Federal Register Notice (i.e., by September 5, 2006 per Reference 6.2).
"   The enforcement discretion will continue provided the appropriate compensatory measures are maintained and the planned corrective actions are completed within 3 years of the publication date of the Federal Register Notice (i.e., March 5, 2009 per Reference 6.2).
In response to the apparent violation, WCNOC developed a plan to address resolution of the operator manual actions issue. The plan contained the following major milestones:
A. Perform a detailed circuit analysis to determine if a credible circuit fault condition is present to warrant the mitigating operator manual action currently credited.
No operator manual actions were eliminated as a result of this additional PFSSD review.
B. Perform a thermal hydraulic analysis to assess plant performance when an operator manual action was credited in response to fire induced spurious equipment operation.
Some operator manual actions were eliminated in cases where the thermal hydraulic analysis demonstrated that the operator manual action was not required to be implemented to achieve and maintain hot standby.
C. Where cost beneficial, implement plant modifications that would meet the requirements of 10 CFR 50 Appendix R, Section III.G.2.
Several plant modifications were implemented to completely eliminate the need for an operator manual action.      Modifications included: cable reroute, instrument relocation, creation of a new fire area, and application of raceway fire barrier protection. Additional plant modifications are progressing which address: single spurious equipment operation for Fire Area A-27, multiple spurious equipment operation, elimination of a Control Room action to maintain hot standby, or resolution of an issue identified in the 2008 Triennial Fire Protection Inspection Report (Reference 6.8).
D. For remaining operator manual actions that were cost prohibitive to address by modification or presented a reasonable success probability for acceptance based on available time to implement the operator manual action, a feasibility and reliability analysis, utilizing the guidance in NUREG-1 852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," (Reference 6.4) was conducted. The information within SECY-08-0093, "Resolution of Issues Related to Fire-Induced Circuit Failures,' (Reference

Attachment I to ET 09-0007 Page 4 of 9 6.5) was utilized as guidance to determine if the identified operator manual action required prior NRC approval in order to credit an operator manual action as a permanent resolution.
SECY-08-0093 divides equipment important to safe shutdown into the following two classifications:
One train of systems necessary to achieve and maintain hot shutdown conditions (identified as "Required for Hot Standby" within the WIP-E-1F9900-004-A-1 analysis).
For fire induced spurious operation within this classification, SECY-08-0093 identifies there is no allowance for operator manual action without prior NRC approval.
Equipment important to safety that could be damaged by a single fire, and the spurious equipment operation could result in either an indirect or direct affect on PFSSD capability. However, the equipment is not credited as an element of the analyzed PFSSD success path. This equipment subset is identified as "Important to Safe Shutdown" within the WIP-E-1F9900-004-A-1 analysis. SECY-08-0093 indicates that prescriptive requirements of 10 CFR 50 Appendix R Sections III.G.1.a and III.G.2 do not apply, and an operator manual action is an acceptable mitigating action for the spurious equipment operation. NRC approval is not required in this case.
As documented in WIP-E-1F9900-004-A-1, the operator manual actions for thirteen fire areas address the maloperation of "Important to Safe Shutdown" equipment, while the operator manual actions for one fire area address the maloperation of "Required for Hot Standby" equipment. However, WCNOC has conservatively decided to request NRC review and approval of all presently identified operator manual actions that are intended to be credited as a permanent resolution in lieu of 10 CFR 50 Appendix R, Section III.G.2 protection. These operator manual actions are evaluated for feasibility and reliability within WIP-E-1 F9900-004-A-1.         Review and approval is also requested for the interim compensatory measure operator manual actions for Fire Area A-27, which are evaluated for feasibility within WI P-E-1 F9900-004-A-1.
WCNOC requests approval pursuant to License Condition 2.C(5) to deviate from the 10 CFR 50 Appendix R comparison response referenced in USAR Appendix 9.5E, to allow the performance of operator manual actions in lieu of meeting separation requirements to protect cables from fire damage that could prevent the operation or cause mal-operation of safe shutdown functions. The operator manual actions provide an acceptable, alternative method of protection to ensure that the unit can be safely shutdown in the event of a fire.
: 3. TECHNICAL EVALUATION As discussed in Section 2 above, document E-1F9900, "Post-Fire Safe Shutdown Manual Actions," is incorporated by reference into USAR Section 9.5B. Interim document number WIP-E-1F9900-004-A-1 for the E-1F9900 revision is provided in Enclosure I of this application.
Document WIP-E-1F9900-004-A-1 evaluates the feasibility and reliability of operator manual actions that are necessary to ensure the availability of a PFSSD success path to achieve and maintain hot standby conditions, in response to a single fire event outside the control room.,

Attachment I to ET 09-0007 Page 5 of 9 Table 3-1 identifies the proposed feasible and reliable operator manual actions that are requested for approval. Table 3-2 identifies the proposed feasible, operator manual actions that are requested for approval on an interim basis for Fire Area A-27. The interim operator manual actions will be eliminated with the field implementation of Change Package 012418. A compensatory fire watch has been established in Fire Area A-27 to provide additional defense in depth for that area, and will remain in place until Change Package 012418 is field implemented. The interim operator manual actions are included within the WIP-E-1F9900-004-A-1 analysis, as they are manual actions that are within the March 5, 2009 enforcement discretion scope.
Table 3-1, Permanent Operator Manual Actions OPERATOR MANUAL ACTION                        Fire Location          Room/Fire Area (Fire Area)         where implemented Close valve KAV0201 to fail close letdown      A-i, A-11, A-18, C-7,    1322/A-25 valves BGLCV0459 and BGLCV0460                 C-12, C-18, C-21, C-24, RB Use local controller ABFHCO002 to              A-16N                    1509/A-23 control/isolate steam release through atmospheric relief valve (ARV) for Steam Generator B Use local controller ABFHCO003 to              A-16N                    1509/A-23 control/isolate steam release through atmospheric relief valve (ARV) for Steam Generator C Isolate air and nitrogen to ARV                A-16N                    1508/A-23 ABPV0004 to fail the ARV closed Terminate train B containment spray by         C-22, C-23, C-30, C-33   3302/C-10 opening breaker NB0203 Terminate train A containment spray by         C-18, C-21, C-24         3301/C-9 opening breaker NBO102 Table 3-2, Interim Operator Manual Actions OPERATOR      MANUAL ACTION                  Fire Location          Room/Fire Area OPERATORMANUALACTION                 _(Fire           Area)       where implemented Open EGHV0016 and EGHV0054 to                  A-27                     1401, 1402/A-16 support 'B' Train CCW lineup The proposed feasible and reliable operator manual actions in conjunction with the engineered and administrative defense-in-depth fire protection features provide an acceptable alternative in
* lieu of fully meeting the 10 CFR 50 Appendix R, Section III.G.2 circuit separation requirements referenced in USAR Appendix 9.5E. Therefore, the proposed change to the Fire Protection Program provides reasonable assurance that the plant-can be safely shutdown in the event of a fire in the above fire areas                          I.. t,

Attachment I to ET 09-0007 Page 6 of 9 The WIP-E-1F9900-004-A-1 analysis provides reasonable assurance that the interim operator manual actions for Fire Area A-27 are feasible. Reliability was not demonstrated by the analysis. Therefore, the operator manual actions are considered interim compensatory measures, coupled with a fire watch, until the operator manual actions are eliminated by the field implementation of Change Package 012418. These compensatory measures provide reasonable assurance that a fire in Fire Area A-27 will not adversely affect the ability to achieve and maintain safe shutdown.
: 4.       REGULATORY EVALUATION 4.1      Applicable Regulatory Requirements/Criteria 10 CFR 50, Section 48, Fire Protection, which states in paragraph (a) that "Each operating nuclear power plant must have a fire protection plan that satisfies Criterion 3 of Appendix A of this part." Paragraph (e) states "Nuclear power plants licensed to operate after January 1, 1979, shall...satisfy Criterion 3 of Appendix A to this part in accordance with the provisions of their licenses."
10 CFR 50, Appendix A, General Design Criterion 3, Fire Protection, requires that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979", Section lII.G.2 requires that cables whose fire damage could prevent the operation or cause mal-operation of safe shutdown functions be physically protected from fire damage by one of three methods. The use of operator manual actions to mitigate the effects of fire damage to these cables is not listed in the regulation as an acceptable method for satisfying this requirement.
Since WCGS was licensed after January 1, 1979, WCNOC is not obligated to meet the requirements of Section III.G.2. However, USAR Appendix 9.5E provides a comparison of the WCGS design to Appendix R. Operator manual actions proposed in this amendment request have not been previously reviewed by the NRC.
NRC Regulatory Issue Summary (RIS) 2006-10 (Reference 6.6) provides the regulatory expectations for 10 CFR 50 Appendix R, Section II.G.2 operator manual actions. This license amendment request is a corrective action option for non-compliances involving operator manual actions.
NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," provides the latest published technical guidance to assist in determining that operator manual actions are feasible and can be performed reliably in response to a fire.

Attachment I to ET 09-0007 Page 7 of 9 4.2      Precedent RIS 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," (Reference 6.6) discusses that operator manual actions in lieu of meeting circuit separation criteria have been previously approved as exemption requests for plants licensed to operate prior to January 1, 1979 (i.e., plants. subjected to the requirements of 10 CFR 50, Appendix R). RIS 2006-10 goes on further to state that plants licensed to operate on or after January 1, 1979 (post 1979 licensees) are not required to meet the requirements of paragraph III.G.2 and use of operator manual actions are approved by a staff decision in an NRC Safety Evaluation Report, either as the result of original licensing or via a license amendment.
Amendment No. 186 to South Texas Project (STP) Unit 1 Facility Operating License No. NPF-76 and Amendment No. 173 to STP Unit 2 Facility Operating License No. NPF-80 approved the use of operator manual actions in lieu of meeting protection requirements of circuit separation.
(Reference 6.7) 4.3      Significant Hazards Consideration WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The design function of structures, systems and components are not impacted by the proposed change. The proposed change involves the performance of operator manual actions to achieve and maintain safe shutdown in the event of a fire outside of the control room and will not initiate an event. The proposed change does not increase the probability of occurrence of a fire or any other accident previously evaluated.
The proposed operator manual actions are feasible and reliable and demonstrate that the plant can be safely shutdown in the event of a fire. No significant consequences result from the performance of the proposed change.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Attachment I to ET 09-0007 Page 8 of 9
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The design function of structures, systems and components are not impacted by the proposed change. The proposed change involves the performance of operator manual actions to achieve and maintain safe shutdown in response to a fire outside of the control room. The operator manual actions do not involve new failure mechanisms or malfunctions that can initiate a new accident.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
For the permanent operator manual actions, adequate time is available to perform the proposed operator manual actions to account for uncertainties in estimates of the time available and in estimates of how long it takes to diagnose and execute the actions. The actions have been verified that they can be performed through demonstration and the actions are proceduralized.        The proposed actions are feasible and reliable and demonstrate that the plant can be safely shutdown in the event of a fire.
For the interim operator manual actions adequate time is available to feasibly perform the proposed operator manual actions and a compensatory measure fire watch is provided for the affected area as an added defense in depth fire protection measure.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, WCNOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4     Conclusions In conclusion, based on the considerations discussed above, (1)      there is reasonable assurance that the health and safety of the public will not be endangered       by operation in the proposed manner, (2) such activities will be conducted in compliance with     the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the    common defense and security or to the health and safety of the public.

Attachment I to ET 09-0007 Page 9 of 9
: 5.      ENVIRONMENTAL CONSIDERATION WCNOC has evaluated the proposed changes and determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set' forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
: 6.      REFERENCES 6.1   WCNOC letter WM 06-0013, "Wolf Creek Nuclear Operating Corporation's (WCNOC's)
Response      to    Noncited    Violation  2005008-03     -    NRC    Inspection    Report 05000482/2005008," April 14, 2006. (ADAMS Accession number ML061100444) 6.2   NRC letter EA-06-170, "Wolf Creek Generating Station - Revised Violation and Exercise of Enforcement        Discretion    05000482/2005008-003      (NRC    Inspection    Report 05000482/2005008)", July 25, 2006. (ADAMS Accession number ML062070216) 6.3   Federal Register Notice (71 FR 11169), "10 CFR Part 50 Fire Protection Program - Post-Fire Operator Manual Actions," March 6, 2006.
6.4   NUREG-1 852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," USNRC, October 2007. (ADAMS Accession number ML073020676) 6.5   SECY-08-0093, "Resolution of Issues Related to Fire-Induced Circuit Failures," USNRC, June 30, 2008. (ADAMS Accession number ML081370346) 6.6   NRC Regulatory Issue Summary 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," June 30, 2006. (ADAMS Accession number ML061650389) 6.7   "South Texas Project, Units 1 and 2 - Issuance of Amendments RE: Deviation from Fire Protection Program Requirements (TAC Nos. MD6694 and MD6695)," September 16, 2008. (ADAMS Accession numbers ML082280465 and ML082280472) 6.8   "Wolf Creek Generating Station - NRC Triennial Fire Protection Inspection Report 05000482/2008010," January 2, 2009. (ADAMS Accession number ML090020490)

Attachment IIto ET 09-0007 Markup of USAR Pages

Attachment IIto ET 09-0007 Page 1 of 4 WOLF CREEK TABLE 9.5E-I     (Sheet 6) 10CFR5O Appendix R                                        WCGS batteries are served by a battery charger that can be manually connected to the plant emergency ac power supply.
The ESW pumphouse also complies.
III. G.       Fire Protection of Safe Shutdown Capability
: 1. Fire protection features shall be provided for struc-tures, systems, and componen-important to safe shutdown.                      bllek that demonstratoc These features shall be capa]ble                 t-hat- no.scingle fire Gan of limiting fire danger so                       prevent safe shutdown.
that:
Redundant- t-ra-ins f sys
: a. One train of systems nec,        etof              requir te s     t red ahiv o sary to achieve and maintain                     and maintain het standby hot shutdown conditions from                     are eparated by 3 hCe-U either the control room or                         Sa rated   fire bsrtriri, emergency control station(s) is                  the equivalent provideod free of fire  damage; and                        by 1III.G.2, or else a diva arn ayans f prt
: b. Systems necessary to                        viding thprveatfsa shut achieve and maintain cold sh,Lit-                down eapability exioto down from either the control room or emergency control station(s) can be repaired within 72 hours.
: 2. Except as provided for i: n                 cold shutdown that could paragraph G.3 of this sectio:n,                  potentially be affected by
                                                             ~o   areqprovided features E-1 F9905, Fire Hazards Analysis, coupled with E-1 F9910, Post Fire ~~aheeand maintainedfo Safe    h Shutdown Fire Area Analysis, provide an area-by-are ~a analysis of the powerblock, which demonstrates that no single fire c*an prevent safe shutdown.
For a fire outside the control room, fire protectior features are provided such that post-fire hot standby can be achieved and maintained from the control room, with limited reliance on operator m anual actions outside the control room. Predominantly, redundant safe sh utdown components are separated by 3-hour fire rated barriers or the equiivalent protection identified by III.G.2. In some instances, operator rmanual actions outside             Rev. 0 the control room are utilized in lieu of III.G.2 prot ection. Operator manual actions have been evaluated for feasibility and r eliability, considering NUREG-1852 guidance.

Attachment IIto ET 09-0007 Page 2 of 4 WOLF CREEK TABLE 9.5E-1  (Sheet 7) 10CFR5O Appendix R                              WCGS where cables or equipment,                a single fire, repairs or including associated non-                          eraon           a safety circuits that could                 e perfo     d within 2 prevent operation or cause                hours.
maloperation due to hot shorts, open circuits, or                As described in Append x shorts to ground, or re-          /             E-1F9905 and Section 7.4, n dundant trains of systems                 auxiliary shutdown panel necessary to achieve and                  is provided as a dedicated maintain hot shutdown                     means of achieving and conditions are located                   maintaining hot standby within the same fire area.                in the event that the main outside of primary con-                  control room is tainment, one of the following           uninhabitable due to a means of ensuring that one                fi e.
of the redundant trains is free of fire  damage shall be provided:       Th     SW pumph    e also mpl
: a. Separation of cables and equipment and assoc-iated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or sup-porting such fire barriers shall be protected to provide fire resistance equivalent to that re-quired of the barrier;
: b. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no in-tervening combustible or
                                                                                       ^Rev. 0

Attachmentll to ET 09-0007 Page 3 of 4                                     WOLF CREEK      t~ca6 e-wtTtL TABLE 9.5E-1  (Sheet 8) 10CFRSO Appendix R                                  WCGS fire   hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or
: c. Enclosure of cable and equip-ment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detec-tors and an automatic fire sup-pression system shall be instal-led in the fire   area; Inside noninerted containments one of the fire    protection means specified above or one of the following fire  protection means shall be provided:
: d. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no in-tervening combustibles or fire hazards;
: e. Installation of fire-detec-tors and an automatic fire suppres-sion system in the fire area; or
: f. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a.
noncombustible radiant energy shield.
Rev. 0 1eto ET 09-0007                                  CAR          61ArP *rK1 Page 4 of                                              WOLF CREEK    '&#xfd;Z   V&#xfd;fXI itM1' TABLE 9.5E-1  (Sheet 9) 10CFR50 Appendix R                               WCGS
: 3. Alternative or dedicated shutdown capability and its associated circuits,6 indepen-dent of cables, systems or components in the area, room, or zone under consideration, shall be provided:
: a. Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or
: b. Where redundant trains of systems required for hot shut-down located in the same fire area may be subject to damage from fire suppression activi-ties  or from the rupture or inadvertent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.
6Alternative shutdown capability is provided by rerouting, relocating or modificating of existing systems; dedicated shutdown capability is provided by installing new structures and systems for the function of post-fire shutdown.
Rev. 0

Attachment III to ET 09-0007 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr.
Richard Flannigan at (620) 364-4117.
REGULATORY COMMITMENTS Regulatory commitment                                                   Due Implement License Amendment                                             Once approved, the amendment will be implemented within 90 days of receipt.
A compensatory fire watch will be maintained in Fire Area A-27, and     Will be maintained until will remain in place until Change Package 012418 is field               Change Package implemented.                                                            012418 is field implemented.

Enclosure I to ET 09-0007 WIP-E-1 F9900-004-A-1, "Post-Fire Safe Shutdown Operator Manual Actions"

Post-Fire Safe Shutdown Operator Manual Actions                                                 Page 1 of 117 WIP-E-1 F9900-004-A-1 COVER SHEET 0I     REVISED        INCOPORATED CHC. DOC.
Change PKG. No. 012954 Rev. 0 ISSUED THISDWG.SUPERSEDED BY            REV. THISDWGSUPERSEDES              REV.
REVISION NOTES:
WIP-E-1 F9900-004-A-1 is a complete replacement of E-1 F9900, Revision 4. The WIP will not be released as a revision to E-1F9900 until approval is received from the NRC. Correspondence ET 09-0007 documents Wolf Creek's license amendment request for the feasibility and reliability analysis provided in WIP-E-1 F9900-004-A-1.
VVF NUCEn REEK                 ELECTRONIC oEPnjAPPROVAL Post-Fire Safe Shutdown Operator Manual Actions SCALE                    DRAWING NUMBER                      REV NONE             WIP-E-1F9900-004-A-1                          0

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 2 of 117 WIP-E-1F9900-004-A-1 Table of Contents 1.0          Purpose                                                                            3 2.0          Scope                                                                              3 3.0          Background                                                                         4 4.0          Definitions                                                                        7 5.0          Methodology                                                                       12 6.0          E-1 F9900 Revision Guidance                                                       28 7.0          References                                                                        28 8.0          Feasibility and Reliability Review                                                30 8.1      Fire Area A-i, Auxiliary Building 1974' General Corridor                     30 8.2. Fire Area A-1 1, Auxiliary Building 2000' Cable Chase                        36 8.3      Fire Area A-16, Auxiliary Building 2026' General Corridor                    41 8.4      Fire Area A-18, Auxiliary Building 2026' North Electrical Penetration Room 48 8.5      Fire Area C-7, Control Building 1984' Cable Chase                            54 8.6      Fire Area C-12, Control Building 2000' North Cable Chase                     60 8.7     Fire Area C-18, Control Building 2016' Cable Chase                            65 8.8     Fire Area C-21, Control Building 2032' Lower Cable Spreading Room             72 8.9     Fire Area C-22, Control Building 2073'-6 Upper Cable Spreading Room           79 8.10    Fire Area C-23, Control Building 2032' South Cable Chase                      84 8.11    Fire Area C-24, Control Building 2032' North Cable Chase                      89 8.12    Fire Area C-30, Control Building 2047'-6                                      96 8.13    Fire Area C-33, Control Building 2073'-6                                     101 8.14    Fire Area RB, Reactor Building General Area                                  106 8.15    Fire Area A-27, Auxiliary Building 2026' Rod Drive MG Set Room               113 Attachment A      Summary of OMAs to Achieve and Maintain Hot Standby                         Al Attachment B1 Fire Alarm System Response Time                                               B1-1 Attachment B2 Sample FDT Data Sheet NUREG-1805 FDT 11. Estimating Smoke Detector Response Time                                                   B2-1 Attachment C       Photos of Equipment Manipulated for Operator Manual Action                 C1

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 3 of 117 WIP-E-1F9900-004-A-1 1.0     Purpose 1.1     The purpose of this document is to evaluate the feasibility and reliability of operator manual actions (OMA) that are potentially necessary to ensure the availability of a post-fire safe shutdown (PFSSD) success path to achieve and maintain hot standby conditions, in response to a single fire event outside the Control Room.
: 1. The OMAs for Fire Area A-27 are evaluated for feasibility only. Refer to Section 2.6 for further discussion.
2.0     Scope 2.1     This feasibility and reliability review is applicable to OMAs, as defined in Section 4.11. Attachment A summarizes the OMAs, and the fire areas affected.
2.2     Consistent with the scope of NUREG-1 852, actions taken within the Control Room that are potentially necessary to mitigate or prevent the undesirable affects of fire induced spurious equipment operation are not addressed within this review for feasibility and reliability. Control Room Actions are identified in E-1F9910, Post-Fire Safe Shutdown Fire Area Analysis, and procedural guidance is provided in OFN KC-016, Fire Response.
2.3     Fire areas that do not require a mitigating action to ensure preservation of a PFSSD success path, are not addressed within this review. Refer to E-1F9910 for the detailed PFSSD analysis for each fire area.
2.4    Actions required for transition to cold shutdown are not included. Hot standby is a safe, stable condition for the plant. Consistent with 10 CFR 50 Appendix R, Section III.G.l.b, cold shutdown repairs are required to be completed within 72 hours.
However, cold shutdown is not required to be achieved within 72 hours.
2.5     Interim compensatory OMAs that are being eliminated as a result of plant modifications are not included within this review. These modifications include the following:
: 1. Change Package 012368 and 012568 - Darmatt fire wrap protection for BGLT01 85 and BGLCV01 12C. This change will reduce vulnerability within Fire Area A-8 for the VCT outlet valves to spuriously stick open, resulting in the potential for charging pump gas binding. This modification addresses a Required for Safe Shutdown component (charging pump). It is a multiple spurious operation (MSO) from a PFSSD perspective, as both VCT outlet valves stick open and letdown is diverted from the VCT. In addition to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected area.
: 2. Change Package 012944 - Pressurizer PORV Cable Reroute to allow PORV closure from Control Room. This modification is in response to LER 2008-009. The modification addresses an Important to Safe Shutdown element, as the pressurizers PORVs are not required for PFSSD. However, closure of the PORVs is desired to prevent an RCS flow diversion. It is a MSO equipment operation from a PFSSD perspective, as the fire induced maloperation of both the PORV and its associated block valve must occur before the event would require outside Control Room response. In addition

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 4 of 117 WIP-E-1F9900-004-A-1 to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected areas.
2.6     The interim compensatory measure OMAs for Fire Area A-27 are evaluated for feasibility only. These interim OMAs will be eliminated with the implementation of Change Package 012418. This modification will install fire rated cable for protection of EGHV0016, CCW 'B' Return and EGHV0054 CCW 'B' Supply. The modification addresses a Required for Safe Shutdown element (component cooling water supporting 'B' Train Charging). It is a single spurious equipment operation from a PFSSD perspective as the fire induce failure, will affect CCW cooling to the seal water heat exchanger. The interim OMAs are included within this analysis, as they are manual actions that are within the March 5, 2009 enforcement discretion scope discussed in Section 3.0. In addition to an OMA compensatory measure for the issue, a fire watch compensatory measure has been established for the affected area.
2.7     The interim compensatory manual action for protection of reactor coolant pump (RCP) seals is not included within this review as the OMA is being eliminated by a Technical Specification (TS) change. The TS change will allow the seal injection containment isolation valves to be open with power to the motor operated valve removed. This modification addresses an Important to Safe Shutdown element, as the reactor coolant pumps are not required for PFSSD. However, RCP seal cooling is desired to prevent an RCS flow diversion, as a result of RCP seal failure. It is a MSO equipment operation from a PFSSD perspective, as both seal injection and thermal barrier cooling must be lost before the event would require outside Control Room response. In addition to an OMA compensatory measure for the identified issue, a fire watch compensatory measure has been established for the affected areas.
3.0     Background The Wolf Creek comparison to 10 CFR 50, Appendix R is contained in USAR, Appendix 9.5E. Section III.G of Appendix R requires fire protection of safe shutdown capability to ensure the ability to achieve and maintain safe shutdown following a severe fire. Outside containment, three separation methods are recognized by the NRC to ensure at least one success path is available to achieve and maintain safe shutdown following a fire where redundant components are located in the same fire area. These methods are as follows:
: 1. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour fire rating.
: 2. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
: 3. Enclosure of cables and equipment and associated non-safety circuits of redundant trains in a fire barrier having a 1-hour fire rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the area.

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 5 of 117 WIP-E-1F9900-004-A-1 Inside non-inerted containments, the following criteria apply:
: 1. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
: 2. Installation of fire detectors and an automatic fire suppression system.
: 3. Separation of cables and equipment and associated non-safety circuits of redundant trains by a non-combustible radiant energy shield.
The Wolf Creek response to the requirements of Section III.G of Appendix R is as follows:
USAR Appendix 9.5B provides an area-by-areaanalysis of the power block that demonstrates that no single fire can prevent safe shutdown. Redundant trainsof systems requiredto achieve and maintain hot standby are separatedby 3- hour rated fire barriers,or the equivalent provided by Ill. G.2, or else a diverse means of providing the safe shutdown capabilityexists and is unaffected by the fire. Forredundant trains of systems requiredto achieve and maintain cold shutdown that could potentially be affected by a single fire, repairs or local operator actions can be performed within 72 hours. As described in Appendix 9.5B and Section 7.4, an auxiliaryshutdown panel is provided as a dedicated means of achieving and maintaininghot standby in the event that the main control room is uninhabitable due to a fire. The ESWpumphouse also complies.
Initially, Wolf Creek's position was that the license commitment described in the USAR comparison response to 10 CFR 50 Appendix R, Section III.G allowed the use of "diverse means" to achieve safe shutdown. Diverse means was interpreted by Wolf Creek to mean any reasonable means, in compliance with other license requirements, necessary to ensure the plant can be brought to safe shutdown conditions following a fire. For example, valve or breaker manipulations are considered reasonable since they are performed as part of normal operator duties.
Repairs necessary to achieve hot standby conditions were not considered reasonable since they are not allowed by 10 CFR 50 Appendix R.
During the 2005 NRC Fire Protection Triennial Inspection, Wolf Creek received a green non-cited violation (NCV) of License Condition 2.C.(5), "Fire Protection (Section 9.5.1, SER; Section 9.5.1.8, SSER 5)," for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The NRC inspection report concluded that a green NCV of License Condition 2,C.(5) existed because Wolf Creek credited the use of manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section II.G.2.
Wolf Creek denied the NCV, as documented in letter WM 06-0013 (Reference 7.10).
The NRC concluded in their response letter (Reference 7.11) to the denial, that the use of operator manual actions in lieu of direct compliance with the separation requirements of 10 CFR 50 Appendix R Section III.G.2 is not within Wolf Creek's current fire protection license basis. The NCV received for this issue during the 2005 NRC Fire Protection Triennial was recategorized to an Apparent Violation with

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 6 of 117 WIP-E-1 F9900-004-A-1 enforcement discretion. The enforcement discretion identified in the referenced NRC letter was consistent with that published in the March 6, 2006 Federal Register Notice regarding operator manual actions. This Federal Register Notice withdrew the proposed rule from 10 CFR 50 Appendix R to codify the acceptability of operator manual actions in lieu of compliance with the separation requirements of Appendix R Section III.G.2. Wolf Creek accepted the Apparent Violation and is complying with the following requirements in effort to receive enforcement discretion through March 5, 2009:
* Implement compensatory measures and initiate corrective actions within 6 months of the publication date of the Federal Register Notice (i.e., by September 5, 2006).
* The enforcement discretion will continue provided the appropriate compensatory measures are maintained and the planned corrective actions are completed within 3 years of the publication date of the Federal Register Notice (i.e., March 5, 2009).
In response to the Apparent Violation Wolf Creek developed a plan to address resolution of the manual actions issue. The plan contained the following major milestones:
A. Perform a detailed circuit analysis to determine if a credible circuit fault condition is present to warrant the mitigating manual action currently credited.
No operator manual actions were eliminated as a result of this additional PFSSD review.
B. Perform a thermal hydraulic analysis (WCNOC-CP-002) to assess plant performance when an OMA was credited in response to fire induced spurious equipment operation.
Some OMAs were eliminated in cases where the thermal hydraulic analysis demonstrated that the OMA was not required to be implemented to achieve and maintain hot standby.
C. Where cost beneficial, implement plant modifications to comply with 10 CFR 50 Appendix R III.G.2.
Several plant modifications were implemented to either completely eliminate the need for an operator manual action or improve the overall feasibility and reliability of remaining operator manual actions for a specific fire area.
Modifications included: cable reroute, instrument relocation, creation of a new fire area, and application of raceway fire barrier protection.
D. For remaining operator manual actions that were cost prohibitive to address by modification or presented a reasonable success probability for acceptance based on available time margin, a feasibility and reliability analysis, considering NUREG-1852 guidance, was conducted. The NUREG-1852 feasibility and reliability analysis is contained within this document. The information within SECY-08-0093 was utilized as guidance to determine if the identified OMA required prior NRC approval in order to credit an OMA as a

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 7 of 117 WIP-E-1F9900-004-A-1 permanent resolution. SECY-08-0093 divides equipment important to safe shutdown into the following two classifications:
                " One train of systems necessary to achieve and maintain hot shutdown conditions (identified as "Required for Hot Standby" in this analysis). For fire induced spurious operation within this classification, SECY-08-0093 identifies there is no allowance for OMA without prior NRC approval.
* Equipment important to safety that could be damaged by a single fire, and the spurious equipment operation could result in either an indirect or direct affect on PFSSD capability. However, the equipment is not credited as an element of the analyzed PFSSD success path. This equipment subset is identified as "Important to Safe Shutdown" within this analysis. SECY-08-0093 indicates that prescriptive requirements of 10 CFR 50 Appendix R Sections III.G.1.a and III.G.2 do not apply, and an OMA is an acceptable mitigating action for the spurious equipment operation. NRC approval is not required in this case.
4.0     Definitions 4.1     Action 4.1.1      An activity, typically observable, and usually involving the manipulation of equipment, that is carried out by an operator(s) to achieve a certain outcome. The required diagnosis of the need to perform the activity, the subsequent decision to perform the activity, obtaining any necessary equipment, procedures, or other aids or devices necessary to perform the activity, traveling to the location to perform the activity, implementing the activity, and checking that the activity has had its desired effect, are all implied and encompassed by the term "action."
4.2     Available Time (or Time Available) 4.2.1      The time period from a presentation of a cue for an action to the time of adverse consequences if the action is not taken. This time is based on one of the following:
: a. Thermal hydraulic analysis, where plant thermal performance is not adversely affected. The thermal hydraulic analysis is documented in WCNOC-CP-002 and SA-08-006. Fire induced spurious equipment actuation requiring OMA implementation are assumed to occur simultaneously at the onset of the event.
: b. Established Technical Specification or Technical Requirements Manual for allowed equipment outage times.
: c. Referenced source (calculation, analysis, industry document, etc.).

Post-Fire Safe Shutdown Operator Manual Actions                                         Page 8 of 117 WIP-E-1F9900-004-A-1 4.3     Cold Shutdown 4.3.1         Plant Mode 5, which is within the following parameters:
Reactivity Condition   % Rated Thermal          Average Reactor Coolant (keff)                 Power (excluding         Temperature (&deg;F) decay heat)
                        < 0.99                 N/A                      < 200 4.4     Control Room Action 4.4.1         Action within the Control Room to mitigate or prevent the undesirable affects of fire induced spurious equipment operation.
4.5     Diagnosis Time 4.5.1          The time required for operator(s) to examine and evaluate data to determine the need for, and to make the decision to implement, an action.
4.6     Feasible Action 4.6.1          An action that is analyzed and demonstrated as being able to be performed within an available time so as to avoid a defined undesirable outcome. As compared to a reliable action (see definition), an action is considered feasible if it is shown that it is possible to be performed within the available time; but it does not necessarily demonstrate that the action is reliable. For instance, performing an action successfully one time out of three attempts within the available time shows that the action is feasible, but not necessarily reliable.
4.7     Fire Indicated 4.7.1          The point when the fire is detected by either human or automatic detection means. The duration of early fire growth before fire alarm indication is determined based on NUREG-1805 guidance regarding smoke detector response time. Refer to Attachment B1 for further discussion regarding the use of NUREG-1805 Fire Dynamics Tools (FDT).
4.8     Fire Initiation 4.8.1          The point when the fire event commences.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 9 of 117 WIP-E-1 F9900-004-A-1 4.9     Hot Standby 4.9.1      Plant Mode 3, which is within the following parameters:
Reactivity Condition  % Rated Thermal         Average Reactor Coolant (keff)                Power (excluding        Temperature ("F) decay heat)
                     < 0.99                N/A                     > 350 The residual heat removal (RHR) system is utilized for decay heat removal at RCS temperatures less than 350 0 F. RHR is a cold shutdown system.
4.10    Important to Safe Shutdown 4.10.1     Component that could be damaged by a single fire, and the spurious equipment operation could result in either an indirect or direct affect on PFSSD capability. However, the equipment is not credited as an element of the analyzed PFSSD success path. This is "orange box" equipment as, defined in Table 1 of SECY-08-0093.
4.11    Multiple Spurious Operation (MSO) 4.11.1     Condition where more than one fire induced equipment maloperation is required before an undesired event, potentially affecting PFSSD, would occur.
4.12    Operator Manual Action (OMA) 4.12.1     Those actions performed by operators to manipulate components and equipment from outside the main Control Room to achieve and maintain post-fire hot standby, but not including "repairs." Operator manual actions comprise an integrated set of actions needed to help ensure that hot standby can be accomplished, given that a fire has occurred in a particular plant area.
4.13    OMA Implementation Time (or OMA Time) 4.13.1     The time required by the operator(s) to successfully perform the manipulative aspects of an action (i.e., not the diagnosis aspects themselves, but typically as a result of the diagnosis aspects), including obtaining any necessary equipment, procedures, or other aids or devices; traveling to the necessary location; implementing the action; and checking that the action has had its desired effect.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 10 of 117 WIP-E-1 F9900-004-A-1 4.14    OMA Uncertainty Time 4.14.1      A time duration to account for varying conditions/uncertainties that could adversely affect overall OMA completion time. Examples considered include:
                    " Communication and feedback with Control Room
                    " Electronically controlled door requiring key access
                    " Obtain RCA access
* Human centered uncertainties such as size, physical strength, and cognitive difference
* Return trip to Control Room as a result of loss of Gaitronics and Radio communication capability 4.15    Preventive Action 4.15.1      Those actions that, upon entering a fire plan/procedure, the operator(s) takes (without needing further diagnosis) to mitigate the potential effects of possible spurious actuations or other fire-related failures, so as to ensure that hot standby can be achieved and maintained. For these actions, it is generally assumed that once the fire has been detected and located, per procedure, the Control Room crew will direct personnel to execute a number of actions, possibly even without the existence of other damage symptoms, to ensure the availability of equipment to achieve its function during the given fire scenario. In many cases, the only criterion for initiating these actions is the presence of the fire itself. The fire must be confirmed before a preventive action will be taken.
4.16    Reactive Action 4.16.1     Those actions taken during a fire in response to an undesired change in plant condition. In reactive actions, the operator(s) detects the undesired change and, with the support of procedural guidance, diagnoses the correct actions to be taken. Thus, with reactive actions, the plant staff responds to indications of changing equipment conditions caused by the fire, and then takes the steps necessary to ensure that the equipment will function when needed (e.g., manually reopening a spuriously closed valve). The plant staff may not initiate the actions until the procedure indicates that, given the relevant indications, the actions must be performed.
4.17    Reliable Action 4.17.1      A feasible action that is analyzed and demonstrated as being dependably repeatable within an available time, so as to avoid a defined adverse consequence, while considering varying conditions that could affect the available time and/or the time to perform the action. As compared to an action that is only feasible (see definition), an action is considered to be reliable as well if it is shown that it can be dependably and repeatably performed within the available time, by different crews, under somewhat varying conditions that typify uncertainties in the available time and the time to perform the action, with a high success rate.

Post-Fire Safe Shutdown Operator Manual Actions                                 Page 11 of 117 WIP-E-1F9900-004-A-1 4.18    Required for Hot Standby 4.18.1     Component on the required safe shutdown path for a particular fire area that is designated to perform one or more of the following safe shutdown functions:
                            " Reactivity control
                            " Pressure control
                            " Inventory control
* Decay heat removal
                            " Process monitoring
* Support systems This is "green box" equipment as defined in Table 1 of SECY-08-0093.
4.19    Sinqle Spurious Equipment Operation 4.19.1     Condition where the fire induced maloperation of a single component potentially affects PFSSD.
4.20    Time Margin 4.20.1     The amount of Available Time (see definition) remaining following OMA implementation, factoring in uncertainty.
4.21    Undetected Fire Growth Time from initial onset of fire before the fire event is detected.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 12 of 117 WIP-E-1F9900-004-A-1 5.0     Methodology The following methodology was applied for each fire area where fire induced spurious equipment operation could result in the need to perform a mitigating OMA to ensure PFSSD capability. Section 8.0 contains the detailed evaluation for each fire area analyzed, utilizing the format described in Section 5.1 5.1     Fire Area # and Location The specific fire area and location within the plant is identified. This is the location of the postulated fire.
5.1.1       Fire Area Features A general description of the fire area, including the active fire protection features provided.
5.1.2       Spurious Equipment Operation requirinq Operator Manual Action A discussion of the equipment that could spuriously operate as a result of the fire is identified. The equipment is classified as either "Required for Hot Standby" or "Important to Safe Shutdown" and a basis is provided for the classification. Additionally, the equipment maloperation is classified as either "Single Spurious Equipment Operation" or "Multiple Spurious Operation" (MSO), and a basis is provided for the classification.
5.1.3       Operator Manual Action Description The OMA and location of the action is identified. The OMA is identified as either a "Reactive Action" or "Preventive Action" based on when the OMA implementation occurs in relation to event diagnosis.
Some OMAs necessary to achieve and maintain PFSSD affect more than one component in the plant. The following assesses the impact to PFSSD concerning components affected by OMA implementation. The review determined that implementation of the OMAs identified in Attachment A will not result in an adverse consequence to PFSSD capability.
5.1.3.1       Close KAV0201 Closing instrument air valve KAV0201 will fail air to the air operated components within the Reactor Building. This is performed in order to fail letdown isolation valves BGLCV0459 and BGLCV0460. Table 5.1.3.1-1 identifies all other components affected by closing KAV0201. Based on the table, there is not adverse impact of safe shutdown by closing KAV0201.

Post-Fire Safe Shutdown Operator Manual Actions                                            Page 13 of 117 WIP-E-1F9900-004-A-1 Table 5.1.3.1-1, OMA Consequence Review for Closing KAV0201 Component               Description                      Consequence Review BBHV7141                Reactor coolant drain tank      Valve is normally closed and fails closed on (RCDT) heat exchanger to         loss of air. Neither the RCDT nor the PRT are pressurizer relief tank (PRT)    PFSSD components. The position of this valve has no impact on safe shutdown.
BBHV8026                PRT nitrogen supply             Valve is normally closed and fails closed on loss of air. The PRT is not a PFSSD component. This valve is a containment isolation valve and the safety position of this valve is closed. The position of this valve has no impact on safe shutdown.
BBHV8031                PRT drain to reactor coolant    Valve is normally closed and fails closed on drain tank (RCDT)                loss of air. Neither the PRT nor the RCDT are PFSSD components. The position of this valve has no impact on safe shutdown.
BBHV8032                Reactor vessel flange leak off  Valve is normally open and fails open on loss of air. This valve allows any leakage from the reactor vessel flange to pass to the RCDT.
Flange leakage is not considered in the PFSSD analysis, as it is mechanical. The position of this valve has no impact on safe shutdown.
BBHV8045                Reactor makeup water to PRT     Valve is normally closed and fails closed on loss of air. This valve assists in maintaining water level in the PRT. The PRT is not a PFSSD component. The position of this valve has no impact on safe shutdown.
BBHV8141A               Reactor coolant pump (RCP) A    These valves are on the individual RCP seal seal water outlet               return lines. They are normally open and fail open on loss of air. This is the assumed BBHV8141 B              RCP B seal water outlet         PFSSD position of these valves. A loss of air BBHV8141C               RCP C seal water outlet         to these valves has no negative impact on PFSSD.
BBHV8141D               RCP D seal water outlet BBLCV0178               RCP D standpipe fill            These valves are normally closed and fail BBLCV0179               RCP C standpipe fill            closed on loss of air. The RCP seal BBLV019__P___stndppeillstandpipes                                     are not PFSSD components. The BBLCV0180               RCP B standpipe fill            position of these valves has no impact on safe shutdown.
BBLCV0181               RCP A standpipe fill BBPCV0455B              Pressurizer spray valve         Air feeds the controllers for the two pressurizer spray valves and modulates the valves.
BBPCV0455C              Pressurizer spray valve         Based on preoperational testing, loss of air to BBPY0455CA              Pressurizer pressure controller the controller causes the spray valves to close. Based on thermal hydraulic analyses BBPY0455BA              Pressurizer pressure controller (WCNOC-CP-002), closing the pressurizer spray valves creates a more conservative condition inthe primary system.
BGHCV0123               Excess letdown heat exchanger   Valve is normally closed and fails closed on isolation                       loss of air. This valve is not a PFSSD component, but inthe failed position it would assist in isolating the excess letdown. The position of this valve has no impact on safe shutdown.

Post-Fire Safe Shutdown Operator Manual Actions                                          Page 14 of 117 WIP-E-1 F9900-004-A-1 Component            Description                       Consequence Review BGHV8143             Excess letdown to RCDT            Valve is a three-way valve and fails open to the seal water heat exchanger on loss of air.
This valve is not a PFSSD component and the position of this valve has no impact on safe shutdown.
BGHV8146             Regenerative heat exchanger to    These valves are the charging injection valves RCS Loop 1 Cold Leg               to the Loop 1 and Loop 4 hot legs. They fail to the open position. For post-fire line-up, BGHV8147             Regenerative heat exchanger to    charging is isolated using the containment RCS Loop 4 Cold Leg               isolation valves BGHV8105 and BGHV8106.
The position of these valves has no impact on safe shutdown.
BGHV8149A            Letdown orifice isolation         These valves are the orifice isolation valves on the letdown lines. They fail closed on loss of BGHV8149B            Letdown orifice isolation         air. Letdown is isolated using BGLCV459 and BGHV8149C            Letdown orifice isolation         BGLCV460. Closing these valves assists in isolating letdown, but the position of these valves has no impact on safe shutdown.
BGHV8160             Letdown containment isolation     Valve is the inboard containment isolation valve                             valve on the letdown line. It fails closed on loss of air. Letdown is isolated using BGLCV459 and BGLCV460. Closing this valve assists in isolating letdown, but the position of this valve has no impact on safe shutdown.
BGHY8145             Pressurizer spray from            Valve is normally closed and fails closed on regenerative heat exchanger       loss of air. It allows charging water to spray in the Pressurizer. Charging is isolated upstream of this valve using BGHV8105 or BGHV8106. The position of this valve has no impact on safe shutdown.
BGLCV0459            Letdown isolation                 These valves are normally open and fail closed on loss of air. The PFSSD position of these two valves is closed. Failing air to these BGLCV0460            Letdown isolation                 two valves will place them inthe PFSSD position.
EJHCV8890A           RHR A test line to safety         These valves are normally closed and fail injection (SI)                    closed on loss of air. The RHR system is not impacted by the closure of these valves. They EJHCV8890B           RHR B test line to safety         are not PFSSD components and their position injection                         has no impact on safe shutdown.
EJHCV8825            RHR test line to safety injection

Post-Fire Safe Shutdown Operator Manual Actions                                           Page 15 of 117 WIP-E-1F9900-004-A-1 Component             Description                     Consequence Review EMHV8823              SI / accumulator test line      These valves are normally closed and fail closed on loss of air. The SI system is not EMHV8824              SI pump B test line             used for PFSSD and it is not impacted by the EMHV8843              Boron injection upstream test   closure of these valves. They are not PFSSD line                            components and their position has no impact on safe shutdown.
EMHV8871              Containment isolation test line EMHV8881              SI pump A test line EMHV8882              Boron injection downstream test line EMHV8889A             Hot leg 1 test line EMHV8889B             Hot leg 2 test line EMHV8889C             Hot leg 3 test line EMHV8889D             Hot leg 4 test line EPHCV0943             Nitrogen containment isolation  These valves are normally closed and fail closed on loss of air. They are associated EPHV8875A            Accumulator A nitrogen supply    with the Nitrogen supply to the SI EPHV8875B            Accumulator B nitrogen supply    accumulators. The SI accumulators are not used for PFSSD. The valves are not PFSSD EPHV8875C            Accumulator C nitrogen supply    components and their position has no impact EPHV8875D            Accumulator D nitrogen supply    on safe shutdown.
EPHV8877A            Accumulator A test line          These valves are normally closed and fail closed on loss of air. They are associated EPHV8877B            Accumulator B test line          with the SI accumulators. The SI EPHV8877C            Accumulator C test line          accumulators are not used for PFSSD. The valves are not PFSSD components and their EPHV8877D            Accumulator D test line          position has no impact on safe shutdown.
EPHV8878A            Accumulator A fill line          These valves are normally closed and fail closed. They are used to maintain water level EPHV8878B            Accumulator B fill line          in the SI accumulators. The SI accumulators EPHY8878C            Accumulator C fill line          are not used for PFSSD. The valves are not PFSSD components and their position has no EPHV8878D            Accumulator D fill line          impact on safe shutdown.
EPHV8879A            Accumulator A test line          These valves are normally closed and fail closed on loss of air. They are associated EPHV8879B            Accumulator B test line          with the SI accumulators. The SI EPHV8879C            Accumulator C test line          accumulators are not used for PFSSD. The valves are not PFSSD components and their position has no impact on safe shutdown.
EPHV8879D            Accumulator D test line EPPV0001             Steam generator nitrogen purge   This is a control valve that fails closed on loss regulator                        of air. This valve was used to purge the Steam Generators with Nitrogen during plant shutdowns. The PIC for this valve is now valved out of service and a manual valve is used to control the Nitrogen flow. The position of this valve has no impact on safe shutdown.
GTHY0005             Containment purge supply         The dampers are associated with the containment purge system. The dampers are GTHY0007             Containment purge supply         normally closed and fail closed on loss of air.
GTHY0008             Containment purge exhaust        The position of these dampers has no impact on safe shutdown.
GTHY001 1            Mini purge exhaust

Post-Fire Safe Shutdown Operator Manual Actions                                              Page 16 of 117 WIP-E-1F9900-004-A-1 Component               Description                       Consequence Review HBHV7126                RCDT vent                         These seven components are associated with the reactor coolant drain tank. Some of the HBHV7127                RCDT outlet                       valves fail open and some fail closed on loss HBHV7143                RCDT recirculation                of air. Loss of air to the controller causes valve HBLCV1003 to fail closed. However, HBHV7144                RCDT recirculation                the RCDT and associated valves are not PFSSD components. The position of these HBHV7176                RCDT discharge                    valves has no impact on safe shutdown.
HBLCV1003               RCDT level control HBLY1003A               RCDT level controller LFLVO097                Containment cooler A drain        These valves are normally closed and fail open on loss of air. The valves allow normal LFLV0098                Containment cooler B drain        drainage from the containment coolers to drain LFLVO099                Containment cooler C drain        to the containment normal sumps. They fail open on loss of air to assure that the LFLVO100                Containment cooler D drain        containment coolers will function properly in an accident case. The containment coolers and drain valves are not PFSSD components and the position of these valves has no impact on safe shutdown.
LFLVO122                Refueling pool standpipe drain to Valve is a normally closed and fails closed on containment sump                   loss of air. It is associated with the refueling pool leak detection system. The refueling pool leak detection system is not a PFSSD system.
The position of this valve has no impact on safe shutdown.
5.1.3.2       Manipulate Local Controller ABFHCO002 Steam generator atmospheric relief valve (ARV) ABPV0002 can be controlled/isolated by manipulation of ABFHCO002.
The local controller is not associated with any other component; so there is no adverse consequence to PFSSD capability.
5.1.3.3       Manipulate Local Controller ABFHCO003 Steam generator ARV ABPV0003 can be controlled/isolated by manipulation of ABFHCO003. The local controller is not associated with any other component; so there is no adverse consequence to PFSSD capability.
5.1.3.4       Isolate ARV ABPV0004 Steam generator ARV ABPV0004 can be isolated by closing air supply valve KAV1429 and nitrogen supply valve KAV1 365, and then bleeding air from the regulator. The manipulated equipment is not associated with any other component; so there is no adverse consequence to PFSSD capability.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 17 of 117 WI P-E-1 F9900-004-A-1 5.1.3.5      Open Breaker NB00203 Breaker NB00203 is opened to terminate the spurious operation of Train B containment spray. Breaker NB00203 is associated only with containment spray pump B. There are no other components that can be affected by manually opening the breaker. Therefore, there is no adverse consequence to PFSSD capability.
5.1.3.6      Open Breaker NBOO102 Breaker NBOO102 is opened to terminate the spurious operation of Train A containment spray. Breaker NBOO102 is associated only with containment spray pump A. There are no other components that can be affected by manually opening the breaker. Therefore, there is no adverse consequence to PFSSD capability.
5.1.4      Feasibility Analysis of Time Available to Perform Operator Manual Action
: 1.      An event timeline, similar to Figure 5.1.4-1, was developed for each fire area necessitating OMA implementation. The event timeline starts at fire initiation. This is more conservative than NUREG-1852 guidance, which starts the event timeline at fire indicated. The fire induced spurious equipment operation is also postulated to occur at fire initiation. This is conservative, as the cable type utilized (IEEE-383) will not present an immediate failure mode when exposed to fire. Elements of the timeline include:
Fire Initiation - Reference Section 4.8 for definition.
Fire Indicated - Reference Section 4.7 for definition. As discussed in Section 5.1.14, OFN KC-016 Fire Response, is entered once the fire condition is confirmed, which is accomplished by one of the following:
: a.       Fire reported by personnel.
: b.       Fire alarm verified by inspection.
: c.       Multiple fire alarms for the same area are received at fire alarm control panel (FACP) KC-008, located in the Control Room.
Diagnosis Time - Reference Section 4.5 for definition. Diagnosis time will start following fire indication.
OMA Implementation Time - Reference Section 4.13 for definition.
OMA Uncertainty Time - Reference Section 4.14 for definition.

Post-Fire Safe Shutdown Operator Manual Actions                                             Page 18 of 117 WIP-E-1F9900-004-A-1 Available Time - Reference Section 4.2 for definition.
Time Margin - Reference Section 4.20 for definition.
: 2.         The timeline results are reviewed to determine if adequate time is available to ensure feasibility of the OMA. The OMA is considered feasible, from a timing perspective, if the OMA implementation time (excluding the OMA uncertainty time) for at least one demonstration does not exceed the available time for performing the OMA.
: 3.        The timeline results are reviewed to determine if adequate time margin is available to ensure reliability of the OMA. The OMA is considered reliable, from a timing perspective, ifthe OMA time plus the OMA uncertainty time does not exceed the available time for OMA implementation.
Operator Manual Action Timeline (Minutes)
Fire Initiated 4 Fire Indicated IDagnosis Timre OMA Time                    OMA Uncertainty 2    4    6   8 10 12 14 16 18 202         24 26 28   32 34 36 38 4042 44 464850 52 54 56 58 60 Time Margin Available Time I
Figure 5.1.4-1, Sample OMA Timeline 5.1.5            Reliability Analysis of Time Available to Perform Manual Actions This criterion addresses uncertainties to ensure that the OMA can be dependably and repeatedly performed within the available time. An OMA is considered reliable provided that a Time Margin remains when considering Fire Indicated Time, Diagnosis Time, OMA Implementation Time and OMA Uncertainty Time, within the OMA event timeline. The following uncertainty times were included, as applicable, in effort to address OMA reliability:

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 19 of 117 WIP-E-lF9900-004-A-1
: 1.      For implementation of each OMA a delay of one (1) minute is included for the OMA action to be understood and repeated back to the Control Room. This delay is invoked in recognition that a limited delay will be present regarding the three-way communication method that will be utilized when the Control Room directs implementation of the aMA. Additional uncertainty time is added for implementation of multiple OMAs.
: 2.      A time delay of three (3) minutes is included, where applicable, to account for cumulative delay through electronically controlled doors that could require key access in the event power is lost to the door. This is a reasonable timeframe for the operator to assess that key access is necessary, in order to obtain ingress beyond affected electronically controlled doors.
: 3.      A time delay of two (2) minutes is included for obtaining necessary access and dosimetry when entering the radiological controlled area (RCA). This time delay is based on the typical processing time to log into and gain access into the RCA. It is recognized that during an emergency, such as fire response, conventional RCA entry may be waived provided a RDD is obtained. However, for conservatism, a time delay has been included within this analysis, which accounts for conventional RCA entry.
: 4.      A time delay of three (3) minutes is included for human centered uncertainties such as size, physical strength, and cognitive difference.
5.1.6      Environmental Factors The expected environmental conditions for the OMA location and associated egress routes were reviewed for acceptability. Environmental factors considered were radiation, lighting, temperature, humidity, smoke, toxic gas, noise, and halon fire suppression discharge. The following is the smoke propagation impact review for OMAs.
5.1.6.1     Smoke Propagation Review A single fire originating within a plant fire area will be contained within the fire area of origin until extinguished. This is the case due to the fire rated barrier construction and associated closure assemblies (fire doors, fire dampers, seismic gap seals, and penetration seals) provided for the fire area boundary. All OMAs are performed outside the fire area of origin and the affected fire area does not have to be traversed in order to perform mitigating manual actions.
Therefore, fire propagation does not present an impediment to the performance of OMAs. However, smoke migration beyond the fire boundary could potentially occur as a result of the following:

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 20 of 117 WIP-E-1F9900-004-A-1
* Smoke migration through HVAC duct work or transfer grille prior to activation of the fusible link operated fire damper within the fire barrier opening created by the ductwork.
                                 " Smoke migration resulting from the momentary opening of a fire door within the boundary of the affected fire area to support fire fighting activities.
Smoke migration via ventilation ductwork or a transfer grille only presents a potential concern during the incipient stage of fire development. Once the 165 0 F activation temperature of the fusible link is attained, the fire damper will close. This action will substantially reduce ventilation related smoke migration beyond the fire boundary, effectively eliminating it as a smoke propagation concern. For fire dampers within ductwork, initial smoke migration would be limited to that entering ventilation diffusers, with the overall internal duct volume presenting an initial repository for the smoke and hot gases. Transfer grilles are open entirely to the fire environment, which presents a more ready means to spread smoke to an adjacent fire area during incipient stage fire development.
In an effort to limit smoke migration via ventilation systems, AP 10-106, Fire Preplans, identifies the HVAC equipment serving each fire area and the respective controls to shutdown each unit. This information provides the necessary guidelines to minimize smoke migration via ventilation equipment during a fire event. Prior to shutdown of the fan, smoke would be drawn into the return ductwork of the respective fan unit. The smoke would then be carried through the ductwork, through the filters and either be exhausted to the outside or re-circulated back into the areas served via the supply ductwork.
After a period of time, the filters could become clogged, causing the fan unit to shut down due to low air flow or high dP across the filters, at which time smoke migration through the ductwork would be limited to natural buoyancy of the heated smoke and gases.
Regarding smoke migration via a fire damper protected transfer grille, Table 5.1.6.1-1 identifies the fire areas containing a transfer grille that also require.a potential OMA within the same building if the subject fire area is involved in a fire event. OMAs occurring outside the building of fire origin are not a concern as no transfer grilles are present between power block buildings. Table 5.1.6.1-1 reveals that no transfer grilles directly communicate with an affected fire area and the location of an OMA. Additionally, the travel path necessary to perform the OMA is not subjected to a transfer grille within the affected fire area boundary. Therefore, initial smoke

Post-Fire Safe Shutdown Operator Manual Actions                                                               Page 21 of 117 WIP-E-1F9900-004-A-1 propagation through transfer grilles prior to fire damper activation, will not impede the performance of OMAs.
Table 5.1.6.1-1, Fire Locations with Transfer Grilles and OMAs Fire                                                                                         Room Where Location                                                              Fire Area Where                 OMA         Discussion (Fire          Ventilation Transfer Grille Review                 OMA Implemented             Implemented Area)
A-1            Fire area A-1 contains the following                A-25                         1322              Note 1 transfer grilles, identified by fire damper and communicating fire area:
GLD040 -> RW-1 GLD059, GLD060, GLD061 - A-4 GLD062, GLD063, GLD064 - A-2 GLD 167 -- A-7 GLD095 -> A-3 A-16           Fire area A-16 contains the following              A-23                          1508              Note 1 transfer grilles, identified by fire damper                                      1509 and communicating fire area:
GLD020 -4 A-18 GLD027 -- A-17 GLD170 - A-3 GLD194, GLD195         -> A-28 GLD0407 - A-26 GLD0411 -&#xf7;A-34 A-18           Fire area A-18 contains the following              A-25                          1322              Note 2 transfer grille, identified by fire damper and communicating fire area:
GLD020      -4 A-16 Notes:
Access to room or rooms where manual action is to be performed does not require the operator to traverse through any identified fire areas that communicate via a fusible link, fire damper protected transfer grille.
: 2.      Transfer grill is provided with a volume control damper that closes prior to Halon release in fire area A-18. A fusible link operated fire damper is also provided for the ventilation opening.
The potential to spread smoke and hot gases as a result of fire fighting efforts only presents a concern if egress to the manual action area is potentially impeded or the area where the manual action occurs is directly subjected to smoke migration via the periodic opening of an access doorway for entry into the affected fire area. A review of OMAs require to achieve and maintain hot standby identified two areas where fire-fighting activities could potentially expose the OMA operator to the fire environment as a result of opening an access door to fight the fire. These areas are identified in Table 5.1.6.1-2.
Fire Area A-27 is the MG Set Room on the 2026' Elevation of the Auxiliary Building. This fire area is protected by a total flooding halon system. It is accessible for fire fighting from the south end through door 14031. This door communicates with fire area A-16. As identified in Table 5.1.6.1-2, Fire Area A-16

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 22 of 117 WIP-E-1F9900-004-A-1 is the location where OMA action may be required in response to an A-27 fire. The manual action at valves EGHV0016 and EGHV0054 are located more than 40 ft from door 14031. This will be the closest point that the operator will be from door 14031, as access to A-16 is remotely located at either the southeast or northeast ends of the building via enclosed stairwells. The ceiling height within A-16 varies from 19'-10" to 20'"-6" with a corresponding fire area size of approximately 7,900 ft2 . This substantial room volume coupled with the separation distance between the communicating door and valves to be manipulated provides reasonable assurance that the periodic fire fighting entry through door 14031 will not present a smoke migration severity that would impede the performance of the OMAs in A-16.
Fire Area C-30 is a cable chase located on the 2047' elevation of the Control Building. The cable chase has no ventilation openings. However, the access door for the chase opens to the Control Room Cabinet area (south of general Control -
Room area). The OMA operator could potentially be exposed to the fire fighting efforts for the cable chase, since the initial operator response is to physically report to the Control Room for direction.
Considering the sensitivity of the cable chase location within the Control Room area, the fire brigade will be cautious to limit smoke propagation beyond the C-30 cable chase, and the duration for opening the cable chase door will be limited due to the small footprint (12' x 12') of the chase. Based on this, the OMA operator and overall OMA implementation will not be adversely affected by the fire fighting efforts for Fire Area C-30.
Table 5.1.6.1-2, Locations where OMA Operator Potentially Subjected to Fire Fighting Efforts Fire Location                     Fire Area Where OMA          Room OMA Performed (Fire Area)                           Performed A-27                                        A-16                           1402 C-30                                        C-27                          3601 5.1.7        Equipment Functionality and Accessibility Equipment credited for implementation of OMA was reviewed to ensure it is accessible, available, and not damaged by the affects of the fire.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 23 of 117 WIP-E-1F9900-004-A-1 5.1.8      Available Indications Availability of relevant diagnostic indications was reviewed to ensure operators would be able to:
0   Detect and diagnose fire location.
0   Assess the need to perform OMA.
0   Direct personnel performing OMA.
0   Provide feedback to the operators, if not directly observable, to verify that the OMA has provided the expected result and the manipulated equipment will remain in the desired position.
5.1.9      Communications Communication equipment was reviewed, to ensure an acceptable communication method is available to the extent it is needed.
The two primary communication systems available for use are the plant public address system (Gaitronics) and the 900 MHz radio system. The following is a review of Gaitronics and radio availability in the event of a fire outside the Control Room.
5.1.9.1      Gaitronics The main Gaitronics panel (QF076) is located in the Control Room back panel area. The Gaitronics system is powered from two separate and independent 120/208 VAC sources.
The normal source is from PN0703 in Fire Area C-16. Cable routing from PN0703 to QF076 is through Fire Areas C-16, C-18, C-24, C-21 and C-27. The emergency source of power is from PN0803 in fire area C-15. Cable routing from PN0803 to QF076 is through fire areas C-15, C-17, C-23, C-30, C-33, C-22 and C-27. Therefore, except for Fire Area C-27, a fire in any area will not affect both sources of 120 VAC power to the Gaitronics system.
The Gaitronics system utilizes 16-conductor cables to distribute 120 VAC power and communication signals to the field devices. A hot short across conductors within this cable could create noise in the system and/or damage multiple components (amplifiers, power supplies, etc), which will prevent operation of the system. Cables associated with the Gaitronics system are run in conduit, which will provide some protection against the effects of a fire. It is reasonable to conclude that a fire will be detected and fire brigade callout will occur prior to the Gaitronics system becoming damaged. After that, Gaitronics functionality may be adversely affected.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 24 of 117 WIP-E-1F9900-004-A-1 5.1.9.2    Radio The 900 MHz radio system main panel (QF362) is located in the Communication Corridor, elevation 2061-6. Power for panel QF362 is from batteries located adjacent to the Radio Equipment Room in Fire Area CC-I. The batteries are charged from the QA lighting system and have sufficient capacity to operate the radio system during the fire. A fire induced short anywhere along the coaxial communication cable, used for the antenna system, will disable the entire 900 MHz radio system. Table 5.1.9.2-1 identifies the fire areas where the coaxial cable is routed.
Table 5.1.9.2-1, 900 MHz Radio System Cable Routing Auxiliary Building       Control Building           Other A-1                      C-1                        CC-1 A-6                      C-2                        Reactor Building A-8                      C-3                        RW-1 A-16                     C-7                        Fuel Building A-18                     C-8 A-27                     C-11 A-33                     C-12 C-15 C-16 C-1 7 C-18 C-23 The on shift operator responsible for OFN KC-016 OMAs is trained to respond to the Control Room for instruction when a fire brigade callout announcement is made for a fire event.
This approach allows the Control Room operators to provide initial face-to-face direction to the operator responsible for implementing OFN KC-016 OMAs. For the majority of the plant OMAs, this is the only communication that will be required to successfully implement the OMAs. A copy of OFN KC-016 will also be available within the Control Room for OMA operator use, this will aid in ensuring that the operator manipulates the proper plant equipment.
The on shift operator responsible for OFN KC-01 6 OMAs is required to carry a radio on their person in effort to improve communication diversity.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 25 of 117 WIP-E-1F9900-004-A-1 5.1.10     Portable Equipment The portable equipment needed to successfully implement the OMA was identified and reviewed for availability and dedication to PFSSD, where appropriate.
In addition to the radio discussed above, the on shift operator responsible for OFN KC-016 OMAs is required to carry on their person the following portable equipment:
* Hand tool for cutting wire tab type locking devices on components that potentially would be required to be manipulated.
                        "   Master key to unlock electronic card reader controlled doors, in the event electronic door function is affected by the fire.
                        "   Flashlight to aid access/egress in the event normal lighting is affected by the fire.
* Key for ABFHCO002 and ABFHCO003 enclosure housings.
5.1.11     Personnel Protective Equipment (PPE)
The personnel protective equipment required to support the performance of the OMA is identified and assessed for availability. Hard hat, safety glasses, hearing protection, and gloves are not included in this review since this is the standard PPE complement, imposed by the WCNOC Safety Manual, for entry into industrial portions of the plant.
5.1.12     Procedures and Training Each OMA was reviewed to ensure it is included within OFN KC-016, Fire Response. This procedure contains the actions potentially necessary to ensure availability of a PFSSD success path following a single fire event outside the Control Room. The Operations department owns this procedure. Training for the procedure is on a biennial cycle. The procedure is also exercised during fire brigade drill activities that involve postulated fires affecting PFSSD success path. The procedure identifies the following information, per fire area with a potential OMA, to ensure Control Room personnel are aware of the potential fire impact on safe shutdown.
* Equipment susceptible to fire induced spurious operation that could affect PFSSD success path.
                       "    OMAs that are required to achieve PFSSD hot standby.
* OMA to mitigate spurious equipment operation.
* Available diagnostic instrumentation to aid in determining the need to perform OMA.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 26 of 117 WIP-E-1F9900-004-A-1 5.1.13     Staffing The manpower requirements for OMA implementation are identified and reviewed against Operations staffing level, taking into account the NUREG-1 852 guidance that Control Room or fire brigade personnel should not perform OMAs. This review is performed to ensure that an adequate number of qualified personnel will be available so that hot standby conditions can be achieved and maintained in the event of a fire.
One Operations individual is assigned OFN KC-016 OMA responsibility prior to taking the shift watch. This assignment is documented on the Shift Managers Relief Checklist (APF 21-001-01). This position assignment has no Control Room, Fire Brigade, or Emergency Planning responsibility.
5.1.14     Demonstration
: 1.       As previously identified, OMAs are identified within procedure OFN KC-016. The procedure is entered when a fire outside the Control Room is confirmed, as discussed in Section 5.1.4.
The Control Room Supervisor is responsible for directing OFN KC-016 actions. The procedure is configured such that another Control Room operator will review the applicable procedure attachment for potential OMAs. This approach ensures that Control Room personnel are promptly made aware of potential OMAs, including the instrumentation that can be relied upon to assess the need for performing the OMA. This is a continuous action step within the procedure, which means that the operator is responsible for observing the step for potential response throughout the fire event. Based on procedure structure and observed Control Room operator performance during fire brigade drill activities, it is conservatively concluded that Control Room personnel will consistently diagnose the need to perform a reactive OMA within seven (7) minutes of a confirmed fire alarm condition.
: 2.       The OMA response outside the Control Room was reviewed to determine that it could be successfully performed (to the extent practical) within the time constraints of this analysis. Multiple operations personnel were timed in the simulated performance of the OMA. The starting point for the timing evolution was the Work Control Center (Room 3613), which is adjacent to the Control Room on the 2047' elevation of the Communications Corridor.
Where multiple OMAs were involved for a particular fire area, the timing for each OMA was initiated from Room 3613. This approach was utilized in effort to conservatively account for each OMA response originating from the Control Room in the event that radio and Gaitronics communication capability is affected by the fire.
The following timing limitations were applied generically when conducting OMA demonstration timing:

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 27 of 117 WIP-E-1F9900-004-A-1
: a.       A time delay of two (2) minutes is included where electrical safety personnel protective equipment is required to be donned prior to performing the OMA. This time constraint is consistent with electrical safety dress-out times that have been demonstrated for OFN RP-017.
: b.       For fire areas with multiple OMAs where both Gaitronics and radio communication capability could be affected by the fire, a return trip to the Control Room is assumed to be necessary following the implementation of individual OMAs. This action is necessary in order for the operator to receive direction regarding additional required OMA response activities. A five (5) minute duration is applied for return trips to the Control Room from the Auxiliary Building and three (3) minutes for Control and Turbine Building.
These times were based on walk down time efforts from the most remote components requiring OMA implementation. A return trip following implementation of the final OMA was not postulated within the OMA timeline as available Control Room indication will reflect OMA implementation.
: 3.       Limitations (environmental, personnel protective equipment, tools, etc.) identified as applicable to the performance of the OMA were incorporated, to the extent practical, when conducting the OMA timed demonstration walkdowns.
5.1.15     Defense-In-Depth Analysis The concept of defense-in-depth, described in 10 CFR 50, Appendix R, is applied to fire protection in areas important to safety, with the following three objectives:
: 1. Prevent fires from starting.
: 2. Detect rapidly, control, and extinguish promptly those fires that do occur; and,
: 3. Provide protection of structures, systems, and components (SSCs) important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent safe shutdown of the plant.
These fire protection defense-in-depth objectives are assessed for each fire area where an OMA is credited for PFSSD.
5.1.16     Conclusion Considering the cumulative results of the OMA review, a conclusion statement is provided regarding the overall feasibility and reliability of the OMA.

Post-Fire Safe Shutdown Operator Manual Actions                                  Page 28 of 117 WIP-E-1F9900-004-A-1 6.0     E-1F9900 Revision Guidance 6.1     E-1 F9900 is part of the Approved Fire Protection Program, as it is incorporated by reference within Updated Safety Analysis Report (USAR). NRC review and approval was obtained for WIP-E-1 F9900-004-A-1. Subsequent changes to E-1 F9900 require prior NRC approval if any one of the following criteria is met:
6.1.1      A Required for Hot Standby OMA is being added.
6.1.2      The Time Margin for a Required for Hot Standby OMA is reduced by more than 10%.
6.2     Important to Safe Shutdown OMA additions or revisions do not require prior NRC approval provided analysis demonstrates that the OMA is feasible and reliable, considering NUREG-1852 guidance.
7.0     References 7.1     NRC Generic Letter 86-10, Implementation of Fire Protection Requirements, dated April 24,1986 7.2     10 CFR 50 Appendix R, Fire Protection Program For Nuclear Power Facilities Operating Prior To January 1, 1979 7.3     NRC Inspection Manual 0609, Appendix F, Fire Protection Significant Determination Process, dated 02/28/05.
7.4     NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities, published 09/2005 7.5     NUREG-1805, Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods for the U.S. Nuclear Regulatory Commission Fire Protection Inspection Program, published 12/2004 7.6     NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications 7.7     NUREG-1 852, Demonstration of the Feasibility and Reliability of Operator Manual Actions in Response to Fire, Published October 2007 7.8     Regulatory Guide 1.189, Fire Protection For Operating Nuclear Power Plants, March 2007 7.9     Federal Register Notice / Vol. 71, No. 43 / March 6, 2006, Fire Protection Program-Post-Fire Operator Manual Actions 7.10   Wolf Creek Letter WM 06-0013, from Richard Muench, 

==Subject:==
Response to Noncited Violation 2008-08-03 NRC Inspection Report 2005-08, dated April 14, 2006 7.11    NRC Letter EA-06-170 from Dwight Chamberlain, 

==Subject:==
Wolf Creek Generating Station - Revised Violation and Exercise of Enforcement Discretion 05000482/2005008-003 (NRC Inspection Report 05000482/2005008), dated July 25, 2006 [Wolf Creek Correspondence Number 06-00357]

Post-Fire Safe Shutdown Operator Manual Actions                               Page 29 of 117 WIP-E-1F9900-004-A-1 7.12    SECY 08-093, Resolution of Issues Related to Fire-Inducted Circuit Failures, dated June 30, 2008 7.13    NRC Letter from Annette L. Vietti-Cook, Secretary to R. W. Borchardt Executive Director for Operations, Staff Requirements - SECY-08-0093 - Resolution Of Issues Related To Fire-Induced Circuit Failures, dated September 3, 2008 7.14    NUREG-0881 SER and SSER through Supplement 5 7.15    Technical Specifications, Wolf Creek Generating Station, Table 1.1-1 (Modes),
Amendment 142 7.16    NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1 7.17    OFN KC-016, Fire Response Revision 21 7.18    OFN RP-017, Control Room Evacuation, Revision 29 7.19    AP 10-102, Control of Combustible Materials, Revision 13 7.20    AP 10-106, Fire Preplans, Revision 7 7.21    AP 21-001, Conduct of Operations, Revision 43 7.22    STS KJ-001A, Integrated D/G And Safeguards Actuation Test - Train A, Revision 36 7.23    WCNOC Electrical Safety Manual, Revision 7 7.24    Wolf Creek Safety Manual, Revision 11 7.25    E-1 F9910, Post Fire Safe Shutdown Fire Area Analysis, Revision 5 7.26    XX-E-013, Post-Fire Safe Shutdown (PFSSD) Analysis, Revision 1 7.27    Equipment Qualification Summary Document (EQSD) Section IV, Revision 0 7.28    WCNOC-CP-002, Thermal Hydraulic Analysis for Fires Outside Control Room, Revision 0 7.29    SA-08-006, Thermal Hydraulic Analysis [Control Room Fire], Revision 0 7.30    AN-96-062, RETRAN Analysis of Plant Shutdown Capability following a Postulated Fire in Fire Area A-18, Revision 0 7.31    NUREG/CR-6931, Cable Response to Live Fire (CAROLFIRE) Volume 1: Test Descriptions and Analysis of Circuit Response Data, Published April 2008

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 30 of 117 WIP-E-1 F9900-004-A-1 8.0     Feasibility and Reliability Review 8.1     Fire Area A-1, Auxiliary Building 1974' General Corridor 8.1.1      Fire Area Features Fire Area A-1 is the general corridor area on the 1974' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection is provided in areas where the PFSSD circuits of concern are routed. A preaction sprinkler system is located in areas with high concentration of cable trays.
8.1.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
8.1.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
8.1.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.1.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - An eight (8) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. Smoke detection is provided in areas where the PFSSD circuits of concern are routed. Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 31 of 117 WIP-E-1F9900-004-A-1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.1.14.
OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.1.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.
Time Margin - The time margin for OMA performance is one hundred forty one (141) minutes.
Fire Area A-1, Operator Manual Action Timeline (Minutes)
Fire Initiated Fire Indicated Diagnosis Time OMATime OAime           1;OMA Uncertainty 10     20   30    40    50  60    70   80   90    100 110 120   130 140 150 160 170  180 Time Margin Available Time Figure 8.1.4-1, Fire Area A-1 OMA Timeline 8.1.5         Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-1 reveals that a one hundred forty one (141) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 32 of 117 WIP-E-1F9900-004-A-1 8.1.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within the general corridor area of the Auxiliary Building 1974' elevation. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area A-1. Access to Fire Area A-25 does not require transition through Fire Area A-1. Fire Area A-1 is within the normal travel path for obtaining access to the Auxiliary Building. However, OFN KC-016 identifies that the exit from the Control Room through CAS Room 3609 and into 2047' of the Auxiliary Building may be utilized since normal access could be affected by the fire event. This is an improved travel path versus A-1 access, as fewer stairwell elevations are required to be traversed. The demonstration timing conducted from the Work Controls Center (3613) effectively bounds travel time utilizing the alternative access means. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers.
The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.1.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 33 of 117 WIP-E-lF9900-004-A-1 8.1.8      Available Indications Point addressable smoke detection is provided for the fire area. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
* Pressurizer level indicators BBLI0459A and BBLI0460A.
* VCT level indicators BGLI0112 and BGLI0185.
8.1.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.
8.1.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors ifthe fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry master key.
8.1.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.1.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 34 of 117 WIP-E-1F9900-004-A-1 8.1.13     Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.1.14     Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.
* Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty      -  3 minutes
                   "   Delay in obtaining and setting up ladder - 3 minutes 8.1.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection is provided for the majority of Fire Area A-I, including the areas where the PFSSD circuits of concern are routed. A preaction sprinkler system is located in areas with high concentration of cable trays.
Fire alarm annunciation is provided locally, and within the Control Room. Smoke detection is point addressable, allowing for prompt recognition of fire location. The preaction sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 35 of 117 WIP-E-1F9900-004-A-1
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in A-1 does not challenge PFSSD.
8.1.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-1 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty one (141) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 36 of 117 WIP-E-1F9900-004-A-1 8.2     Fire Area A-1 1, Auxiliary Buildinq 2000' Cable Chase 8.2.1      Fire Area Features Fire Area A-1 1 is a single room (1335) cable chase located on the 2000' elevation of the Auxiliary Building within the North Pipe Penetration Room. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.2.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
8.2.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
8.2.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.2.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A six (6) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, A-11 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to eleven (11) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                        Page 37 of 117 WIP-E-1F9900-004-A-1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.2.14.
OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.2.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.
Time Margin - The time margin for OMA performance is one hundred thirty eight (138) minutes.
Fire Area A-11, Operator Manual Action Timeline (Minutes)
Fire Initiated Fire Indicated Diagnosis Time TMATime         ',OMAUncertainty 10      20    30    40    50   60  70    80   90    100 110 120  130 140  150 160  170  180 Time Margin Available Time 4                                                                                             I Figure 8.2.4-1, Fire Area A-11 OMA Timeline 8.2.5           Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-1 1 reveals that a one hundred thirty eight (138) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 38 of 117 WIP-E-1F9900-004-A-1 8.2.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 1335 located on the 2000' elevation of the Auxiliary Building, within the North Pipe Penetration Room. The fire will be confined to the Fire Area A-1 1 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.2.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire -and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.2.8      Available Indications Point addressable smoke detection is provided for Cable Chase 1335.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
0   Pressurizer level indicator BBLI0460A.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 39 of 117 WIP-E-1 F9900-004-A-1 0   VCT level indicators BGLI0112 and BGLI0185.
8.2.9      Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.2.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.2.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.2.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.2.13     Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.2.14     Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.
0     Communication and feedback with Control Room - 1 minute

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 40 of 117 WIP-E-1F9900-004-A-1
* Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty - 3 minutes
* Delay in obtaining and setting up ladder - 3 minutes 8.2.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the general area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in A-11 does not challenge PFSSD.
8.2.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-1 1 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred thirty eight (138) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 41 of 117 WI P-E-1 F9900-004-A-1 8.3     Fire Area A-16, Auxiliary Building 2026' General Corridor 8.3.1      Fire Area Features Fire Area A-16 is the general corridor area on the 2026' elevation of the Auxiliary Building. It is effectively separated into two areas (A-16N and A-16S) by a 10 CFR 50 Appendix R, IIl.G.2.b, 20' combustible control zone.
The fire area is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection is provided, and a preaction sprinkler system is located in areas with a high concentration of cable trays.
8.3.2      Spurious Equipment Operation Requiring Operator Manual Action In A-16N, cables associated with steam generator atmospheric relief valves (ARV) ABPV0002 (steam generator 'B'), ABPV0003 (steam generator 'C'), and ABPV0004 (steam generator 'D') may be damaged, preventing control of theses valves from the Control Room. Additionally, auxiliary feedwater for steam generators 'A' and 'D' could be affected by a fire in this area.
This is an Important to Safe Shutdown spurious equipment operation, as Thermal Hydraulic Analysis WCNOC-CP-002 determined that hot standby conditions could be maintained with no action taken to close three spuriously open ARVs. Additionally, WCNOC-CP-002 determined that, for three spuriously failed closed ARVs, hot standby could be maintained via steam released through the steam generator safety valves. However, use of the safety valves is not the operational preferred method for maintaining post-fire hot standby. Therefore, it was conservatively concluded that a feasibility and reliability analysis would be completed for the A-16 actions addressing fire induced ARV maloperation. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire induced maloperation involves multiple steam release paths from the main steam system.
8.3.3      Operator Manual Action Description Steam generator ARV ABPV0002 can be controlled/isolated by manipulation of ABFHCO002. Steam generator ARV ABPV0003 can be controlled/isolated by manipulation of ABFHCO003. These components are located at local control stations in Fire Area A-23 on the 2037'-7" elevation of the Auxiliary Building (Reference Attachment C, Photos C-2 and C-3).
Steam generator ARV ABPV0004 can be isolated by closing air supply valve KAV1429 and nitrogen supply valve KAV1365, and then bleeding air from the regulator. The air and nitrogen supply valves and regulator are also located in Fire Area A-23, on the 2037'-7" elevation of the Auxiliary Building (Reference Attachment C, Photos C-4 through C-6).
Based on thermal hydraulic analysis (Reference 7.28 and 7.30), the operator can close ABPV0004 and either ABPV0002 or ABPV0003 and leave either ABPV0002 or ABPV0003 full open. The operator will report

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 42 of 117 WIP-E-1F9900-004-A-1 back to the Control Room for further instructions. The initial OMA response will be a Reactive Action.
8.3.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.3.4-1 reflects the OMA timeline in response to ARV ABPV0002 ABPV0003, and ABPV0004 maloperation. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1 805 for smoke detector response. Area detection is provided for Fire Area A-16.
Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.
Diagnosis Time - A seven (7) minute diagnosis time is utilized, based on Section 5.1.14.1.
OMA Implementation Time - A cumulative twenty seven (27) minute operator implementation time for performing the three OMAs is utilized, based on the demonstrated OMA walkdown time documented in Section 8.3.14.
OMA Uncertainty Time - A twenty six (26) minute OMA uncertainty time is utilized based on Section 8.3.14.
Available Time - Thermal hydraulic analysis AN-96-062 identifies that RHR entry conditions can be achieved in 94 hours after reactor trip ifa single steam generator ARV is used and; ifa second ARV is placed in service in 60 hours, RHR entry conditions can be achieved in 61 hours.
Furthermore, if either ARV ABPV0002 or ABPV0003 is left in the full open position with all remaining ARVs closed, cool down can be controlled from the Control Room by adjusting auxiliary feedwater flow to the associated steam generator with an open ARV. This approach is also supported by thermal hydraulic analysis WCNOC-CP-002, which identifies that three ARVs can remain spuriously open or closed for at least 200 minutes without adverse consequence to reactor performance.
Time Margin - The time margin for OMA performance is one hundred thirty six (136) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                          Page 43 of 117 WIP-E-1 F9900-004-A-1 Fire Area A-16, Operator Manual Action Timeline (Minutes)
Fire Initiated
     -1 Fire Indicated Diagnosis "1ie SMATime OMA Uncertainty 10    20    30   40   50   601 70  80   90   100 110 120 130 140 150 160 170 180 190 200 Time Margin Available Time Figure 8.3.4-1, Fire Area A-16 OMA Timeline 8.3.5            Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-16 reveals that a one hundred thirty six (136) minute time margin remains. Application of the uncertainty time, provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.
8.3.6            Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within the general corridor area of the Auxiliary Building 2026' elevation. The location of the OMAs is within the Main Steam Enclosure on the 2037'-7" elevation of the Auxiliary Building (Fire Area A-23). Based on fire barrier separation, the fire will be confined to Fire Area A-16. Access to Fire Area A-23 does not require transition through Fire Area A-16. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths, and the components requiring OMA manipulation. Normal radiation conditions within the areas of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 44 of 117 WIP-E-1 F9900-004-A-1 Temperature and humidity conditions within the Main Steam Enclosure will be elevated in the proximity of a spuriously open ARV. Historically, Operations has successfully isolated an ARV by closing its respective local isolation valve, which requires closer, long-term proximity to the ARV discharge line than the prescribed OMA. This historical success demonstrates that the environment within the Main Steam Enclosure will remain tenable regarding local temperature and humidity exposure during the prescribed OMA implementation. Additionally, the discharge piping in the area where the OMA is performed is insulated, which protects against contact exposure with the hot piping.
There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.
8.3.7      Equipment Functionality and Accessibility The components requiring manipulation for ARV control/isolation are mechanical. No equipment support functions are required for successful manual action implementation. Each is readily accessible for manipulation. These components are physically separated from the fire event by fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control. Key access is also required for the enclosure housing ARV controllers ABFHCO002 and ABFHCO003. The OFN KC-016 OMA operator also carries this key.
8.3.8     Available Indications Point addressable smoke detection is provided for Fire Area A-16. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.
To diagnose the spurious opening of an ARV, valve position indication or appropriate pressure instrumentation needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious opening of an ARV:
                        " ABPV0002 - Steam Generator 'B' pressure indication on ABPI524A
* ABPV0003 - Steam Generator 'C' pressure indication on ABPI534A

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 45 of 117 WIP-E-1 F9900-004-A-1
* ABPV0004 - Steam Generator 'D' pressure indication on ABPI544A 8.3.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout.
This approach allows the Control Room operators to provide face-to-face direction for the OMAs. OMA implementation approach provided in OFN KC-016 is based on availability of communication. If the fire affects communication, OFN KC-016 guidance will be followed to close ABPV0002 and open ABPV0003 and then physically report to the Control Room for further direction. The limiting scenario, reflected by the Figure 8.3.4-1 timeline is that the fire affects communication.
8.3.10     Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMAs. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. Wire cutters will be necessary to remove the lock tabs from the components to be manipulated for ARV ABPV0004 isolation. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters. Key access is also required for the enclosures housing ARV controllers ABFHCO002 and ABFHCO003. The OFN KC-016 OMA operator also carries this key.
8.3.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.3.12     Procedures and Training The OMAs are identified in OFN KC-016. Procedure direction is based on availability of communications. If communication is not affected by the fire, the direction for the ARVs, with a protected auxiliary feedwater source, is to close ABPV0002 and throttle open ABPV0003 per Control Room direction. If the fire affects communication, the direction is to close ABPV0002, open ABPV0003, and physically report back to the Control Room for further direction. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.3.13    Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 46 of 117 WIP-E-1F9900-004-A-1 8.3.14     Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. Each of the three OMAs were conservatively timed as independently originating from Room 3613 in recognition that radio and Gaitronics communication capability could be affected by the fire. The timing effort reflected that each OMA could be implemented in nine (9) minutes, for a cumulative OMA total of twenty-seven (27) minutes.
Once initial ARV control/isolation is established, PFSSD OMA capability is adequately demonstrated. Operations can continue to transition between the Main Steam Enclosure and the Control Room to affect ARV position change throughout the event course, or steam generator feedwater can be throttled from the Control Room to control decay heat removal. Based on the diversity of available decay heat removal options, timing considerations were that each ARV maloperation would have to be visited once for OMA implementation.
In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twenty-six (26) minutes.
* Communication and feedback with Control Room for OMAs - 3 minutes
* Electronically controlled door key access - 3 minutes
                   "    Obtain RCA access - 2 minutes
                   " Transition to Control Room from Fire Area A-23 after OMA implementation (three trips at 5 minutes per trip) - 15 minutes
* Human centered uncertainty     - 3 minutes 8.3.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. A 10 CFR 50 Appendix R, 20' combustible control zone is provided for separation of redundant component cooling water components.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection is provided for the area. A preaction sprinkler system is located in areas with high concentration of cable trays. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 47 of 117 WIP-E-1F9900-004-A-1 recognition of fire location. The preaction sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of III.G.2 protection to ensure a fire in A-16 does not challenge PFSSD.
8.3.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area A-16 are dependable, reliable, and can be consistently performed within the required Available Time. A one hundred thirty six (136) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Therefore, the OMAs are considered both feasible and reliable. Considering that WCNOC-CP-002 demonstrates that the maloperation of three ARVs does not require outside Control Room action to achieve and maintain post-fire hot standby, the feasibility and reliability analysis for A-1 6 provides an added defense in depth approach to ensure post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 48 of 117 WIP-E-1F9900-004-A-1 8.4     Fire Area A-18, Auxiliary Building 2026' North Electrical Penetration Room 8.4.1      Fire Area Features Fire Area A-18 is the North Electrical Penetration Room (1410) on the 2026' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Cross-zoned smoke detection is provided, which actuates a total flooding halon system for the room. A wet pipe sprinkler system is provided for the open cable chase in the northwest corner of the room.
8.4.2      Spurious Eguipment Operation Requirinq Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
Atmospheric relief valve (ARV) ABPV0002 could spuriously open as a result of an A-18 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown.
8.4.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
8.4.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.4.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.

Post-Fire Safe Shutdown Operator Manual Actions                                        Page 49 of 117 WIP-E-1F9900-004-A-1 Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Area smoke detection is provided. Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.4.14.
OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.4.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.
Time Margin - The limiting time margin for OMA performance is fifteen (15) minutes.
Fire Area A-18, Operator Manual Action Timeline (Minutes)
Fire Initiated Fire Indicated Diagnosis Time OMA Tim e              OMA Uncertainty 2   4     6   8 10 12      14 16 18   20 22 24 26 28 30      32 34 36 38 40 42 44 46 48 50 Time Margin Available Time Figure 8.4.4-1, Fire Area A-18 OMA Timeline

Post-Fire Safe Shutdown Operator Manual Actions                                  Page 50 of 117 WIP-E-1F9900-004-A-1 8.4.5      Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area A-1 8 reveals that a fifteen (15) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.
8.4.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within the North Electrical Penetration Room on the 2026' elevation of the Auxiliary Building. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area A-18. Access to Fire Area A-25 does not require transition through Fire Area A-18. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.4.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 51 of 117 WIP-E-1 F9900-004-A-1 8.4.8      Available Indications Point addressable smoke detection is provided for the North Electrical Penetration Room. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
* Pressurizer level indicator BBLI0460A.
* VCT level indicators BGLI0185 and BGLI0112.
8.4.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
The OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room ifthe Gaitronics or radio system functionality are affected by the fire.
8.4.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.4.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.4.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 52 of 117 WIP-E-1F9900-004-A-1 8.4.13     Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.4.14     Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.
                   "   Communication and feedback with Control Room - 1 minute
                   "   Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty - 3 minutes
                   "   Delay in obtaining and setting up ladder - 3 minutes 8.4.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.
: 2.      Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and a total flooding halon system are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler protection for the open cable chase and the general area halon protection will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided adjacent to the area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 53 of 117 WIP-E-1F9900-004-A-1
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in A-18 does not challenge PFSSD.
8.4.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-1 8 is dependable, reliable, and can be consistently performed within the required Available Time. A fifteen (15) minute time margin remains when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 54 of 117 WIP-E-1F9900-004-A-1 8.5     Fire Area C-7, Control Building 1984' Cable Chase 8.5.1       Fire Area Features Fire Area C-7 is a single room (3230) cable chase located on the 1984' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.5.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
8.5.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
8.5.4       Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.5.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-7 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                            Page 55 of 117 WIP-E-1F9900-004-A-1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.5.14.
OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.5.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.
Time Margin - The time margin for OMA performance is one hundred forty three (143) minutes.
Fire Area C-7, Operator Manual Action Timeline (Minutes)
Fire Initiated
     -         Fire Indicated Diagnosis Time OAi              ', OMA Uncertainty.
10     20    30     40    50  60     70   80    90   100 110  120 130   140 150 160  170 180 Time Margin Available Time I                                                                                                 I Figure 8.5.4-1, Fire Area C-7 OMA Timeline 8.5.5          Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-7 reveals that a one hundred forty three (143) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 56 of 117 WIP-E-1 F9900-004-A-1 8.5.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3230 located on the 1984' elevation of the Control Building. The OMA is in an adjacent structure within the Auxiliary Building. The fire will be confined to the Fire Area C-7 Cable Chase of origin, which contains no ventilation openings.
The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment. The cable chase door for C-7 opens into the normal travel path for obtaining access to the Auxiliary Building. However, OFN KC-016 identifies that the exit from the Control Room through CAS Room 3609 and into 2047' of the Auxiliary Building may be utilized since normal access could be affected by the fire event. This is an improved travel path versus Auxiliary Building access through Fire Area A-I, as fewer stairwell elevations are required to be traversed. The demonstration timing conducted from the Work Controls Center (3613) effectively bounds travel time utilizing the alternative access means.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.5.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.5.8     Available Indications Point addressable smoke detection is provided for Cable Chase 3230.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 57 of 117 WI P-E-1 F9900-004-A-1 To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
                      "   Pressurizer level indicators BBLI0459A and BBLI0460A.
                      " VCT level indicators BGLI0112 and BGLI0185.
8.5.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.
8.5.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.5.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.5.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.5.13     Staffinq The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 58 of 117 WIP-E-1F9900-004-A-1 8.5.14     Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.
* Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty - 3 minutes
                   "   Delay in obtaining and setting up ladder - 3 minutes 8.5.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3.      Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-7 does not challenge PFSSD.

Post-Fire Safe Shutdown Operator Manual Actions                                 Page 59 of 117 WIP-E-1F9900-004-A-1 8.5.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-7 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty three (143) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 60 of 117 WIP-E-1F9900-004-A-1 8.6     Fire Area C-12, Control Building 2000' North Cable Chase 8.6.1       Fire Area Features Fire Area C-12 is a single room (3306) cable chase located on the 2000' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.6.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
8.6.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
8.6.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.6.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-12 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 61 of 117 WIP-E-1 F9900-004-A-1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.6.14.
OMA Uncertainty Time -A twelve (12) minute OMA uncertainty time is utilized based on Section 8.6.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when letdown is the only flow diversion event, it can remain open for one hundred eighty (180) minutes without adverse consequence to reactor performance.
Time Margin - The time margin for OMA performance is one hundred forty three (143) minutes.
Fire Area C-12, Operator Manual Action Timeline (Minutes)
Fire Initiated Fire Indicated Diagnosis Time OMATime i      ; OMA Uncertainty 10     20    30    40    50  60   70   80    90   100 110  120 130   140 150 160 170  180 Time Margin Available Time Figure 8.6.4-1, Fire Area C-12 OMA Timeline 8.6.5          Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time,'and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-12 reveals that a one hundred forty three (143) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 62 of 117 WIP-E-1F9900-004-A-1 8.6.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3306 located on the 2000' elevation of the Control Building. The OMA is in an adjacent structure within the Auxiliary Building. The fire will be confined to the Fire Area C-12 Cable Chase of origin, which contains no ventilation openings.
The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.6.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.6.8     Available Indications Point addressable smoke detection is provided for Cable Chase 3306.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
0   Pressurizer level indicators BBLI0459A and BBLI0460A.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 63 of 117 WIP-E-1F9900-004-A-1 0   VCT level indicators BGLI0112 and BGLI0185.
8.6.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.
8.6.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.6.11     Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.6.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.6.13     Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.6.14      Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12) minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 64 of 117 WIP-E-1F9900-004-A-1
                   "    Communication and feedback with Control Room - 1 minute
                   "    Electronically controlled door key access - 3 minutes
                   "    Obtain RCA access - 2 minutes
                   "    Human centered uncertainty - 3 minutes
                   "    Delay in obtaining and setting up ladder - 3 minutes 8.6.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-12 does not challenge PFSSD.
8.6.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-12 is dependable, reliable, and can be consistently performed within the required Available Time. A one hundred forty three (143) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance. Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                  Page 65 of 117 WIP-E-1F9900-004-A-1 8.7     Fire Area C-18, Control Building 2016' Cable Chase 8.7.1      Fire Area Features Fire Area C-18 is a single room (3419) cable chase located on the 2016' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.7.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
Atmospheric relief valve (ARV) ABPV0001 could spuriously open as a result of a C-1 8 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown.
Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.7.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 66 of 117 WIP-E-1F9900-004-A-1 BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive aMA.
Containment spray pump PEN01A can be stopped by opening breaker NB0102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to Attachment C Photo C-7, for a photograph of the respective breaker.
This is a Reactive OMA.
8.7.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.7.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NB0102. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-18 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.
A six (6) minute operator action time is utilized for opening NB01 02, based on the demonstrated OMA walkdown time documented in Section 8.7.14.
A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.7.14.
OMA Uncertainty Time - A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.7.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.
E-1 F991 0 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Post-Fire Safe Shutdown Operator Manual Actions                                             Page 67 of 117 WIP-E-11F9900-004-A-1 Time Margin - The limiting time margin for OMA performance is three (3) minutes.
Fire Area C-18, Operator Manual Action Timeline (Minutes)
Fire Initiated
                 ; Fire Indicated
                                  'Dagnosis Tirre OMA Time CTM-T Spray OMA Time Letdow n 3i OMA Uncertainty I
2    4    6   8 10 12 14 16 18 20 22 24 26 28 30 32 343638 40 42 44 46 485052 54 56 58 60 Limiting Time Available Time                                Margin Letdown Available Time CTMT Spray Figure 8.7.4-1, Fire Area C-18 OMA Timeline 8.7.5            Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-1 8 reveals that a three (3) minute time margin remains for the most limiting OMA.
Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.
8.7.6           Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Cable Chase 3419 located on the 2016' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 68 of 117 WIP-E-1F9900-004-A-1 2000' elevation of the Control Building, within the north ESF Switchgear Room.
The fire will be confined to the Fire Area C-18 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.
8.7.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.7.8      Available Indications Point addressable smoke detection is provided for Cable Chase 3419.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
0   Pressurizer level indicator BBLI0460A.
                        . VCT level indicator BGLI0185.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 69 of 117 WIP-E-1F9900-004-A-1 To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
* RWST level indicators BNLI0931 and BNL1933.
* Containment pressure indicators GNP10934 and GNP10936.
8.7.9      Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
The OMAs do not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-01 6 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.
8.7.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.7.11     Personnel Protection Equipment Opening of breaker NB01 02 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.
8.7.12     Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.7.13    Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 70 of 117 WIP-E-1F9900-004-A-1 8.7.14     Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.
The timing effort reflected that the OMA for opening NBO102 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.
The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NB0102.
This results in a cumulative OMA implementation time of fifteen (15) minutes for KAV0201.
In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.
* Communication and feedback with Control Room - 2 minutes
* Electronically controlled door key access - 3 minutes
                   "   Obtain RCA access - 2 minutes
* Human centered uncertainty      -  3 minutes
* Delay in obtaining and setting up ladder - 3 minutes 8.7.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2.      Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the general area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 71 of 117 WIP-E-1 F9900-004-A-1
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of I1I.G.2 protection to ensure a fire in C-18 does not challenge PFSSD.
8.7.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-18 are dependable, reliable, and can be consistently performed within the required Available Time. A three (3) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                 Page 72 of 117 WIP-E-1 F9900-004-A-1 Spreading Room 8.8     Fire Area C-21, Control Building 2032' Lower Cable 8.8.1      Fire Area Features Fire Area C-21 is the Lower Cable Spreading Room (3501) on the 2032' elevation of the Control Building. The Room contains predominantly cable. It is separated from adjacent areas by 3-hour fire rated barriers.
Smoke detection and a preaction sprinkler system are provided for the area.
8.8.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
Atmospheric relief valve (ARV) ABPV0001 and ABPV0003 could spuriously open as a result of a C-21 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with two spuriously open ARVs.
However, the thermal hydraulic analysis determined that spuriously open ARVs concurrent with letdown does affect the available time for isolating letdown.
Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.8.3       Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 73 of 117 WIP-E-1F9900-004-A-1 Containment spray pump PEN01A can be stopped by opening breaker NB0102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to Attachment C, Photo C-7, for a photograph of the respective breaker.
This is a Reactive OMA.
8.8.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.8.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NB0102. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area C-21.
Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.
A six (6) minute operator action time is utilized for opening NB01 02, based on the demonstrated OMA walkdown time documented in Section 8.8.14.
A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.8.14.
OMA Uncertainty Time -A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.8.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.
E-1F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.
Time Margin - The limiting time margin for OMA performance is eight (8) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                               Page 74 of 117 WIP-E-1 F9900-004-A-1 Fire Area C-21, Operator Manual Action Timeline (Minutes)
Fire Initiated 4H    Fire Indicated Diagnosis Time OMA 1ime CTMT Spray OMA Ltdown
                                              -3me            OMA Uncertainty I 2    4    6   810 12 14 16 18 20 22 24 26 28 30 32 34 36 38 404           44 46 48 50 52 54 56 58 60 Limiting Time Available Time                                        Margin Letdown Available Time CTMT Spray Figure 8.8.4-1, Fire Area C-21 OMA Timeline 8.8.5           Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-21 reveals that an eight (8) minute time margin remains for the most limiting OMA.
Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.
8.8.6           Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Lower Cable Spreading Room on the 2032' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000' elevation of the Control Building, within the north ESF Switchgear Room.
Based on fire barrier separation, the fire will be confined to Fire Area C-21. The travel path and location of the equipment requiring

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 75 of 117 WIP-E-1 F9900-004-A-1 manipulation are physically separated from the fire by rated fire barriers.
The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.
8.8.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.8.8      Available Indications Point addressable smoke detection is provided for the Lower Cable Spreading Room. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
                        "   Pressurizer level indicator BBLI0460A.
                        "   VCT level indicator BGLI0185.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 76 of 117 WIP-E-1 F9900-004-A-1 instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
* RWST level indicators BNLI0931 and BNL1933.
                        "   Containment pressure indicators GNP10934 and GNP10936.
8.8.9      Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMAs do not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.8.10     Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors ifthe fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.8.11     Personnel Protection Equipment Opening of breaker NB01 02 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.
8.8.12     Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.8.13     Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 77 of 117 WIP-E-1F9900-004-A-1 8.8.14     Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.
The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NB01 02 This is conservative, as radio communication Will be available. The resulting cumulative OMA implementation time for KAV0201 is fifteen (15) minutes.
The timing effort reflected that the OMA for opening NBO102 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.
In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.
                   " Communication and feedback with Control Room - 2 minutes
                   " Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty - 3 minutes
                   "   Delay in obtaining and setting up ladder-.3 minutes 8.8.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and preaction sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, if necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 78 of 117 WIP-E-1 F9900-004-A-1
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of III.G.2 protection to ensure a fire in C-21 does not challenge PFSSD.
8.8.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-21 are dependable, reliable, and can be consistently performed within the required Available Time. An eight (8) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 79 of 117 WIP-E-1F9900-004-A-1 8.9     Fire Area C-22, Control Buildinq 2073'-6 Upper Cable Spreading Room 8.9.1      Fire Area Features Fire Area C-22 is the Upper Cable Spreading Room (3801) on the 2073'-
6" elevation of the Control Building. The Room contains predominantly cable. It is separated from adjacent areas by 3-hour fire rated barriers.
Smoke detection and a preaction sprinkler system are provided for the area.
8.9.2      Spurious Equipment Operation Reguiring Operator Manual Action Containment spray pump PEN01B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a MSO scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.9.3      Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-1 0). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.
8.9.4      Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.9.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area C-22.
Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.9.14.
OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.9.14.

Post-Fire Safe Shutdown Operator Manual Actions                                             Page 80 of 117 WIP-E-1F9900-004-A-1 Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.
Time Margin - The time margin for OMA performance is thirty nine (39) minutes.
Fire Area C-22, Operator Manual Action Timeline (Minutes)
Fire Initiated
      -I Fire Indicated SDiagnosis Time OMATime OMA Uncertainty 2 4       6   8  10 12 14 16 18 20822 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Time Margin Available Time Figure 8.9.4-1, Fire Area C-22 OMA Timeline 8.9.5             Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-22 reveals that a thirty nine (39) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.
8.9.6             Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Upper Cable Spreading Room on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.
The fire will be confined to Fire Area C-22 Upper Cable Spreading Room.
The travel path and location of the equipment requiring manipulation are

Post-Fire Safe Shutdown Operator Manual Actions                                       Page 81 of 117 WIP-E-1F9900-004-A-1 physically separated from the fire by multiple fire rated barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.9.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire rated barriers.
This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.9.8     Available Indications Point addressable smoke detection is provided for C-22. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
0   RWST level indicators BNLI0930 and BNLI0932.
                        . Containment pressure indicators GNP10935 and GNPI0937.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 82 of 117 WI P-E-1 F9900-004-A-1 8.9.9      Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.9.10     Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.9.11     Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMA.
8.9.12     Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.9.13     Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.9.14     Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.
                   . Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 83 of 117 WI P-E-1 F9900-004-A-1 0    Human centered uncertainty - 3 minutes 8.9.15     Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and preaction sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, if necessary. Fire extinguishers and hose stations are provided in the area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-22 does not challenge PFSSD.
8.9.16     Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-22 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty nine (39) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 84 of 117 WIP-E-1F9900-004-A-1 8.10    Fire Area C-23, Control Building 2032' South Cable Chase 8.10.1     Fire Area Features Fire Area C-23 is a single room (3505) cable chase located on the 2032' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.10.2     Spurious Equipment Operation Requiring Operator Manual Action Containment spray pump PEN01B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.10.3     Operator Manual Action Description Containment spray pump PEN01 B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-1 0). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.
8.10.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8:10.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-23 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

Post-Fire Safe Shutdown Operator Manual Actions                                                 Page 85 of 117 WIP-E-1F9900-004-A-1 OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.10.14.
OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.10.14.
Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.
Time Margin - The time margin for OMA performance is thirty four (34) minutes.
Fire Area C-23, Operator Manual Action Timeline (Minutes)
Fire Initiated Fire Indicated SDiagnosis Time OMATime
                                                       - OMA Uncertainty 2  4     6   8 10 12 14 16 18 20 22 24           28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Time Margin Available Time Figure 8.10.4-1, Fire Area C-23 OMA Timeline 8.10.5          Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-23 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.
8.10.6          Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3505 located on the 2032' elevation of the Control Building. The location of the OMA for

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 86 of 117 WIP-E-1F9900-004-A-1 stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.
The fire will be confined to the Fire Area C-23 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and the emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.10.7     Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire rated barriers.
This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.10.8     Available Indications Point addressable smoke detection is provided for Cable Chase 3505.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
                        . RWST level indicators BNLI0930 and BNLI0932.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 87 of 117 WIP-E-1F9900-004-A-1
* Containment pressure indicators GNP10935 and GNPI0937.
8.10.9     Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
The OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room for further direction, if the Gaitronics or radio system functionality is affected by the fire.
8.10.10    Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.10.11    Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMA.
8.10.12    Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.10.13    Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.10.14    Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 88 of 117 WIP-E-1 F9900-004-A-1 have been included, resulting in a total uncertainty time of seven (7) minutes.
                   "    Communication and feedback with Control Room - 1 minute
                   "    Electronically controlled door key access - 3 minutes
                   "    Human centered uncertainty - 3 minutes 8.10.15    Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-23 does not challenge PFSSD.
8.10.16    Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-23 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty four (34) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 89 of 117 WI P-E-1 F9900-004-A-1 8.11     Fire Area C-24, Control Buildinq 2032' North Cable Chase 8.11.1       Fire Area Features Fire Area C-24 is a single room (3504) cable chase located on the 2032' elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.11.2      Spurious Equipment Operation Requiring Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
Atmospheric relief valve (ARV) ABPV0001 could spuriously open as a result of a C-24 fire. Thermal hydraulic analysis WCNOC-CP-002 determined that no operator action is required to achieve and maintain hot standby with a spuriously open ARV. However, the thermal hydraulic analysis determined that a spuriously open ARV concurrent with letdown does affect the available time for isolating letdown.
Containment spray pump PEN01A could spuriously start and discharge valve ENHV0006 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.11.3      Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment C, Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 90 of 117 WIP-E-1F9900-004-A-1 BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.
Containment spray pump PEN01A can be stopped by opening breaker NB0102. The breaker is located on 4.16 KV bus NB01 within the Control Building 2000' north ESF Switchgear Room (Fire Area C-9). Refer to Attachment C, Photo C-7, for a photograph of the respective breaker.
This is a Reactive OMA.
8.11.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.11.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460 and opening breaker NB0102. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-24 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - Implementation sequence for the two OMAs will be based on Control Room diagnosis. The conservative approach from a feasibility and reliability timing perspective is to postulate that letdown isolation is addressed second in the sequence of OMA events. This is conservative since letdown has a more restrictive available time for OMA implementation.
A six (6) minute operator action time is utilized for opening NB0102, based on the demonstrated OMA walkdown time documented in Section 8.11.14.
A fifteen (15) minute operator action time is utilized for isolating KAV0201, based on the demonstrated OMA walkdown time documented in Section 8.11.14.
OMA Uncertainty Time - A thirteen (13) minute OMA uncertainty time is utilized based on Section 8.11.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies when letdown is open, concurrent with spuriously open atmospheric relief valve related cooling, letdown can remain open for fifty (50) minutes, without adverse consequence to reactor performance.
E-1F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.

Post-Fire Safe Shutdown Operator Manual Actions                                          Page 91 of 117 WIP-E-1F9900-004-A-1 Time Margin - The limiting time margin for OMA performance is three (3) minutes.
Fire Area C-24, Operator Manual Action Timeline (Minutes)
Fire Initiated
                 -  Fire Indicated
                                   'Dagnosis Time OMA Time CTMTW Spray OMA Time Letdown OMA Uncertainty S2      4 6      810 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Limiting Time Available Time                             Margin Letdown Available Time CTMT Spray Figure 8.11.4-1, Fire Area C-24 OMA Timeline 8.11.5            Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-24 reveals that a three (3) minute time margin remains for the most limiting OMA.
Application of the uncertainty time provides reasonable assurance that the OMAs are dependable, reliable, and can be performed with a high rate of success.
8.11.6             Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within Cable Chase 3504 located on the 2032' elevation of the Control Building. The location of the OMA for isolating KAV0201 is in an adjacent structure on the 2000' elevation of the Auxiliary Building, within the south Pipe Penetration Room. The location of the OMA for stopping PEN01A containment spray is located on the 2000' elevation of the Control Building, within the north ESF Switchgear Room.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 92 of 117 WIP-E-1 F9900-004-A-1 The fire will be confined to the Fire Area C-24 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths, the emergency equipment cabinet necessitating access for retrieval of personal protective equipment, and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the OMA areas will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMAs.
8.11.7     Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by several fire rated barriers. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.11.8     Available Indications Point addressable smoke detection is provided for Cable Chase 3504.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
* Pressurizer level indicator BBLI0460A
* VCT level indicator BGLI0185.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 93 of 117 WIP-E-lF9900-004-A-1 indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
* RWST level indicators BNLI0931 and BNL1933.
* Containment pressure indicators GNP10934 and GNP10936.
8.11.9     Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMAs do not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.11.10    Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors ifthe fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.11.11   Personnel Protection Equipment Opening of breaker NB0102 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, which is adjacent to the room where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Auxiliary or Control Building access, is required to perform the OMAs.
8.11.12   Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.11.13    Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 94 of 117 WIP-E-1 F9900-004-A-1 8.11.14    Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor.
The timing effort reflected that the OMA for opening NB01 02 could be implemented in six (6) minutes. This included time for donning electrical safety PPE.
The timing effort reflected that the OMA for isolating KAV0201 could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
Additionally, three (3) minutes is included in the OMA time for the operator to return to the Control Room after opening breaker NBO102.
This is conservative, as radio communication will be available. The resulting cumulative OMA implementation time for KAV0201 is fifteen (15) minutes.
In addition, the following uncertainty times have been included, resulting in a total uncertainty time of thirteen (13) minutes.
* Communication and feedback with Control Room - 2 minutes
* Electronically controlled door key access - 3 minutes
                   "    Obtain RCA access - 2 minutes
                   "    Human centered uncertainty - 3 minutes
* Delay in obtaining and setting up ladder - 3 minutes 8.11.15    Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMAs. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMAs. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied,

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 95 of 117 WIP-E-lF9900-004-A-1 as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs are utilized in lieu of III.G.2 protection to ensure a fire in C-24 does not challenge PFSSD.
8.11.16    Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-24 is dependable, reliable, and can be consistently performed within the required Available' Time. A three (3) minute time margin remains for the most limiting OMA, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance or unacceptable loss of RWST inventory. Therefore, the OMAs are considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 96 of 117 WIP-E-lF9900-004-A-1 8.12    Fire Area C-30, Control Buildinq 2047'-6" Cable Chase 8.12.1     Fire Area Features Fire Area C-30 is a single room (3617) cable chase located on the 2047'-
6" elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.12.2     Spurious Eguipment Operation Requiring Operator Manual Action Containment spray pump PEN01B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation,. as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.12.3     Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-1 0). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.
8.12.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.12.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A nine (9) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-30 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to fourteen (14) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

Post-Fire Safe Shutdown Operator Manual Actions                                          Page 97 of 117 WIP-E-1F9900-004-A-1 OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.12.14.
OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.12.14.
Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.
Time Margin - The time margin for OMA performance is twenty six (26) minutes.
Fire Area C-30, Operator Manual Action Timeline (Minutes)
Fire Initiated I  Fire Indicated SDiagnosis Time
                                             . 0MAiim
                                                .         ...    . OMA .Uncertainty 2   4    6   8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 Time Margin Available Time Figure 8.12.4-1, Fire Area C-30 OMA Timeline 8.12.5          Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-30 reveals that a twenty six (26) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.
8.12.6           Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3617 located on the 2047' elevation of the Control Building. The location of the OMA for

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 98 of 117 WIP-E-1F9900-004-A-1 stopping PEN01 B containment spray is located on the 2000' elevation of the Control Building within the south ESF Switchgear Room.
The fire will be confined to the Fire Area C-30 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers. The access door for the cable chase opens to the back of the Control Room in the equipment cabinet area.
The OMA operator will be present in the Control Room in order to receive OMA implementation direction. Manual fire fighting efforts, if necessary, will require periodic opening of the cable chase door. However, the smoke propagation review documented in Section 5.1.6 determined that OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.12.7    Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire rated barriers.
This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.12.8     Available Indications Point addressable smoke detection is provided for Cable Chase 3617.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 99 of 117 WIP-E-1F9900-004-A-1 indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
* RWST level indicators BNLI0930 and BNLI0932.
* Containment pressure indicators GNP10935 and GNP10937.
8.12.9     Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.12.10    Portable Eguipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters.
8.12.11    Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMAs.
8.12.12    Procedures and Training The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.12.13   Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.12.14   Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 100 of 117 WIP-E-1 F9900-004-A-1 be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.
* Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Human centered uncertainty - 3 minutes 8.12.15    Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-30 does not challenge PFSSD.
8.12.16    Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMAs for Fire Area C-30 are dependable, reliable, and can be consistently performed within the required Available Time. A twenty six (26) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 101 of 117 WIP-E-1F9900-004-A-1 8.13    Fire Area C-33, Control Building 2073'-6" South Cable Chase 8.13.1     Fire Area Features Fire Area C-33 is a single room (3804) cable chase located on the 2073'-
6" elevation of the Control Building. The chase contains cable and normal room lighting only. It is separated from adjacent areas by 3-hour fire rated barriers. Smoke detection and wet pipe sprinkler protection are provided for the area. No natural or forced ventilation is provided for the fire area. General access to the cable chase is restricted by a normally locked fire door.
8.13.2     Spurious Equipment Operation Requiring Operator Manual Action Containment spray pump PEN01B could spuriously start and discharge valve ENHV0012 could spuriously open due to fire induced cable damage. This would result in containment spray actuation. Containment spray is an Important to Safe Shutdown spurious equipment operation, as the event would divert RWST inventory to the containment sump. This is a multiple spurious operation scenario from a PFSSD perspective, as two fire induced component maloperation events are required before containment spray would be spuriously actuated.
8.13.3     Operator Manual Action Description Containment spray pump PEN01B can be stopped by opening breaker NB0203. The breaker is located on 4.16 KV bus NB02 within the Control Building 2000' south ESF Switchgear Room (Fire Area C-10). Refer to Attachment C, Photo C-8, for photograph of the respective breaker. This is a Reactive OMA.
8.13.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.13.4-1 reflects the OMA timeline in response to spurious containment spray actuation. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A one (1) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. However, C-33 contains only one smoke detector within the cable chase. Therefore, physical confirmation of the fire event is necessary. This confirmation is postulated to take up to five (5) minutes following receipt of the initial fire alarm indication in the Control Room. This increases the total fire detected time to six (6) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.

Post-Fire Safe Shutdown Operator Manual Actions                                              Page 102 of 117 WIP-E-1 F9900-004-A-1 OMA Implementation Time - A six (6) minute operator implementation time is utilized based on the demonstrated OMA walkdown time documented in Section 8.13.14.
OMA Uncertainty Time - A seven (7) minute OMA uncertainty time is utilized based on Section 8.13.14.
Available Time - E-1 F9910 identifies that containment spray can operate for sixty (60) minutes before RWST level will be below that required for cold shutdown.
Time Margin - The time margin for OMA performance is thirty four (34) minutes.
Fire Area C-33, Operator Manual Action Timeline (Minutes) 4 Fire Initiated 4            - Fire Indicated SDagnosis Tirme OMATime a                 OMA Uncertainty 2   4     6   810 12 14 16 18 20 22 246        28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 28    Time Margin Available Time I
Figure 8.13.4-1, Fire Area C-33 OMA Timeline 8.13.5           Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area C-33 reveals that a thirty four (34) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 103 of 117 WIP-E-1 F9900-004-A-1 8.13.6     Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Cable Chase 3804 located on the 2073'-6" elevation of the Control Building. The location of the OMA for stopping PEN01 B containment spray is on the 2000' elevation of the Control Building within the south ESF Switchgear Room.
The fire will be confined to the Fire Area C-33 Cable Chase of origin, which contains no ventilation openings. The travel path and location of the equipment requiring manipulation are physically separated from the fire by multiple fire rated barriers, ensuring that smoke propagation and fire fighting activities will not present an egress impediment.
Emergency lighting is provided for illumination of potential egress paths, the component requiring OMA manipulation, and the emergency equipment cabinet necessitating access for retrieval of personal protective equipment. Normal radiation, temperature, and humidity conditions will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.13.7     Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The component requiring manipulation is an electrical breaker. The breaker is readily accessible for manipulation. It is physically separated from the fire event by several fire rated barriers.
This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.13.8    Available Indications Point addressable smoke detection is provided for Cable Chase 3804.
Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the cable chase.
To diagnose spurious operation of containment spray, the pump breaker status indication, containment spray flow indication, containment pressure

Post-Fire Safe Shutdown Operator Manual Actions                                  Page 104 of 117 WIP-E-1 F9900-004-A-1 indication, or RWST level indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of spurious containment spray actuation:
* RWST level indicators BNLI0930 and BNLI0932.
* Containment pressure indicators GNP10935 and GNP10937.
8.13.9     Communications A fire in this area could affect the Gaitronics system. The 900 MHz radio communication system is unaffected by the fire. The OMA does not require constant communication with the Control Room. After initially reporting to the Control Room, the operator will receive face-to-face direction regarding OMA implementation. The operator may then use the radio system as necessary, or report directly back to the Control Room for further instruction.
8.13.10    Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key and wire cutters.
8.13.11    Personnel Protection Equipment Opening of breaker NB0203 requires donning of electrical safety gear to protect against potential arc flash. This PPE is located within Fire Area C-10, where the OMA is performed.
No other personnel protective equipment, beyond that normally necessary for Control Building access, is required to perform the OMAs.
8.13.12    Procedures and Traininq The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.13.13   Staffing The operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.13.14   Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 105 of 117 WIP-E-1 F9900-004-A-1 be consistently performed within six (6) minutes. This included time to don electrical safety PPE. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of seven (7) minutes.
* Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Human centered uncertainty - 3 minutes 8.13.15    Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the cable chase is normally locked, which prevents general access to the area.
: 2. Detect, Control, and Extinguish Fires This objective is not affected by the OMA. Smoke detection and wet pipe sprinkler protection are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room.
Smoke detection is point addressable, allowing for prompt recognition of fire location. The sprinkler system will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and hose stations are provided in the adjacent area for manual fire fighting.
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in C-33 does not challenge PFSSD.
8.13.16   Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area C-33 is dependable, reliable, and can be consistently performed within the required Available Time. A thirty four (34) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no unacceptable loss of RWST inventory.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                  Page 106 of 117 WIP-E-1F9900-004-A-1 8.14    Fire Area RB, Reactor Building General Area 8.14.1     Fire Area Features Fire Area RB is all elevations of the Reactor Building. The 4-foot-thick Reactor Building walls serve as the fire barrier separation from adjacent Buildings. There are no fire rated barriers walls or floors internal to the Reactor Building, though substantial barrier and spatial separation are provided within the building. Linear heat detection is installed above each reactor coolant pump and in areas where cable trays are concentrated.
Duct smoke detection is provided for each containment cooler. A fixed, manually charged, closed head sprinkler system is provided for the north and south cable penetration areas on the 2026' elevation.
8.14.2     Spurious Equipment Operation Requirinq Operator Manual Action Cables associated with letdown isolation valves BGLCV0459 and BGLCV0460 may be damaged, preventing these valves from being closed from the Control Room. PFSSD requires one of these valves to be closed to ensure adequate charging flow.
This spurious equipment operation is Important to Safe Shutdown, as letdown is not required for PFSSD. However, letdown isolation is required to prevent RCS flow diversion. This event is a multiple spurious equipment operation from a PFSSD perspective, as the fire-induced maloperation involves two series valves in the chemical and volume control system.
Cables associated with excess letdown isolation valves BGHV8153A and BGHV8154A may be damaged, preventing these valves from being closed from the Control Room. Thermal hydraulic analysis WCNOC-CP-002 reveals that these valves may remain open, with no adverse impact to PFSSD, provided letdown is isolated within one hundred twenty (120) minutes.
8.14.3     Operator Manual Action Description Valves BGLCV0459 and BGLCV0460 can be isolated by closing instrument air supply valve KAV0201 located in the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Reference Attachment, C Photo C-1). This removes air to BGLCV0459, BGLCV0460, and all air operated components within the Reactor Building. Historical performance of STS KJ-001A, which isolates instrument air to the Reactor Building, reveals that BGLCV0459 and BGLCV0460 will fail closed within three (3) minutes following isolation of instrument air. This is a Reactive OMA.

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 107 of 117 WIP-E-1F9900-004-A-1 8.14.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.14.4-1 reflects the OMA timeline for closing BGLCV0459 and BGLCV0460. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - Total coverage fire alarm detection is not provided for the Reactor Building. The majority of the detection provided responds to thermal change due to fire and not the smoke products of combustion (duct smoke detection is provided for the containment coolers). Thermal detection typically responds to a fire event slower than smoke detection.
Additionally, the Reactor Building is not normally occupied and is not as readily accessible as the Control or Auxiliary Buildings. Therefore, the time for Reactor Building fire indication is postulated to be up to sixty (60) minutes. This is a conservatively reasonable time as a fire that adversely affects all letdown/excess letdown isolation valves would be of significant severity that fire detection would occur within sixty (60) minutes.
Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.14.14.
OMA Uncertainty Time - A twelve (12) minute OMA uncertainty time is utilized based on Section 8.14.14.
Available Time - Thermal hydraulic analysis WCNOC-CP-002 identifies that when both letdown and excess letdown flow diversion events are active concurrently, excess letdown may remain open provided letdown is isolated in one hundred and twenty (120) minutes. Implementation within the Available Time ensures there will be no adverse consequence to reactor performance.
Due to substantial spatial separation between cables and the valves of concern, it is unlikely that a fire event would involve the maloperation of all isolation valves associated with letdown and excess letdown.
However, from an OMA timeline perspective, it is conservatively assumed that all excess letdown and letdown isolation valves are simultaneously affected by the same fire, since the literal separation of requirements of 10 CFR 50 Appendix R Section III.G.2 are not fully satisfied.
Time Margin - The time margin for OMA performance is twenty nine (29) minutes.

Post-Fire Safe Shutdown Operator Manual Actions                                             Page 108 of 117 WIP-E-1F9900-004-A-1 Fire Area RB, Operator Manual Action Timeline (Minutes)
Fire Initiated I Fire Indicated Dagnosis Time OMA Time OMA Uncertainty 2*
10      20      30     40      50       60        70      80     90    100      110   12 0 6     Time Margin Available Time Figure 8.14.4-1, Fire Area RB OMA Timeline 8.14.5         Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time, within the OMA event timeline. The OMA Timeline for Fire Area RB reveals that a twenty nine (29) minute time margin remains. Application of the uncertainty time provides reasonable assurance that the OMA is dependable, reliable, and can be performed with a high rate of success.
8.14.6         Environmental Factors Habitable environmental conditions will be present for performance of the OMA. The postulated fire event is within Reactor Building. The location of the OMA is within the South Pipe Penetration Room on the 2000' elevation of the Auxiliary Building (Fire Area A-25). Based on fire barrier separation, the fire will be confined to Fire Area RB. Access to Fire Area A-25 does not require transition through Fire Area RB. The travel path and location of the equipment requiring manipulation are physically separated from the fire by rated fire barriers. The smoke propagation review documented in Section 5.1.6 determined that the described OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths and the component requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 109 of 117 WIP-E-1F9900-004-A-1 There are no physical impediments in proximity to the manual action component that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.14.7     Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA component is physically separated from the fire event by a the Reactor Building external wall. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.14.8     Available Indications Point addressable duct smoke detection is provided for the containment coolers. Linear detection is provided for the reactor coolant pumps and areas with cable tray concentration. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the alarm. This will likely be the first indication of a fire event within area.
To diagnose a failure of BGLCV0459 and BGLCV0460 to close, valve position indication or appropriate level indication needs to be available.
The following instrumentation is unaffected by the fire and is available to assist Control Room diagnosis of BGLCV0459 and BGLCV0460 failure to close:
* Pressurizer level indicator BBLI0460A.
* VCT level indicators BGLI0112 and BGLI0185.
To diagnose a failure of the excess letdown valves, valve position indication of appropriate level indication needs to be available. The valve position indication cables are located in the same area of the Reactor Building as the valves, so position indication cannot be relied on. The excess letdown valves discharge to the Pressurizer Relief Tank (PRT) inside the Reactor Building. Since the PRT is also inside Reactor Building, its level indication could also be affected by the same fire.
Therefore, there is no direct reliable indication of the failure for excess letdown to isolated. However, based on a thermal hydraulic analysis WCNOC-CP-002, a charging pump will adequately compensate for the loss of inventory from the one inch excess letdown line, which flows approximately 50 gpm at full reactor pressure. Pressurizer level indicator BBLI0460A will be available and both of the VCT level indicators, BGLI0112 and BGLI0185, will be available. However, as previously

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 110 of 117 WIP-E-1F9900-004-A-1 identified, no action is required for excess letdown isolation to maintain hot standby, provided letdown is isolated in one hundred twenty (120) minutes.
8.14.9     Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
This OMA does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room operators to provide face-to-face direction for the OMA. Once the OMA has been implemented, the operator can physically report back to the Control Room if the Gaitronics or radio system functionality are affected by the fire.
8.14.10    Portable Equipment KAV0201 is located approximately 10' above the floor. Access to a portable ladder for OMA implementation is available. No other portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMA.
Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.14.11    Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMA.
8.14.12    Procedures and Traininq The OMA is identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.14.13    Staffing The operator assigned OFN KC-016 OMA duty for the shift is responsible for performing the OMA. Only one person is required to perform the OMA.
8.14.14    Demonstrations The OMA was timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMA could be consistently performed within nine (9) minutes. This included time to obtain a ladder to reach KAV0201. The three (3) minute delay for BGLCV0459 and BGLCV0460 closure following the isolation of instrument air is also factored into the overall OMA implementation time.
This results in a cumulative OMA implementation time of twelve (12)

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 111 of 117 WIP-E-1F9900-004-A-1 minutes. In addition, the following uncertainty times have been included, resulting in a total uncertainty time of twelve (12) minutes.
* Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
* Human centered uncertainty - 3 minutes
* Delay in obtaining and setting up ladder- 3 minutes 8.14.15    Defense-In-Depth
: 1. Fire Prevention The objective of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety. Additionally, the area is not normally occupied, which limits the potential for the introduction of transient fire hazards.
: 2. Detect, Control, and Extinguish Fires Considering the conservative OMA timeline application for fire indication, this objective is not affected by the OMA. Linear heat detection is installed above each reactor coolant pump and in areas where cable trays are concentrated. Duct smoke detection is provided for each containment cooler. Fire alarm annunciation is provided locally, and within the Control Room. Alarms are zoned, allowing for prompt recognition of fire location.
A system is provided to collect and contain lubricating oil for each reactor coolant pump (RCP). The RCP oil spillage protection and control system consists of a package of splash guards, catch basins, and enclosure assemblies as attachments to the RCP motors at strategic locations to preclude the possibility of oil making contact with hot components and pipe.
All fire water system piping within the Reactor Building is maintained dry by two normally closed isolation valves located in series on the same supply line. These valves are located in the south Pipe Penetration Room on the 2026' elevation of the Auxiliary Building.
A fixed, manually charged, closed head sprinkler system is provided for the north and south cable penetration areas on the 2026' elevation. The preaction sprinkler system, will aid in controlling the fire event within the cable penetration areas. Fire extinguishers and hose stations are also provided within the Reactor Building for manual fire fighting.

Post-Fire Safe Shutdown Operator Manual Actions                                    Page 112 of 117 WIP-E-1 F9900-004-A-1
: 3. Protection of SSCs so that Fires Will Not Prevent Safe Shutdown Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMA is utilized in lieu of III.G.2 protection to ensure a fire in RB does not challenge PFSSD.
8.14.16    Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area RB is dependable, reliable, and can be consistently performed within the required Available Time. A twenty nine (29) minute time margin remains, when applying uncertainty elements to ensure OMA reliability. Post-fire safe shutdown capability is maintained with no adverse reactor thermal performance.
Therefore, the OMA is considered both feasible and reliable.

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 113 of 117 WIP-E-1 F9900-004-A-1 8.15    Fire Area A-27, Auxiliary Building 2026' Rod Drive MG Set Room 8.15.1     Fire Area Features Fire Area A-27 is the Rod Drive MG Set Room (1403) on the 2026' elevation of the Auxiliary Building. The fire area is separated from adjacent areas by 3-hour fire rated barriers. Cross-zoned smoke detection is provided, which actuates a total flooding halon system for the room.
8.15.2     Spurious Equipment Operation Requiring Operator Manual Action Cables associated with component cooling water (CCW) isolation valves EGHV0016 andEGHV0054 may be damaged, preventing the valves from being opened from the Control Room. The fire induced failure mode for EGHV0016 and EGHV0054 is the as is position. These valves are normally closed when 'A' CCW is operating. 'B' CCW is credited for an A-27 fire, as 'A' train CCW operability can be affected by the postulated fire. Swap over from 'A' to 'B' CCW would require opening of EGHV0016 and EGHV0054, which could be failed in the closed position as a result of fire induced circuit interaction. No OMA is required if 'B' train CCW is operating prior to the fire event, as EGHV0016 and EGHV0054 will be open to support charging pump operability, and the valves will not maloperate to the closed position as a result of the fire.
8.15.3     Operator Manual Action Description Motor operated valve EGHV0016 is located on the 2026' elevation of the Auxiliary Building in the general corridor (1402) area of Fire Area A-16.
(Reference Attachment C, Photo C-9). The valve can be manipulated locally by declutching the motor and manually opening the valve.
Motor operated valve EGHV0054 is located on the 2026' elevation of the Auxiliary Building in the 'B' CCW (1401) area of Fire Area A-16.
(Reference Attachment C, Photo C-10). The valve can be manipulated locally by declutching the motor and manually opening the valve.
Local opening of EGHV0016 and EGHV0054 is a Reactive OMA.
8.15.4     Feasibility Analysis of Time Available to Perform Manual Actions Figure 8.15.4-1 reflects the OMA timeline for opening EGHV0016 and EGHV0054. The identified times are based on the following:
Fire Initiated - This is the initiating event, which occurs at time zero.
Fire Indicated - A four (4) minute detection response time is utilized based on the Attachment B1 application of NUREG-1805 for smoke detector response. Total area detection is provided for Fire Area A-27.
Therefore, multiple detection alarms would be initiated for a fire event warranting OMA response action.

Post-Fire Safe Shutdown Operator Manual Actions                                            Page 114 of 117 WIP-E-1F9900-004-A-1 Diagnosis Time - A seven (7) minute diagnosis time is utilized based on Section 5.1.14.1.
OMA Implementation Time - A cumulative twelve (12) minute operator action time is utilized based on the demonstrated OMA walkdown time documented in Section 8.15.14.
OMA Uncertainty Time - A nine (9) minute OMA uncertainty time is utilized based on Section 8.15.14.
Available Time - Thermal hydraulic analysis SA-08-006 and E-1 F991 0 identify that charging, and thus CCW, must be established within twenty eight (28) minutes.
Time Margin - The time margin, without considering OMA uncertainty, is five (5) minutes. This demonstrates that the OMAs are feasible. The time margin for OMA performance, considering OMA uncertainty is, negative four (4) minutes.
Fire Area A-27, Operator Manual Action Timeline (Minutes)
Fire Initiated 4 Fire Indicated Diagnosis Time OMA Time                 OMA Uncertainty 2       4    6     8     10  12  14   16    18  20  22 24   26  28    30   32   34 36 38   40 Time Margin (without Uncertainty)
Available Time Figure 8.15.4-1, Fire Area A-27 OMA Timeline 8.15.5           Reliability Analysis of Time Available to Perform Manual Actions As discussed in Section 5.1.5, an OMA is considered reliable provided that a Time Margin remains when applying Fire Indicated Time, Diagnosis Time, OMA Implementation Time, and OMA Uncertainty Time. The Figure 8.15.4-1 OMA timeline does not support a conclusion that the OMAs are reliable. However, the feasible OMAs coupled with a fire watch, are acceptable interim compensatory measures until the OMAs are eliminated by the field implementation of change package 012418.

Post-Fire Safe Shutdown Operator Manual Actions                                     Page 115 of 117 WIP-E-1F9900-004-A-1 8.15.6      Environmental Factors Habitable environmental conditions will be present for performance of the OMAs. The postulated fire event is within the Rod Drive MG Set Room on the 2026' elevation of the Auxiliary Building (Fire Area A-27). Based on fire barrier separation, the fire will be confined to Fire Area A-27.
Access to Fire Area A-16 does not require transition through Fire Area A-
: 27. The travel path and location of the equipment requiring manipulation are physically separated from the fire by a rated fire barrier. Fire fighting access to A-27 could be from door 14031 within A-16. However, the smoke propagation review documented in Section 5.1.6 determined that the OMA implementation would not be impeded by smoke migration from the fire event.
Emergency lighting is provided for illumination of potential egress paths and the components requiring OMA manipulation. Normal radiation, temperature, and humidity conditions within the area of concern will not be adversely affected by the fire and subsequent spurious equipment operation.
There are no physical impediments in proximity to the manual action components that would significantly delay or prevent required manipulation. No special equipment, related to environmental condition, is necessary for performance of the OMA.
8.15.7      Equipment Functionality and Accessibility No equipment support functions are required for successful manual action implementation. The OMA components are physically separated from the fire event by a fire rated barrier. This ensures that the credited equipment is not adversely affected by the fire and its effects.
The operator responsible for OFN KC-016 OMAs carries a master key that can be used to open electronically controlled doors in the event that the fire has negatively affected the normal card key access means. All electronically controlled doors are provided with this secondary access arrangement. This ensures that the postulated fire will not prevent egress through doors provided with electronic access control.
8.15.8     Available Indications Point addressable smoke detection is provided for the fire area. Upon detector activation, main fire alarm panel KC-008, located in the Control Room, will annunciate a fire alarm condition with a descriptive location of the detector in alarm. This will likely be the first indication of a fire event within the area.
To diagnose a failure of 'A' Train CCW, necessitating the need to swap to
                   'B' CCW, pump breaker position indication or CCW flow indication needs to be available. The following instrumentation is unaffected by the fire and is available to assist the Control Room in diagnosing the need to locally open EGHV0016 and EGHV0054 to lineup 'B' CCW:

Post-Fire Safe Shutdown Operator Manual Actions                                   Page 116 of 117 WIP-E-1F9900-004-A-1
                      " "A" CCW Pump breaker position from hand indicating switch EGHIS0021.
                      *   "C" CCW Pump breaker position from hand indicating switch EGHIS0023.
                      " CCW flow to service loop EGFI0055A.
8.15.9     Communications A fire in this area could affect the Gaitronics and 900 MHz radio systems.
The OMAs does not require constant communication with the Control Room. As previously discussed, the operator assigned OFN KC-016 OMA duty will report to the Control Room for instruction following fire brigade callout. This approach allows the Control Room Operators to provide face-to-face direction for the OMA. Once the OMAs have been implemented, the operator can physically report back to the Control Room ifthe fire affects the Gaitronics or radio system functionality.
Communication with the Control Room of OMA implementation is not required due to CCW service loop flow indication being available.
8.15.10    Portable Equipment No portable equipment or tools, beyond those required to be carried by the designated OMA operator, are necessary to perform the specified OMAs. Key access may be necessary for electronic card reader controlled doors if the fire affects electronic door control. As previously identified, the OFN KC-016 OMA designated operator is required to carry a master key.
8.15.11    Personnel Protection Equipment No other personnel protective equipment, beyond that normally necessary for Auxiliary Building access, is required to perform the OMAs.
8.15.12    Procedures and Training The OMAs are identified in OFN KC-016. See Section 5.1.12 for further discussion addressing the fire response procedure.
8.15.13    Staffing The Operator assigned OFN KC-01 6 OMA duty for the shift is responsible for performing the OMAs. Only one person is required to perform the OMAs.
8.15.14    Demonstrations The OMAs were timed using multiple operators, each starting from the Work Control Center (3613) on the 2047' elevation of the Communications Corridor. The timing effort reflected that the OMAs

Post-Fire Safe Shutdown Operator Manual Actions                                      Page 117 of 117 WIP-E-1F9900-004-A-1 could be consistently, sequentially performed within twelve (12) minutes.
In addition, the following uncertainty times have been included, resulting in a total uncertainty time of nine (9) minutes.
                   "   Communication and feedback with Control Room - 1 minute
* Electronically controlled door key access - 3 minutes
* Obtain RCA access - 2 minutes
                   "   Human centered uncertainty - 3 minutes 8.15.15    Defense-In -Depth
: 1. Fire Prevention The object of fire prevention is not affected by the OMA. The area of the plant where the fire could occur, necessitating OMA implementation, has combustible loading allowances and hot work limitations that are consistent with other plant areas important to safety.
: 2. Detection Control and Extinguish Fires Smoke detection and a total flooding halon system are provided for the area. Fire alarm annunciation is provided locally, and within the Control Room. Smoke detection is point addressable, allowing for prompt recognition of fire location. The halon protection will aid in controlling the fire event until manual suppression can be applied, as necessary. Fire extinguishers and a hose station are provided within the area for manual fire fighting.
: 3. Protection of systems structures and components (SSC) so that fires will not prevent safe shutdown.
Historically, this objective has been deterministically satisfied by conforming to the requirements of 10 CFR 50 Appendix R, Sections III.G.1 or III.G.2. The subject OMAs, coupled with a fire watch are utilized in lieu of passive fire barrier protection to ensure a fire in A-27 does not challenge PFSSD.
8.15.16    Conclusion The above analysis and time-authenticated demonstrations provide reasonable assurance that the OMA for Fire Area A-27 is feasible.
Reliability was not demonstrated by the analysis. Therefore, the OMAs are considered interim compensatory measures, coupled with a fire watch, until the OMAs are eliminated by the field implementation of change package 012418. These compensatory measures provide reasonable assurance that a fire in Fire Area A-27 will not adversely affect the ability to achieve and maintain safe shutdown.

Post-Fire Safe Shutdown Operator Manual Actions  Page A-1 of A-2 Attachment A WIP-E-1F9900-004-A-1 Attachment A to WIP-E-1 F9900-004-A-1 Summary of OMAs to Achieve and Maintain Hot Standby

Post-Fire Safe Shutdown Operator Manual Actions                                                             Page A-2 of A-2 Attachment A WIP-E-1F9900-004-A-1 Summary of OMAs to Achieve and Maintain Hot Standby Room / Fire Operator Manual Action        Area Where   A-1 A-11 A-16N A-18 A-27  C-7 C-12  C-18 C-21 C-22   C-23 C-24 C-30  C-33   RB OMA Implemented Close valve KAV0201 to fail close letdown valves           1322 / A-25  X    X         X         X    X     X    X                X                 X BGLCV0459 and BGLCV0460.
Use local controller ABFHCO002 to control/isolate steam release through ARV for Steam Generator B Use local controller ABFHC0003 to control/isolate   1509 / A-23            X steam release through ARV for Steam Generator C Isolate air and nitrogen to atmospheric relive valve ABPV0004 to fail the ARV closed Terminate Train B containment spray by opening breaker       3302/ C-10                                                 X   X       X          X NB0203.
Terminate Train A containment spray by opening breaker        3301/ C-9                                       X    X                x NB0102.
Open EGHV0016 and              1401,1402/
EGHV0054 to support 'B' Train      A-16                         X CCW lineup

Post-Fire Safe Shutdown Operator Manual Actions     Page B1-1 of B1-3 Attachment BI WI P-E-1 F9900-004-A-1 Attachment B1 to WIP-E-1 F9900-004-A-1 Fire Alarm System Response Time

Post-Fire Safe Shutdown Operator Manual Actions                                Page B1-2 of B1-3 Attachment B1 WIP-E-1F9900-004-A-1 NUREG-1805, Fire Dynamics Tools (FDT) was utilized to determine smoke detector response time in areas where fire induced spurious equipment actuation results in the potential need for mitigating action to preserve the analyzed PFSSD success path. The results of the fire modeling effort are applied to the OMA timeline analysis for the respective fire area. The FDT utilized in the fire modeling approach was developed, prepared, and validated by the Nuclear Regulatory Commission (NRC) to provide a consistent, simplified fire modeling approach.
NUREG-1805 FDT "11. Estimating Smoke Detector Response Time" (Version 1805.0), was utilized to determine smoke detector response time (where applicable) when applying a simple fire heat release rate from Appendix F of NRC Inspection Manual 0609 (Table 2.3.1). An example of the FDT is provided in Attachment B2.
Input information necessary for the FDT is as follows:
* Fire Heat Release Rate (kW) - a 70 kW fire was postulated, as it represents lowest kW output fire from generic fire bin types identified in Appendix F Table 2.3.1 of NRC Inspection Manual 0609. A lower intensity fire produces a slower detector response time, which is conservative for application to the OMA timeline. The use of 70 kW as a conservative heat release rate is further substantiated by the intermediate-scale cable burn tests documented in NUREG/CR-6931, where a 200 + kW fire was utilized to assess cable performance when subjected to fire exposure.
            "   Radial Distance to the Detector (ft) - The radial distance to the detector was postulated to be 15' (half the detector listed spacing) or room radial distance, if the room footprint is less than 15' x 15'.
            "   Height of Ceiling above Top of Fuel (ft) - Distance from ceiling to floor was utilized.
            "   Ambient air temperature (OF) - The lowest normal temperature identified in EQSD-IV Table 1, was utilized. A lower ambient temperature results in a slower detection response time, which is conservative for application to the OMA timeline.
The input data and resulting detector activation time are summarized in Table B1-1.
The detector activation time identified in the table is the longest detector activation time calculated from the three methods (Alpert, Mowrer, and Milke) rounded up to the next whole minute.

Post-Fire Safe Shutdown Operator Manual Actions                              Page B1-3 of B1-3 Attachment B1 WIP-E-1F9900-004-A-1 Table B1-1, Detector Response Time NUREG-1805 FDT "l1. Estimating Smoke Detector Response Time" Input Data                              Detector Fire Area                         Radial                         Ambient        Activation time Heat Release     Distance to         Ceiling      Temperature        (minutes)
Rate (kW)       Detector (ft),     height (if)        (OF)
A-1                 70               15               25              60                8 A-11                70               6              23.33             60                6 A-16N               70               15              20.5             60                4 A-18                70               15              20.5            602                4 A-27                70               15              20.5            60'                4 C-7                 70             2.917            15.17             60                 1 C-12                70               6              15.17            601                 1 C-18                70               6              15.33             60                 1 C-21                70               15             14.83            601                 1 C-22                70               15               12             601                 1 C-23                70               6              14.83            601                 1 C-24                70               6              14.83            601                 1 C-30                70               6              25.33            601                9 C-33                70               6                12             601                 1 Notes:
: 1. Control Building cable chase temperatures are not identified in EQSD-IV Table 1. The low temperature (60 0 F) for the cable spreading rooms was utilized.
: 2. Auxiliary Building cable chase temperatures are not identified in EQSD-IV Table 1. The low temperature (60 0 F) for the electrical penetration rooms was utilized.
: 3. The MG Set Room, 1403, is not identified in EQSD-IV Table 1. The low temperature (60 0 F) for the 2026' corridor rooms, 1402 and 1408, was utilized.
GLTIC01 85 for SGL20 is set for 65'F per WCRE-01, TPSD.

Post-Fire Safe Shutdown Operator Manual Actions  Page B2-1 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1 Attachment B2 to WIP-E-1 F9900-004-A-1 Sample FDT Data Sheet NUREG-1 805 FDT "11. Estimating Smoke Detector Response Time"

Post-Fire Safe Shutdown Operator Manual Actions                                                                                         Page B2-2 of B2-4 Attachment B2 WIP-E-1F9900404-A-1 INPUT PARAMETERS Heat.Release    Rateofthe Fire       ~q~SteradyStauel                                                         75.00 M~
itnce to the Detector(r) -noevermorethee0 707 or 1124J2ofthe listedspacing-
                        !Rda                                                                                                   10.1M  t
                !Heightof Ce!ing above Topof Fuel (11)                                                                         13.00 Activation Temperature ofthe Smoke Detector (Taeivi.)
Smko /t eponse TimeIndex (RTI)                                                                  -  500 r-e)
Ambient AirTemperature (tar                                                                                       .f
:ConvectiveHealReleaseRateFractron(X,)                                                                          0705 IPlume Leg Time Constant (CI) (Epverrmentary Determined)                                                        067 iCeilingJet Lag Time Constant (Cj) (Experimentally Determ.ined)                                                  12 Temperature Rise ofGases Under the Ceiling(ATr)                                                               1t 01    -F forSmoke Detector to Activate CH.
                   =                          0.77.
ESTIMATING SMOKE DETECTOR RESPONSE TIME METWOD OF ALPERT n (RTI/4,) (In(T. - T)('T.r - T-,.ir))
                *Thiomethodassumesmokedetector                 isa lowRTIdesicewitk a fexedactivatron       temperature Where           tesrier = detector activation time (sec)
ORTI  = detector response time index(rn-sec)W urceiling let velocity(rrssec)
T. ceilingjet temperature       (&#xfd;C)
T,= ambientair temperature (iC)
Tir, riv= activat*o temperature           of detector (&deg;C)
Ceili!p0 Jet Tenepetatmne Carctilatlioi Tm - T= 08q(Qtr)t/HSC .                         .for                                io/H 018
                        -635 T.
                     -T.              /~t/                                                         for n/H 0 18 W/here
                    .            T       ceiling jet temperature (T)
T,, ambient air temperature ('C) 1       convective portion ofthe heat release rate(k")
H= eiph! of cei Ingabe to of fue                  .      .   .      ..
                                   = radial distance from the plume centerline to the detector (m)
Convective Heat Release RateCalculation A\Mere         DO= convective portionofthe heat release rate (k1W)
S6:=hea-trelease      rate oftire -fre (-k/iS)
Radial Distance to Ceillnf Heighit Ratio Calculation cH-    >0t1,1                         ,    1
                                                                                             <0 !t Tier      5 38 ((c/r)i213)/H T.=:                     34.061('C)
ICe~i.9rJet Velocity Calculatlot o=    0896 (IJ/H)rrt               =for                                                r/H 59015 jgr= 195O2' Hn)Woyr            I                                              forr/H > 015 aWhere        ut = ceiling jet velocity (rnsec) 3 = heat release rate of the fire (bkY)
H =height ofceiling1       abovetop offuel (in)
                                   ,r-radial druta  Incehromtheplumecenterline        to the detector (M)
               *r/                                         0015
                                                         >.)/
                                                                                            ,b0S6                      2 06[
ow=     (0,1156  l11/3 Hit12)O(/r'6)
Re=      .647              in/sec SanelseDetectorResponse             Time Catenlat     I en ltoamimas = (RTV(-Jutx))   (Is (T. - Ti)/(tre- TacI-oo))
1NOTE: If          "tiail - "NUM" Detector does not activate

Post-Fire Safe Shutdown Operator Manual Actions                                                 Page B2-3 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1 METHOD-*MOMWR.ER Ita-4,'ato. tp + tcJ
          !:Where             t 5  -,    =   detector actriation time (sec) tp, = transport lag time of plume (sec) tel = transport eag time of cedlng jet (sec) ttlTiistsolr!    L_.40rime oIfPlIume11 tit,= C0,1 (H)*/(Q)rt3               I    CalCUlIation1 Where              tpr = transport lag time of plume (sec)
Cep= pluome     tag tim e cocnstant H = height of ceiling above top of fuel (m) 0 = heat release rate of the fire (k0) te,                             1.OOlsec Tuanspeut      Lag Thineof Ceililing      Jet Calculatlion Io= (r)iO(u)()   '            H1 Wheire           t5     transport lag time of ceiling iet (sect C5i    ceiling Jet lag tihe constant I= radial distance from the plume centerline to the detector (m)
H heighrt of ceiling abmve       top of fuel (in)
Q = heat release rate of the fire (keW)
It,                     0.771nec 35t        :     ~tplt 1SInoloke Delecto Respol3senTilne Calctlation

Post-Fire Safe Shutdown Operator Manual Actions                                                                           Page B2-4 of B2-4 Attachment B2 WIP-E-1F9900-004-A-1 METHOD OF MILKE t-rr-u       X H/'1 V/here             t       = detector activation time (see) 0 X=4,6 t1 4Y +27 10r ys
                         &#xfd;H- height ofceiling above top offuel (h)
O = heat release rate from steady fire (Btui/sec)
Where              Y = AT. HW"f   Oto jATr = temperature rise of gases under the ceiliog forsmoke detector to activate (F)
Before estltoathng siioke detecletr espoltne tnille. StraltlfCariolr effects C011be calorrlate(l.
NFPA92B, 2000 Edirion. Section A.3.4 pijovides following cosielatolio to estimate stiroke stlatlficatloIrt ir a Compartmllientl.
Hz = 74 O,2'I I AT,.*c365 Where              Hma= the maximum ceiling clearance to which a plume can rise (It)
Q, = convective portion ofthe heat release rate (Btu/sec)
Tir = difference in temoperature due to firebetween the fuel localion and ceiling level (TF)
Convective Heat Release Rate C-ateritalon Where              0Q= convective portionofthe heat release rate (Btu/secl O = heat .lease rate of the fire &#xfd;Btutsec) convective heat releasratefiraction 0, =             49.76           Btu/sec Differlence IirTeoiperatrieDire to File Between lire Fuel Locaiioii awl Ceilini Level 2
AT = 1300               1Q
                                *H" Where             ATt.,, = difference in temperature due to firebetween the fuel location and ceilrig level(TF)
O = coorsctive portionofthe heat release rate (Etuisec)
H = ceilin seht ei above the firesource (1f)
AT,-             1        2414.70 &deg;F Siroioke  Si atifcalioli ffects 0
n      74O ,/ /fT, ve'*
Hnm =                      13.03 ft n this case the highest point of smoke rise is estimated to be                                  13.03 It Thus, the smoke wo uld b expected to reach the ceiling mounted smoke detector t
Y- AT, H'*' O Y=                         75.39 X =4.6 10uy2 .2.7        10 r15f x =2.62 Slnoke Detector R ejirise Time Calculatioln

Post-Fire Safe Shutdown Operator Manual Actions     Page C-1 of C-3 Attachment C WIP-E-1 F9900-004-A-1 Attachment C to WIP-E-1 F9900-004-A-1 Photos of Equipment Manipulated for Operator Manual Action

Post-Fire Safe Shutdown Operator Manual Actions                  Page C-2 of C-3 Attachment C WIP-E-1F9900-004-A-1 F-noto u-i, KAvuzui                  I-'fOtO U-2, AbI--HUUUUZ Photo C-3, ABFHCO003                     Photo C-4, KAV1429 Photo C-5, KAV1365

Post-Fire Safe Shutdown Operator Manual Actions               Page C-3 of C-3 Attachment C WIP-E-1F9900-004-A-1 Photo C-8, NB0203 Photo C-10, EGHV0054}}