ML091040206

Calculation No. OSC-9291, Rev. 0, NFPA 805 Transition B-2 Table.

ML091040206
Person / Time
Site:	Oconee
Issue date:	05/29/2008
From:	Parker D E Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
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ML091040234	List: ML091040205 ML091040206 ML091040207 ML091040208 ML091040214
References
OSC-9291, Rev 0
Download: ML091040206 (135)

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Enclosure 3 Duke Energy Oconee Nuclear Station Calculations Supporting Transition to NFPA-805 0 0 0 0 OSC-9291 OSC-9293 OSC-9295 OSC-9313 NFPA 805 Transition B-2 Table NFPA 805 Transition Radioactive Release G-l Table NFPA 805 Transition B-i Table/Report NFPA 805 Transition Non-Power Fire Area Assessments (Pinch Point Analysis)NFPA 805 Transition risk-Informed, Performance Based Change Evaluation Methodology 0 OSC-9314 Form 101.1 (R08-04)CERTIFICATION OF ENGINEERING CALCULATION Station And Unit Number Oconee Units 1, 2 & 3 Title Of Calculation NFPA 805 Transition B-2 Table Calculation Number OSC-9291 Total Original Pages i thru iv and 1 Through 4 Total Supporting Documentation Attachments 2(111 & 12 pgs) Total Microfiche Attachments 0 Total Volumes 1 Active Calculation

/ Analysis , Yes x No [I Microfiche Attachment List 0 Yes x No If Active is this a Type I Calculation/Analysis Yes x No 0 (See Form 101.4)These engineering Calculations cover QA Condition 1 Items. In accordance with established procedures, the quality has been assured and I certify that the above Calculation has been Originated, Checked, or Approved as noted below:.Originated By D. E. Parker -Date 5-29-08 Checked By Date 5-Z9-Or Verification Method: hod 1 Method 2 F] Method 3 [n] Other LI Approved By ~Z.Date 5 X o'Issued To Document Management 4- -ndj Date ' /?p 14?Received By Document Management Date -Complete The Spaces Below For Documentation Of Multiple Originators Or Checkers Pages _ _ _ .\\_ Through Originated By n_ _ _ _ _ __.__..._Date Checked By Date Verification Method: Method Method 2 LI Method 3 LI Other LI Pages Through Originated By Date Checked By Date Verification Method: Method 1 L] Method 2 L] Method 3 -I Other I-Pages Through _Originated By Date Checked By Date Verification Method: Method 1 1 Method 2 E-] Method 3 EI Other LI i Form 101.2 (R3-03)Calculation Number OSC-9291 REVISION DOCUMENTATION SHEET Revision Revision Description Number 0 Injtial Issue____________

I-F+-F i-F+ii FORM 101.3 (ROB-04)FORM 101.3 (R08-04)CERTIFICATION OF ENGINEERING CALCULATION

-REVISION LOG Station And Unit Number Oconee Units 1, 2 & 3 Title Of Calculation NFPA 805 Transition B-2 Table Calculation Number OSC-9291 Active Calculation

/ Analysis Yes x No 0 Calculation Pages (Vol) Supporting Volumes Orig Chkd Verif. ApprI Issue Documentation (Vol) Vo__es O _ ___hd_ Meth. _ Date Rev. 1,2,3, Rec'd No. Revised Deleted Added Revised Deleted Added Deleted Added Date Date "Other" Date ,4r I ArDate-a4 -1,2-- 17/ol ,__ ,__Note 1: When approving a Calculation revision with multiple Originators or Checkers, the Approver need sign only one block.iii Engineering Manual 4.9 CALCULATION IMPACT ASSESSMENT (CIA)Station / Unit Oco nee /Calculation No. OSC-9291 I ,:i.Z PIP No. (if applicable)

N/A.rob. No. (stress & s/r use only) N/A Rev. I Page iv Date 10/24/2008 Date 6 7 L: NEDL reviewed to identify calculations?(formally SAROS)Note: A NEDL search is NOT required for calculation originations (i.e. Rev. O's)Identify in the blocks below, the groups consulted for an Impact Assessment of this calculation origination/revision.

LI RES (Power, I&C, ERRT, Reactor)NMCE (Primary Systems, Balance of Plant, Rotating Equipment, Valves & Heat Exchangers, Civil)Indiv. Contacted/Date mndiv. Contacted/Date NGO (QA Tech. Services (SI), Severe Accident Analysis,Elect.

Sys. & Equip., Design &-Reactor Supp., Civil Structural, Core Mech. & T/H Analysis, Mech.Sys. & Equip., Nuclear Design and Safety Analysis, Matls/Metallurgy/Pipinng El MOD (Mechanical Engr., Electrical Eugr., Civil Engr.)[] Training[] Local IT D Operations

-OPS Support W Maintenance

-Tech. Support* Work Control -Program. Supp.[] Other Group E] Regulatory Compliance El Chemistry 0] Radiation Protection 91 No Group required to be consulted Listed below are the Identified documents (ex: TECHNICAL SPECIFICATION SECTIONS, UFSAR SECTIONS, DESIGN BASIS DOCUMENTS, STATION PROCEDURES-, DRAWINGS, OTHER CALCULATIONS, ETC.) that may require revision as a result of the calculation origination or revision, the document ownerlgroup and the change required (including any necesssary PIP Corrective Actions).*NOte: Any design changes, which require changes to Station Procedures, must be transmitted as Design Deliverable Documents.

DOCUMENT GROUP CHANGE REQUIRED OSC-9292 will use this data ,A-~ -~ 'KlNT~rK I:;"~ r ~ 'm'~y. 7- ~ P 4 ~ T .Page 1 of I Calculation No.: OSC-9291 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 1 of 4 1.0. Problem Statement The transition for Oconee to a new NFPA-805 fire protection licensing basis under 10 CFR 50.48 (c) requires that the methodology utilized in performing the deterministic safe shutdown analysis for NFPA-805 Section 2.4.2 that forms the basis for transition be compared against the provisions of NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, revision 1. This calculation formally documents the results of that review for incorporation into the Duke Document Control system as a QA condition 1 design input.2.0. Methodology Sections 4.3.2 and B.2-1 of NEI 04-02, Revision 1 provide the background and bases for the Nuclear Safety Methodology Reviews. Section B.2-1 recommends that the 'pre-transitional safe shutdown analysis' be reviewed against the methodology of NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1. This review compares the provisions of NEI 00-01 as mapped against the main requirements of NFPA-805, section 2.4.2 to the Oconee Safe Shutdown Analysis Methodology which is primarily contained within the AREVA Engineering Information Record EIR 51-5044354-002. Other documents that formed the basis for comparison were also used.The first step involved gathering the core methodology documents and plant specific calculations/analyses for: W Safb shutdown system and equipment selection 0 Safe shutdown cable identification 0 Safe shutdown equipment and cable location a Fire area assessment and supporting analyses a Outstanding Frequently Asked Questions (FAQs) related to the Nuclear Safety Methodology Transition (e.g., FAQ 06-0006, High-low pressure interface) and status documents such as NRC comments and comment resolutions.

a Applicable NRC correspondence with Duke The next step was to perform a line item by line item comparison of the methodology sections described in NEI 00-01 based on how they were 'Mapped' to the four main deterministic analysis sections of NFPA-805 outlined below: " 2.4.2.1 -Nuclear Safety Capability System and Equipment Selection" 2.4.2.2 -Nuclear Safety Capability Circuit Analysis" 2.4.2.3 -Nuclear Safety Equipment and Cable Location 0 2.4.2.4 --Fire Area Assessment Calculation No.: OSC-9291 Revision No.: I Applicable Units: Oconee Unit 1, 2, & 3 Page 2 of 4 The NEI sections are not necessarily in order of their appearance in NEI 00-01, but ordered based on their application to the NFPA sections above as determined during the earliest Pilot plant meetings.

In some cases brackets [] were used to provide pseudo titles of sections when distinctions between various subsections needed to be made. The specific figures referenced in the mapped NEI 00-01 sections were provided as page extracts in attachment 2 for ease of review.Based upon the content of the individual NEI 00-01 methodology statements, the review determined if the 'Mapped NEI 00-01 Reference' was applicable to Oconee. Examples where a line item may not have been applicable include: " Since Oconee is a PWR, guidance provided in NEI 00-01 specifically for BWRs does not apply." Specific references to equipment/component types/cable types that are not used at Oconee.For each 'Mapped NEI 00-01 Reference' that was determined to be applicable, a comparison was performed of the Oconee safe shutdown methodology against the NEI 00-01 section to determine how closely aligned the two methodologies were. For each applicable

'Mapped NEI 00-01 Reference' the following information was documented:

Alignment Statement -One of the following alignment statements was used for Oconee.Other alignment statements may be used depending upon the site licensing basis." Not Required" Not Applicable" Aligns" Aligns with intent* Does not Align* Does not Align but has previous approval Alignment Basis -The review provided a text description supporting the Alignment Statement.

Reference Document(s)

-Appropriate Reference Document(s) were identified and the relevant sections/page numbers provided for future reviewers to determine source of the alignment basis statements.

Comments and Other Details -Any clarification information to support the other statements was provided.

• Calculation No.: OSC-9291 Revision No.: I_______Applicable Units: Oconee Unit 1,.2, & 3 Page 3 of 4 Unit Applicability

-for those items applicable to a single unit, the opportunity was provided to review alignment on a per unit basis, however this was not utilized at Oconee.Open items applicable to the methodology review were documented.

Appendix 13.2.1 of NEI 04-02 was referred to for guidance on interpretation of licensing bases that are vague or silent (e.g., fire-induced circuit failure methodologies) and the need to establish a clear basis for transition.

3.0. Design

Bases and References

3.1 Title

10 Code of Federal Regulations, Section 50.48 (c)3.2 National Fire Protection Association 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition as accepted by Federal Register notice 69FR 33536, June 16, 2004.3.3 Nuclear Energy Institute (N El) 04-02, Revision 1, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), September 2005 3.4 Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, May 2006 3.5 10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979 3.6 N E 100-0 1, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1, January 2005.3.7 EIR 51-5044354-002, Oconee Appendix R Fire Safe Shutdown Analysis 3.1 PIP 0-08-02444, NEI 00-0 1 B-2 Table Open Items.4.0. Summary Information This is a Type I calculation because it must be reviewed for each Engineering Change that is implemented and updated when required.

These tables can reasonably be expected to routinely involve insignificant changes due to Engineering Changes since it is basically a comparison document to established safe shutdown analytical methods.

Calculation No.: OSC-9291 Revision No.: I Applicable Units: Oconee Unit 1. 2, & 3 Page 4 of 4 Revision of these methods would require a significant departure from NRC endorsed guidance and is not likely to occur. Because this Calculation is a summary of methodology review, these insignificant changes would not directly challenge any SSC's ability to perform its design function(s).

The results of this review have determined that the safe shutdown methodologies utilized by Oconee for system, component and cable/circuit selection as well as fire area compliance analysis generally conform to the guidance of NEI 00-01 with the exception of the treatment of Operator Manual Actions (OMA's) and Multiple Spurious Operations (MSO's) which remain to be resolved via the FAQ process. There is also an open item related to the adequacy of the current electrical power supply coordination analysis, the ability to manually operate manual valves post-fire following potential fire damage, and the use of manual actions for HSB. These Open Items have been entered into the corrective action program under PIP 0-08-02444 and are being resolved.5.0. Assumptions 5.1. None 6.0 Technical Presentation Attachment 1 -Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment 2 -Extracted pages from NEI 00-01 for Figures referenced in Table B-2 Calculation No.: Applicable Units: OSC-9291 Oconee Unit 1, 2, & 3 Revision No.: Attachment I I Attachment 1 Table B-2 -Nuclear Safety Capability Assessment Methodology Review 112 total pages OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection A comprehensive list of systems and equipment and their interrelationships to be analyzed for a fire event shall be developed.

The equipment list shall contain an inventory of those critical components required to achieve the nuclear safety performance criteria of Section 1.5. Components required to achieve and maintain the nuclear safety functions and components whose fire-induced failure could prevent the operation or result in the maloperation of those components needed to meet the nuclear safety criteria shall be included.

Availability and reliability of equipment selected shall be evaluated.

NEI 00-01 Ref 3 Deterministic Methodology NEt 00-01 Guidance This section discusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe shutdown analysis to address regulatory requirements.

The plant-specific analysis approved by NRC is reflected in the plant's licensing basis. The methodology described in this section is also an acceptable method of performing a post-fire safe shutdown analysis.

This methodology is indicated in Figure 3-1. Other methods acceptable to NRC may also be used. Regardless of the method selected by an individual licensee, the criteria and assumptions provided in this guidance document may apply. The methodology described in Section 3 is based on a computer database oriented approach, which is utilized by several licensees to model Appendix R data relationships.

This guidance document, however, does not require the use of a computer database oriented approach.The requirements of Appendix R Sections III.G.1, III.G.2 and III.G.3 apply to equipment and cables required for achieving and maintaining safe shutdown in any fire area. Although equipment and cables for fire detection and suppression systems, communications systems and 8-hour emergency lighting systems are Important features, this guidance document does not address them.Additional information is provided in Appendix B to this document.Comments Applicability Applicable Alignment Statement Aligns Oconee Alignment Basis A deterministic methodology is utilized to assess conformance with Appendix R.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details 3.4.2 Page 1 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1 [A, Intro] Safe Shutdown Systems and Path Development NEI 00-01 Guidance This section discusses the identification of systems available and necessary to perform the required safe shutdown functions.

It also provides information on the process for combining these systems into safe shutdown paths. Appendix R Section IIl.G.1 .a requires that the capability to achieve and maintain hot shutdown be free of fire damage. It is expected that the term "free of fire damage" will be further clarified in a forthcoming Regulatory Issue Summary. Appendix R Section III.G.1 .b requires that repairs to systems and equipment necessary to achieve and maintain cold shutdown be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It is the intent of the NRC that requirements related to the use of manual operator actions will be addressed in a forthcoming rulemaking.

[Refer to hard copy of NEI 00-01 for Figure 3-1]Comments Applicabillty Applicable Alignment Statement Aligns Oconee Alignment Basis Safe shutdown systems and functions are identified.

Safe shutdown success paths are identified.

Logic diagrams are utilized to determine if sufficient safe shutdown functions are available to achieve safe shutdown goals.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Attachment P Page 2 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1 [B, Goals] Safe Shutdown Systems and Path Development NEI 00-01 Guidance The goal of post-fire safe shutdown is to assure that a one train of shutdown systems, structures, and components remains free of fire damage for a single fire in any single plant fire area. This goal is accomplished by determining those functions important to achieve and maintain hot shutdown.

Safe shutdown systems are selected so that the capability to perform these required functions is a part of each safe shutdown path. The functions important to post-fire safe shutdown generally include, but are not limited to the following:

Reactivity control Pressure control systems Inventory control systems Decay heat removal systems Process monitoring Support systems o Electrical systems o Cooling systems These functions are of importance because they have a direct bearing on the safe shutdown goal of being able to achieve and maintain hot shutdown which ensures the integrity of the fuel, the reactor pressure vessel, and the primary containment.

If these functions are preserved, then the plant will be safe because the fuel, the reactor and the primary containment will not be damaged. By assuring that this equipment is not damaged and remains functional, the protection of the health and safety of the public is assured.Comments Applicability Applicable Alignment Statement Aligns Alignment Basis Safe shutdown performance goals are translated into safe shutdown success paths and are identified and utilized to ensure safe shutdown can be achieved.

Logic diagrams are used to assess safe shutdown success paths.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 DAch Details Attachment P Oconee Page 3 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1 IC, Spurious Operations]

Safe Shutdown Systems and Path Development NEI 00-01 Guidance In addition to the above listed functions, Generic Letter 81-12 specifies consideration of associated circuits with the potential for spurious equipment operation and/or loss of power source, and the common enclosure failures.

Spurious operations/actuations can affect the accomplishment of the post-fire safe shutdown functions listed above. Typical examples of the effects of the spurious operations of concern are the following:

o A loss of reactor pressure vessel/reactor coolant inventory in excess of the safe shutdown makeup capability o A flow loss or blockage In the Inventory makeup or decay heat removal systems being used for the required safe shutdown path.Spurious operations are of concern because they have the potential to directly affect the ability to achieve and maintain hot shutdown, which could affect the fuel and cause damage to the reactor pressure vessel or the primary containment.

Common power source and common enclosure concerns could also affect these and must be addressed.

Comments Applicability Applicable Alignment Statement Aligns Alignment Basis Spurious operations are considered in both the selection of safe shutdown functions and systems as well as the cabling associated with the components relied upon to achieve those functions.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.1.2 ,3.4.2 and 8.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 4 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP *nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1 Criteria / Assumptions Anplicability Applicable Alignment Statement Not Required NEI 00-01 Guidance The following criteria and assumptions may be considered when identifying systems available and necessary to perform the required safe shutdown functions and combining these systems into safe shutdown paths.Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 5 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP *nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.1 [GE BWR Paths]Applicability Not Applicable Alignment Statement Not Applicable NEI 00-01 Guidance[BWR] GE Report GE-NE-T43-00002-00-01-ROl entitled 'Original Safe Shutdown Paths For The BWR" addresses the systems and equipment originally designed into the GE boiling water reactors (BWRs) in the 1960s and 1970s, that can be used to achieve and maintain safe shutdown per Section III.G.1 of 10CFR 50, Appendix R. Any of the shutdown paths (methods) described in this report are considered to be acceptable methods for achieving redundant safe shutdown.Comments Alignment Basis B&W PWR Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 6 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP :nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System anrd Equipment Selection NEI 00-01 Ref 3.1.1.2 [SRVs / LP Systems]Applicabilii Not Applicable Alignment Statement Not Applicable NEI 00-01 Guidance[BWR] GE Report GE-NE-T43-00002-00-03-RO1 provides a discussion on the BWR Owners' Group (BWROG) position regarding the use of Safety Relief Valves (SRVs) and low pressure systems (LPCI/CS) for safe shutdown.

The BWROG position is that the use of SRVs and low pressure systems is an acceptable methodology for achieving redundant safe shutdown in accordance with the requirements of 10CFR50 Appendix R Sections Ill.G.1 and III.G.2. The NRC has accepted the BWROG position and issued an SER dated Dec. 12, 2000.Comments Alignment Basis B&W PWR Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 7 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291:,-

NFP .nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section. 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.3 [Pressurizer Heaters)Applicability Applicable Alianment Statement Aligns with Intent NEI 00-01 Guidance[PWR] Generic Letter 86-10, Enclosure 2, Section 5.3.5 specifies that hot shutdown can be maintained without the use of pressurizer heaters (i.e., pressure control is provided by controlling the makeup/charging pumps). Hot shutdown conditions can be maintained via natural circulation of the RCS through the steam generators.

The cooldown rate must be controlled to prevent the formation of a bubble in the reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled.

Comments Alignment Basis For a control room shutdown, ONS credits use of makeup/charging to control RC pressure at hot standby conditions.

For a SSF shutdown, ONS credits use of pressurizer heaters and makeup/charging to control RC pressure at hot standby conditions.

Decay heat removal during hot standby conditions and cool down of the RCS is provided by natural circulation of the RCS through the steam generators utilizing emergency feedwater for a control room shutdown and SSF Aux service water for a SSF shutdown.

The rate of cool down, supported by the use of reactor head vents or periodic cycling of reactor coolant pumps, prevents the formation of a bubble in the reactor vessel head during a natural circulation cooldown.

Feedwater flow rates and steam release rates are controlled by the throttling of feedwater control valves and atmospheric dump valves.Comments Unit Reference Document AP/OINA1700/025, Standby Shutdown Facility Emergency Operating Procedure, Rev. 38, 811612007 Doec. Details 74-1152414-10, AREVA Emergency Operating Procedures Technical Bases Document D 1982-09-20, RAI On ONS Standby Shutdown Facility, 9/20/1982 EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 8 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev, 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Aligns with Intent For a control room shutdown, ONS credits use of makeup/charging to control RC pressure at hot standby conditions.

For a SSF shutdown, ONS credits use of pressurizer heaters and makeup/charging to control RC pressure at hot standby conditions.

Decay heat removal during hot standby conditions and cool down of the RCS is provided by natural circulation of the RCS through the steam generators utilizing emergency feedwater for a control room shutdown and SSF Aux service water for a SSF shutdown.

The rate of cool down, supported by the use of reactor head vents or periodic cycling of reactor coolant pumps, prevents the formation of a bubble in the reactor vessel head during a natural circulation cooldown.

Feedwater flow rates and steam release rates are controlled by the throttling of feedwater control valves and atmospheric dump valves, OSC-9347, Thermal Hydraulic Analysis for NFPA-805 Transition, Rev.1. 9/18/2008 Attachment B Oconee ONS -LAR No 2008-01 Supplement.mdb Page 9 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP ,nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 SectIon: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.4 [Alternative Shutdown Capability]

NEI 00-01 Guidance The classification of shutdown capability as alternative shutdown is made independent of the selection of systems used for shutdown.

Alternative shutdown capability is determined based on an inability to assure the availability of a redundant safe shutdown path. Compliance to the separation requirements of Sections lll.G.1 and 1ll.G.2 may be supplemented by the use of manual actions to the extent allowed by the regulations and the licensing basis of the plant, repairs (cold shutdown only), exemptions, deviations, GL 86-10 fire hazards analyses or fire protection design change evaluations, as appropriate.-

These may also be used in conjunction with alternative shutdown capability.

Comments Applicabilit Applicable Alignment Statement Aligns with Intent Alignment Basis Oconee utilizes a dedicated Standby Shutdown Facility (SSF) for the following fire areas at Oconee: o BOP o BH12 o BH3 o Yard East The transfer of control to the SSF of the equipment credited for a SSF shutdown isolates the systems and, equipment from the affects of a fire for the above fire areas. The intent of the guidance is that dedicated cables and equipment credited for alternative shutdown is independent of the fire area of concern. Following transfer of control to the SSF, the dedicated equipment credited for a SSF shutdown meets the intent of the guidance.Comments U nit Reference Document UFSAR Section 9.6, Standby Shutdown Facility Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Section 11 Page 10 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.5 [Initial Conditions]

Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance At the onset of the postulated fire, all safe shutdown systems (including applicable redundant trains) are assumed operable and available for post-fire safe shutdown.

Systems are assumed to be operational with no repairs, maintenance, testing, Limiting Conditions for Operation, etc. in progress.

The units are assumed to be operating at full power under normal conditions and normal lineups.Comments Alignment Basis Same initial conditions are assumed by the safe shutdown analysis.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.4.Oconee ONS -LAR No 2008-01 Supplement.mdb Page 11 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.6 [Other Events in Conjunction with Fire]Applicabili Applicable Alignment Statement Aligns NEI 00-01 Guidance No Final Safety Analysis Report accidents or other design basis events (e.g. loss of coolant accident, earthquake), single failures or non-fire induced transients need be considered in conjunction with the fire.Comments Alignment Basis No accidents or other design basis events (i.e.loss of coolant accident, control rod misalignment accident, etc.), single failures or non-fire induced transients are considered in conjunction with the fire.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 12 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP insition B-2 Table Rev. I Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.7 [ Offsite Power]NEI 00-01 Guidance For the case of redundant shutdown, offsite power may be credited if demonstrated to be free of fire damage. Offsite power should be assumed to remain available for those cases where its availability may adversely impact safety (i.e., reliance cannot be placed on fire causing a loss of offsite power if the consequences of offsite power availability'are more severe than its presumed loss). No credit should be taken for a fire causing a loss of offsite power. For areas where train separation cannot be achieved and alternative shutdown capability is necessary, shutdown must be demonstrated both where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Comments Applicability Applicable Aligjnment Statement Aligns with Intent Aliqnment Basis Oconee does not credit off-site power for redundant safe shutdown (i.e., Control Room shutdown) following a fire unless specifically analyzed to show that offsite power is available.

Oconee relies upon Keowee hydro station to provide emergency onsite power in lieu of using offsite power. Offsite power has not been analyzed or demonstrated to be free of fire damage for redundant shutdown.

The cascading power supply analysis determines fire impact to credited power sources and is utilized in the analysis of fire areas for safe shutdown.

This analysis ensures power is available to operate credited safe shutdown equipment.

The intent of the guidance is to ensure that if offsite power is credited for redundant safe shutdown equipment that it is demonstrated to be available.

Also for cases where offsite power could adversely impact safe shutdown it is assumed to be available.

Since Oconee does not credit offsite power, it is not required to demonstrate it is free of fire damage; thus Oconee meets the intent of the guidance.Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 8.4.3, 11.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 13 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.8 (Safety-Related Equipment]

Applicabile Applicable Alignment Statement Aligns NEI 00-01 Guidance Post-fire safe shutdown systems and components are not required to be safety-related, Comments rC Comments Alignment Basis Credited safe shutdown components are not always safety related. Most are safety related due to their credited emergency function(s).

Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Attachment B Oconee ONS -LAR No 2008-01 Supplement.mdb Page 14 of112 1013012008 Transition Tool Version 1.0.6 OSC-9291 -NFP insition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section; 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.9 [72 Hour Coping]Applicabili Applicable Alignment Statement Aligns NEI 00-01 Guidance The post-fire safe shutdown analysis assumes a 72-hour coping period starting with a reactor scram/trip.

Fire-induced impacts that provide no adverse consequences to hot shutdown within this 72-hour period need not be included in the post-fire safe shutdown analysis.

At least one train can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capability to achieve cold shutdown.Comments Alignment Basis 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> coping period was implicitly analyzed based on the compliance strategy requirement to perform cold shutdown repairs within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures and analysis currently demonstrate ONS has the capability to meet this requirement.

Note: NFPA 805 does not have any explicit requirements to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; therefore, NFPA-805 licensing will apply.Comments Unit Reference Document EI R 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10118/2008 Doec. Details Section 3.4.2 UFSAR Section 9.6, Standby Shutdown Facility Oconee ONS -LAR No 2008-01 Supplement.mdb Page 15of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.1.10 [Manual /Automatic Initiation of Systems]Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance Manual initiation from the main control room or emergency control stations of systems required to achieve and maintain safe shutdown is acceptable where permitted by current regulations or approved by NRC; automatic initiation of systems selected for safe shutdown is not required but may be included as an option.Comments Alignment-Basis Oconee does not credit the automatic initiation of systems for safe shutdown.

Systems will be manually initiated from the control room or emergency control stations.

The SSF is an alternate shutdown location and is manually initiated.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 3.4.2 and 4.16 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 16 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFF insition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00.01 Ref 3.1.1.11 [Multiple Affected Units]Applicabil Applicable Alignment Statement Aligns NEI 00-01 Guidance Where a single fire can impact more than one unit of a multi-unit plant, the ability to achieve and maintain safe shutdown for each affected unit must be demonstrated.

Comments Alignment Basis The affects of fire on the ability to achieve and maintain safe shutdown of all three units have been evaluated for all fire areas in the safe shutdown analysis.

The analysis has demonstrated this ability for each unit separately and for all three units collectively where required.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 Doc. Details Section 3.4.2 Oconee Page 17 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP insition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2 Shutdown Functions Applicabilit, Applicable Aliqnment Statement Not Required NEI 00-01 Guidance The following discussion on each of these shutdown functions provides guidance for selecting the systems and equipment required for safe shutdown.

For additional information on BWR system selection, refer to GE Report GE-NE-T43-00002-00-01-R01 entitled "Original Safe Shutdown Paths for the BWR." Comments Alignment Basis Generic Paragraph.

Alignment discussed in subsequent sections.Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 18 of 112 10/30/2008 Transition Too[ Version 1.0.6 OSC-9291 -NFP trnsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.1 Reactivity Control NEI 00-01 Guidance[BWR] Control Rod Drive System The safe shutdown performance and design requirements for the, reactivity control function can be met without automatic scram/trip capability.

Manual scram/reactor trip is credited.

The post-fire safe shutdown analysis must only provide the capability to manually scram/trip the reactor.[PWR] Makeup/Charging There must be a method for ensuring that adequate shutdown margin is maintained by ensuring borated water is utilized for RCS makeup/charging.

Comments Applicability Applicable Alignment Statement Aligns Alignment Basis For a SSF shutdown, borated water from the SFP using the RCMU pump is used to maintain shutdown margin following automatic or manual reactor trip. For a shutdown from the control room, borated water from the BWST using normal injection (HPI) is used to maintain shutdown margin. Minimum Boron concentration in the SFP and BWST has been calculated to ensure shutdown margins for the Appendix R event.Comments Unit Reference Document OSC-2282 Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 OSC-7706 Section 11.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 19 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP :nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.2 Pressure Control Systems NEI 00-01 Guidance The systems discussed in this section are examples of systems that can be used for pressure control. This does not restrict the use of other systems for this purpose.[BWR] Safety Relief Valves (SRVs)The SRVs are opened to maintain hot shutdown conditions or to depressurize the vessel to allow injection using low pressure systems. These are operated manually.

Automatic initiation of the Automatic Depressurization System is not a required function.[PWR] Makeup/Charging RCS pressure is controlled by controlling the rate of charging/makeup to the RCS. Although utilization of the pressurizer heaters and/or auxiliary spray reduces operator burden, neither component is required to provide adequate pressure control. Pressure reductions are made by allowing the RCS to coollshrink, thus reducing pressurizer level/pressure.

Pressure increases are made by initiating charging/makeup to maintain pressurizer level/pressure.

Manual control of the related pumps is acceptable.

Comments Applicability Applicable Alignment Statement Aligns Ali gnment Basis For a control room shutdown, ONS credits use of makeup/charging to control RC pressure at hot standby conditions.

The pressurizer safety valves are credited for limiting RC overpressure.

The use of pressurizer auxiliary spray Is credited for reducing RC pressure during cool down.Comments unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Section 11.4 For a SSF shutdown, ONS credits use of pressurizer heaters and makeup/charging to control RC pressure at hot standby conditions.

The pressurizer safety valves are credited for limiting RC overpressure.

The use of pressurizer auxiliary spray and the pressurizer PORV is credited for reducing RC pressure during cool down.Oconee ONS -LAR No 2008-01 Supplernent.mdb Page 20 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP insition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.3 Inventory Control NEI 00-01 Guidance[BWR] Systems selected for the inventory control function should be capable of supplying sufficient reactor coolant to achieve and maintain hot shutdown.

Manual initiation of these systems is acceptable.

Automatic initiation functions are not required.[PWR]: Systems selected for the inventory control function should be capable of maintaining level to achieve and maintain hot shutdown.

Typically, the same components providing inventory control are capable of providing pressure control. Manual initiation of these systems is acceptable.

Automatic initiation functions are not required.Comments Applicability Applicable Alignment Statement Aligns Oconee Alignment Basis Reactor makeup from the SSF using the SSF RC Makeup Pump taking suction from the SFP or normal injection (HPI) via BWST is used to maintain reactor coolant inventory levels, Oconee assumes manual initiation of these systems.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 Doc. Details Section 11.4 Page 21 of 112 10130/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.4 Decay Heat Removal NEI 00-01 Guidance[BWR] Systems selected for the decay heat removal function(s) should be capable of: o Removing sufficient decay heat from primary containment, to prevent containment over-pressurization and failure.o Satisfying the net positive suction head requirements of any safe shutdown systems taking suction from the containment (suppression pool).o Removing sufficient decay heat from the reactor to achieve cold shutdown.[PWR] Systems selected for the decay heat removal function(s) should be capable of: o Removing sufficient decay heat from the reactor to reach hot shutdown conditions.

Typically, this entails utilizing natural circulation in lieu of forced circulation via the reactor coolant pumps and controlling steam release via the Atmospheric Dump valves.o Removing sufficient decay heat from the reactor to reach cold shutdown conditions.

This does not restrict, the use of other systems.Comments Applicabilit Applicable Alignment Statement Aligns Alignment Basis For an SSF shutdown decay heat removal during hot standby conditions and cool down of the RCS is provided by natural circulation of the RCS through both steam generators utilizing the SSF auxiliary service water pump.For a control room shutdown decay heat removal during hot standby conditions and cool down of the RCS is provided by natural circulation of the RCS through both steam generators utilizing the MDEFDWPs.Comments Unit Reference Document.EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Section 11.4 OSC-9347, Thermal Hydraulic Analysis for NFPA-805 Transition, Rev.1, 9/18/2008 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 22 of 112 10/30/2008 Transition Tool Version 1.0.6 6SC-9291 -NFP insition B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.5 Process Monitoring NEt 00-01 Guidance The process monitoring function is provided for all safe shutdown paths. IN 84-09, Attachment 1,Section IX "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (1 OCFR50 Appendix R)" provides guidance on the instrumentation acceptable to and preferred by the NRC for meeting the process monitoring function, This instrumentation is that which monitors the process variables necessary to perform and control the functions specified in Appendix R Section lll.L1. Such instrumentation must be demonstrated to remain unaffected by the fire. The IN 84-09 list of process monitoring is applied to alternative shutdown (llI.G.3).

IN 84-09 did not identify specific instruments for process monitoring to be applied to redundant shutdown (III.G.1 and III.G.2).

In general, process monitoring instruments similar to those listed below are needed to successfully use existing operating procedures (including Abnormal Operating Procedures).

BWR o Reactor coolant level and pressure o Suppression pool level and temperature o Emergency or isolation condenser level o Diagnostic instrumentation for safe shutdown systemsoLevel indication for tanks needed for safe shutdown PWR o Reactor coolant temperature (hot leg I cold leg)o Pressurizer pressure and level o Neutron flux monitoring (source range)o Level indication for tanks needed for safe shutdown o Steam generator level and pressure o Diagnostic instrumentation for safe shutdown systems The specific instruments required may be based on operator preference, safe shutdown procedural guidance strategy (symptomatic vs. prescriptive), and systems and paths selected for safe shutdown.Comments Applicability Applicable Alignment Statement Alignment Basis Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 23 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP insition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 80S Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Aligns with Intent Process monitoring has been analyzed on a functional level for safe shutdown systems (RCS temp, PZR level and temp, SG level, diagnostic instruments and tank level instruments).

BWST level is provided for a control room shutdown, the SFP level at the SSF is related to the suction pressure of the RCMU pump. An exemption for boron sampling in lieu of neutron source range.monitoring instrumentation has been granted for the SSF, therefore neutron source range instrumentation has not been provided or analyzed for the SSF. Steam generator pressure instruments are also not provided in the SSF. An exemption for steam generator pressure indication has been granted for the SSF. Both Neutron Instrumentation and steam generator pressure indication are available in the Main Control Room. The intent of the guidance is that indication for the above parameters be provided.

The NRC has accepted the lack of SSF indication for two of the parameters, therefore, based on the exemptions, Oconee aligns with.the intent of the guidance.EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Section 11.4 and Attachment P 1983-08-31 NRC SER, Nuclear Instrumentation and SG Pressure, 8/31/1983 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 24 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFF insition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.6 Support Systems Applicability Alignment Statement Not Required NEI 00-01 Guidance[Blank Heading -No specific guidance]Comments Alignment Basis Generic Heading alignment discussed in subsequent paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 25 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFF insition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref NEI 00-01 Guidance 3.1.2.6,1 Electrical Systems AC Distribution System Power for the Appendix R safe shutdown equipment is typically provided by a medium voltage system such as 4.16 KV Class 1E busses either directly from the busses or through step down transformers/load centers/distribution panels for 600, 480 or 120 VAC loads. For redundant safe shutdown performed in accordance with the requirements of Appendix-R Section III.G.1 and 2, power may be supplied from either offaite power sources or the emergency diesel generator depending on which has been demonstrated to be free of fire damage. No credit should be taken for a fire causing a loss of offsite power. Refer to Section 3.1.1.7.DC Distribution System Typically, the 125VDC distribution system supplies DC control power to various 125VDC control panels including switchgear breaker controls.

The 1 25VDC distribution panels may also supply power to the 120VAC distribution panels via static inverters.

These distribution panels typically supply power for instrumentation necessary to complete the process monitoring functions.

For fire events that result in an interruption of power to the AC electrical bus, the station batteries are necessary to supply any required control power during the interim time period required for the diesel generators to become operational.

Once the diesels are operational, the 125 VOC distribution system can be powered from the diesels through the battery chargers.[BWR] Certain plants are also designed with a 25OVDC Distribution System that supplies power to Reactor Core Isolation Cooling and/or High Pressure Coolant Injection equipment.

The DC control centers may also supply power to various small horsepower Appendix R safe shutdown system valves and pumps. If the DC system is relied-upon to support safe shutdown without battery chargers being available, it must be verified that sufficient battery capacity exists to support the necessary loads for sufficient time (either until power is restored, or the loads are no longer required to operate).A lica Comments Applicable Alignment Statement Alignment Basis Comments n Reference Document Doc. Details Oconee. Page 26 of 112 10/30/2008 ONS -LAR No 2008-01 Supplement.mdb Transition Tool Version 1.0.6 OSC-9291 -NFF insition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Aligns with Intent Offsite power is not credited for a control room shutdown unless specifically analyzed to show that offsite power is available and is not credited beyond the first 10 minutes of a fire event for a SSF shutdown; however, if available it is provided to safe shutdown equipment through main feeder buses (MFBs).Oconee does not have onsite diesel generators.

Emergency onsite power to the MFBs is provided from the Keowee Hydro power station. Both AC and DC power supplies are analyzed for their availability and capacity to support the required safe shutdown loads. Oconee aligns with this guidance except Keowee Hydro power station is relied upon for emergency power instead of onsite diesel generators.

The safe shutdown equipment operated from the alternate shutdown location, SSF, has its own diesel supplied power and DC systems.EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3,10/18/2008 Attachment P Oconee ONS -LAR No 2008-01 Supplementmdb Page 27 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFF insitlon B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.6.2 Cooling Systems (Main Section]NEI 00-01 Guidance Various cooling water systems may be required to support safe shutdown system operation, based on plant-specific considerations.

Typical uses include: 0 0 0 0 RHR/SDC/DHO Heat Exchanger cooling water Safe shutdown pump cooling (seal coolers, oil coolers)Diesel generator cooling HVAC system cooling water Applicability Applicable Alignment Statement Aligns Oconee Comments Alignment Basis Required cooling system components have been included in the SSEL. The EIR assumes that cooling systems are capable of performing their design function and are not out of service or degraded at the onset of the fire. If free of fire damage, they are capable of performing their cooling function for safe shutdown.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Section 11.4 and Attachment P Page 28 of 112 10/3012008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFPI isition B-2 Table Rev. I Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.2.6,2 Cooling Systems[HVAC]NEI O0-01 Guidance HVAC Systems HVAC Systems may be required to assure that safe shutdown equipment remains within its operating temperature range, as specified in manufacturer's literature or demonstrated by suitable test methods, and to assure protection for plant operations staff from the effects of fire (smoke, heat, toxic gases, and gaseous fire suppression agents).HVAC systems may be required to support safe shutdown system operation, based on plant-specific configurations.

Typical uses include: o Main control room, cable spreading room, relay room o ECCS pump compartments o Diesel generator rooms o Switchgear rooms Plant-specific evaluations are necessary to determine which HVAC systems are essential to safe shutdown equipment operation.

Comments Applicability Applicable Alignment Statement Aligns Alignment Basis Required HVAC components have been included on the SSEL based on functional requirements and feedback from Oconee System Engineering.

This includes-cooling for the control room, cable room, and equipment rooms. The SSF has an independent HVAC system which provides cooling for the SSF and SSF equipment, including the diesel generator and switchgear rooms.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 D£c. Details Attachment P and Section 11.4 Page 29 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP/ isition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.3 Methodology for Shutdown System Selection Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Refer to Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe shutdown systems and developing the shutdown paths.The following methodology may be used to define the safe shutdown systems and paths for an Appendix R analysis:[Refer to hard copy of NEI 00-01 for Figure 3-2]Comments Alignment Basis Generic paragraph.

Alignment is discussed in subsequent paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 30 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPI isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.3.1 Identify safe shutdown functions NEI 00-01 Guidance Review available documentation to obtain an understanding of the available plant systems and the functions required to achieve and maintain safe shutdown.Documents such as the following may be reviewed: o Operating Procedures (Normal, Emergency, Abn'mal)o System descriptions o Fire Hazard Analysis o Single-line electrical diagrams o Piping and Instrumentation Diagrams (P&IDs)o [BWR] GE Report GE-NE-T43-00002-00-01-R02 entitled 'Original Shutdown Paths for the BWR" Comments Applicability Applicable Alignment Statement Aligns Alignment Basis Safe shutdown functions, systems and components needed to satisfy the safe shutdown performance goals were identified from available plant documentation.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8 and Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 31 of 112 10130/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP/ isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.3.2 Identify Combinations of Systems that Satisfy Each Safe Shutdown Function NEI 00-01 Guidance Given the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of achieving the safe shutdown functions of reactivity control, pressure control, inventory control, decay heat removal, process monitoring, and support systems such as electrical and cooling systems (refer to Section 3.1.2). This selection process does not restrict the use of other systems. In addition to achieving the required safe shutdown functions, consider spurious operations and power supply issues that could impact the required safe shutdown function.Comments Applicabilit Applicable Alignment Statement Aligns Alioqnment Basis Safe shutdown functions, systems and components needed to satisfy the safe shutdown performance goals were selected using the criteria and assumptions of NEI 00-01, Sections 3.1.1 and 3.1.2.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.4 and Attachment P Oconee Page 32 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Toot Version 1.0.6 OSC-9291 -NFPJ isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.3.3 Define Combinations of Systems for Each Safe Shutdown Path Applicabilit Applicable Alignment Statement Aligns NEI 00-01 Guidance Select combinations of systems with the capability of performing all of the required safe shutdown functions and designate this set of systems as a safe shutdown path. In many cases, safe shutdown paths may be defined on a divisional basis since the availability of electrical power and other support systems must be demonstrated for each path.Comments Alignment Basis Safe shutdown functions, systems and components needed to satisfy the safe shutdown performance goals were identified and placed into safe shutdown logic diagrams to show success paths.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 11.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 33 of 112 10130/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPi isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.1.3.4 Assign Shutdown Paths to Each Combination of Systems Applicability Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Assign a path designation to each combination of systems. The path will serve to document the combination of systems relied upon for safe shutdown in each fire area. Refer to Attachment 1 to this document (NEI 00-01) for an example of a table illustrating how to document the various combinations of systems for selected shutdown paths.Comments Alignment Basis Safe shutdown logic diagrams were utilized to show success paths for the various safe shutdown functions.

Success paths were designated for each system and performance goal. The example in the attachment showed designating the equipment for 3 discrete safe shutdown success paths. Oconee did not assign a 'path designation' to each combination of systems or equipment, instead the logic diagrams provided numerous combinations of 'success paths' that could be used to achieve safe shutdown.

Oconee then credited one combination of success paths for each fire area. This meets the intent of the guidance.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.4.2, 11.4 and Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 34 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPi -isition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section; 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2 Safe Shutdown Equipment Selection NEI 00-01 Guidance The previous section described the methodology for selecting the systems and paths necessary to achieve and maintain safe shutdown for an exposure fire event (see Section 5.0 DEFINITIONS for "Exposure Fire"). This section describes the criteria/assumptions and selection methodology for identifying the specific safe shutdown equipment necessary for the systems to perform their Appendix R function.

The selected equipment should be related back to the safe shutdown systems that they support and be assigned to the same safe shutdown path as that system, The list of safe shutdown equipment will then form the basis for identifying the cables necessary for the operation or that can cause the maloperation of the safe shutdown systems.Comments Applicability Applicable Alignment Statement Not Required Aliqnment Basis Generic paragraph.

Alignment discussed in subsequent sections.Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 35 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPi isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section; 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1 Criteria / Assumptions Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Consider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:

Comments Alignment Basis Generic paragraph.

Alignment discussed in subsequent paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 36 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPj isition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.1 [Primary Secondary Components]

NEI 00-01 Guidance 3.2.1.1 Safe shutdown equipment can be divided into two categories.

Equipment may be categorized as (1) primary components or (2) secondary components.

Typically, the following types of equipment are considered to be primary components:

o Pumps, motor operated valves, solenoid valves, fans, gas bottles, dampers, unit coolers, etc.o All necessary process indicators and recorders (i.e., flow indicator, temperature indicator, turbine speed indicator, pressure indicator, level recorder)o Power supplies or other electrical components that support operation of primary components (i.e., diesel generators, switchgear, motor control centers, load centers, power supplies, distribution panels, etc.).Secondary components are typically items found within the circuitry for a primary component.

These provide a supporting role to the overall circuit function.

Some secondary components may provide an isolation function or a signal to a primary component via either an interlock or input signal processor.

Examples of secondary components include flow switches, pressure switches, temperature switches, level switches, temperature elements, speed elements, transmitters, converters, controllers, transducers, signal conditioners, hand switches, relays, fuses and various instrumentation devices.Determine which equipment should be included on the Safe Shutdown Equipment Ust (SSEL). As an option, include secondary components with a primary component(s) that would be affected by fire damage to the secondary component.

By doing this, the SSEL can be kept to a manageable size and the equipment included on the SSEL can be readily related to required post-fire safe shutdown systems and functions.

Comments Applicability Applicable Alignment Statement Aligns with Intent Alignment Basis The dividing of equipment into 2 categories approach was used at Oconee; 'primary'components were identified and added to the SSEL, 'secondary' components (referred to as subcomponents) were grouped together with the primary components.

Although some subcomponents were not individually identified (i.e., relays, fuses, hand switches,.

etc), the cable which connected to the subcomponents were identified and assigned to the primary components, In some instances, components were not captured by the cable selection process but were captured within the cascading Interlocks analysis as pseudo-components.

The affects of fire on these pseudo components was evaluated where appropriate.

Oconee aligns with the above guidance except the additional category of 'pseudo' components is used. Examples of pseudo components are ES, AFIS, iCC, and ICS.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3,10118/2006 Doc. Details Section 3.1 and Attachment P Oconee ONS -LAR No 200801 Supplement.mdb Page 37 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Sayety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.2 [Fire Damage to Mechanical Components (not electrically supervised)]

Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance 3.2.1.2 Assume that exposure fire damage to manual valves and piping does not adversely impact their ability to perform their pressure boundary or safe shutdown function (heat sensitive piping materials, including tubing with brazed or soldered joints, are not included in this assumption).

Fire damage should be evaluated with respect to the ability to manually open or close the valve should this be necessary as a part of the post-fire safe shutdown scenario.Comments Alignment Basis Safe Shutdown analysis assumptions for post-fire integrity of mechanical components to function as pressure boundaries are essentially identical.

No damage to packing or gaskets is assumed. The analysis assumes no damage to manual valves. The abilitity to manually operate valves post fire is evaluated in OSC-9535 as necessary.

Comments Unit Reference Document OSC-9535, Recovery and DID Action Evaluation in Support of Nuclear Safety Capability Assessment, Rev. 0, 10/29/2008 EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Open/Closed Closed Doc. Details Section 8.4 and Attachment P Open Item ID 3.2.1.2 Open Item Description

-Potential fire damage has not been specifically evaluated in regard to the ability to manually operate valves post fire.Disposition OSC-9535, Manual Action Feasibility in Support of Nuclear Safety Capability Assessment evaluates the ability to operate valves manually post fire.Date Entered 5/23/2008 Corrective Action Reference Include in LAR/TR Change Eval I Modification Referenc PIP 0-08-02444 No Oconee ONS -LAR No 2008-01 Supplement.mdb Page 38 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.3 [Manual Valve Positions]

Applicabili Applicable AlIgnment Statement Aligns NEI 00-01 Guidance Assume that manual valves are in their normal position as shown on P&IDs or in the plant operating procedures.

Comments Alignment BasIs Manual valves are assumed in their normal operating position from the operating procedures and other references.

Comments Reference Document El R 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc, Details Section 8.4 and Attachment P Oconee Page 39 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsltion B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2,4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.4 [Check Valves]Applicabilitv Applicable Alignment Statement Aligns NEI 00-01 Guidance Assume that a check valve closes in the direction of potential flow diversion and seats properly with sufficient leak tightness to prevent flow diversion.

Therefore, check valves do not adversely affect the flow rate capability of the safe shutdown systems being used for inventory control, decay heat removal, equipment cooling or other related safe shutdown functions.

Comments Alignment Basis Safe Shutdown analysis assumptions for post-fire integrity of check valves is functionally identical.

Coments~Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.4 and Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 40 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP[" nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.5 [Instrument Failures]Applicabilitv Applicable Alignment Statement Aligns NEI 00-01 Guidance Instruments (e.g., resistance temperature detectors, thermocouples, pressure transmitters, and flow transmitters) are assumed to fail upscale, midscale, or downscale as a result of fire damage, whichever is worse. An instrument performing a control function is assumed to provide an undesired signal to the control circuit.Comments Alignment Basis Instruments are assumed to fail in the worst case providing an undesirable result.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.4 Oconee Page 41 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ret 3.2.1.6 [Spurious Components],pplicabili Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Identify equipment that could spuriously operate or mal-operate and impact the performance of equipment on a required safe shutdown path during the equipment selection phase. Consider Bin 1 of RIS 2004-03 during the equipment identification process.Comments Alignment Basis Spurious operation was considered in identification of SSEL components.

RIS 2004-03 Bin 1 circuit configurations are summarized as conductor-to-conductor shorts within a multiconductor cable, and thermoplastic-cable-to-thermoplastic-cable interactions.

Conductor-to-conductor shorts within a multiconductor cable configurations were considered for power, control, and instrumentation circuits whose fire-induced failures could prevent operation of safe shutdown equipment or through maloperstion cause a flow diversion, loss of coolant, or other scenario that could significantly impact the ability to achieve and maintain hot standby.Oconee aligns with the intent of this guidance because thermoplastic-cable-to-thermoplastic-cable interactions are not postulated due to Oconee cables being armor jacketed which would preclude cable-to-cable interactions.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.4, 8.2, 8.4 and Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 42 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.1.7 [Instrument Tubing]Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance Identify instrument tubing that may cause subsequent effects on instrument readings or signals as a result of fire. Determine and consider the fire area location of the instrument tubing when evaluating the effects of fire damage to circuits and equipment in the fire area.Comments Alignment Basis Instrument tubing has been included in the evaluation for effects from fire.Comments Unit Reference Document EIR 51-5044354-003.

Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 3.2 and Attachment 0 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 43 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.2 Methodology for Equipment Selection Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Refer to Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown equipment.

Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:[Refer to hard copy of NEI 00-01 for Figure 3-3]Comments Alignment Basis Generic Paragraph, Alignment discussed in subsequent paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 44 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.22.1 identify the System Flow Path for Each Shutdown Path Appiicabilitv Applicable Alignment Statemen Aligns with Intent NEI 00-01 Guidance Mark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path. Refer to Attachment 2 for an example of an annotated P&ID illustrating this concept.Comments Alignment Basis P&IDs were marked up and used up to determine flow and diversion paths which were then translated into Safe Shutdown success path logic diagrams.

These logic diagrams were then used to identify potential SSEL components.

These P&ID drawings were not maintained as part of the safe shutdown analysis.

Instead, Oconee simplified flow diagrams (OSFDs) are marked up and annotated to designate specific flow paths for each system. This approach meets the intent of the guidance.Comments Unit Reference Document EIR 51-5044364-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10118/2008 Doc. Details Attachment P Page 45 of 112 Oconee.ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.2.2 Identify the Equipment in Each Safe Shutdown System Flow Path Including Equipment That May Spuriously Operate and Affect System Operation Applicabile Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Review the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all equipment in each system's flow path has been Identified.

Assure that any equipment that could spuriously operate and adversely affect the desired system function(s) is also identified.

If additional systems are identified which are necessary for the operation of the safe shutdown system under review, include these as systems required for safe shutdown.

Designate these new systems with the same safe shutdown path as the primary safe shutdown system under review (Refer to Figure 3-1).Comments Alignment Basis P&IDs and electrical one lines were marked up to determine flow and diversion paths for safe shutdown functions and to identify potential SSEL components including components that could spurious operate and affect the desired system function of SSD equipment.

Any new SSD 'success paths' identified were defined on logic diagrams, however the technique of designating a set number of 'safe shutdown paths' was not used. The Oconee approach of providing numerous 'success paths' meets the intent of the guidance, Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 46 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4,2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.2.3 Develop a List of Safe Shutdown Equipment and Assign the Corresponding System and Safe Shutdown Path(s) Designation to Each.Applicability Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Prepare a table listing the equipment identified for each system and the shutdown path that it supports.

Identify any valves or other equipment that could spuriously operate and impact the operation of that safe shutdown system. Assign the safe shutdown path for the affected system to this equipment.

During the cable selection phase, identify additional equipment required to support the safe shutdown function of the path (e.g.. electrical distribution system equipment).

Include this additional equipment in the safe shutdown equipment list. Attachment 3 to this document provides an example of a (SSEL). The SSEL identifies the list of equipment within the plant considered for safe shutdown and it documents various equipment-related attributes used in the analysis.Comments Alignment Basis P&IDs were marked up to determine flow and diversion paths for safe shutdown functions and to identify potential SSEL components including spurious operations.

An iterative process was utilized to arrive at the final SSEL based on additional support components identified during the cable selection process (such as electrical distribution equipment).

The table listing as identified in Attachment 3 was not utilized, since the ARTRAK database has its own data entry format, which provides the necessary equipment information.

Also, equipment was not assigned a safe shutdown'path'; instead safe shutdown logic diagrams denote system function 'success paths'. The Oconee approach meets the intent of the guidance.Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10118/2008 Attachment P Oconee ONS -LAR No 2008-01 Supplement.mdb Page 47 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.2.4 Identify Equipment Information Required for the Safe Shutdown Analysis NEI 00-01 Guidance Collect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for the equipment.

In order to facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer to Attachment 3 to this document for an example of a SSEL. Examples of related equipment data should include the equipment type, equipment description, safe shutdown system, safe shutdown path, drawing reference, fire area, fire zone, and room location of equipment.

Other information such as the following may be useful in performing the safe shutdown analysis:

normal position, hot shutdown position, cold shutdown position, failed air position, failed electrical position, high/low pressure interface concern, and spurious operation concern.Comments Applicabilit, Applicable Alignment Statement Aligns with Intent Alignment Basis Plant design information on capability to meet safe shutdown functions were collected to the extent necessary to identify potential SSEL components including components required due to spurious operation concerns.

An iterative process was utilized to arrive at the final SSEL based on additional support components identified during the cable selection process and review of plant design basis information.

The required equipment information listed in Attachment 3 to NEI 00-01 is contained within the ARTRAK database except for 'safe shutdown path' and 'room location'.

Equipment at Oconee was not assigned a 'safe shutdown path'; instead safe shutdown logic diagrams denote system function 'success paths'. The ARTRAK database includes fire area and zone but does not include room locations.

All 'examples' of data listed are not required to perform a safe shutdown analysis.

The Oconee approach meets the intent of the guidance.

-Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.4.2 and Attachment P ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 48 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 605 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref 3.2.2.5 Identify Dependencies Between Equipment, Supporting Equipment, Safe Shutdown Systems and Safe Shutdown Paths.Applicabll Applicable Alignment Statement Aligns NEI 00-01 Guidance In the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as electrical power and interlocked equipment.

As an aid in assessing identified impacts to safe shutdown, consider modeling the dependency between equipment within each safe shutdown path either in a relational database or in the form of a Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an example of a SSLD that may be developed to document these relationships.

Comments Alignment Basi Safe Shutdown logic diagrams were utilized to assess the dependencies of equipment and systems on the ability to achieve the safe shutdown performance goals. Cascading power supply and cascading interlock analyses were developed to support this effort.Attachment 4 of NEI 00-01 was used in this effort.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 Doc. Details Sections 3.1.2, 3.2, 3.4.2 and Attachments C, H& P Page 49 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 2.4.2.2.1 Circuits Required in Nuclear Safety Functions.

Circuits required for the nuclear safety functions shall be identified.

This includes circuits that are required for operation, that could prevent the operation, or that result in the maloperation of the equipment identified in 2.4.2.1. This evaluation shall consider fire-induced failure modes such as hot shorts (external and internal), open circuits, and shorts to ground, to identify circuits that are required to support the proper operation of components required to achieve the nuclear safety performance criteria, including spurious operation and signals. This will ensure that a comprehensive population of circuitry is evaluated.

2.4.2.2.2 Other Required Circuits.

Other circuits that share common power supply and/or common enclosure with circuits required to achieve nuclear safety performance criteria shall be evaluated for their impact on the ability to achieve nuclear safety performance criteria.(a)(b)Common Power Supply Circuits.

Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance cdteria shall be identified.

This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device.Common Enclosure Circuits.

Those circuits that share enclosures with circuits required to achieve the nuclear safety performance criteria and whose fire-induced failure could cause the loss of the required components shall be identified.

The concem is that the effects of a fire can extend outside of the immediate fire area due to fire-induced electrical faults on inadequately protected cables or via inadequately sealed fire area boundaries.

NEI 00-01 Ref 3.3 Safe Shutdown Cable Selection and Location Apolicability Applicable Alignment Statement Not Required NEI 00-01 Guidance This section provides industry guidance on the recommended methodology and criteria for selecting safe shutdown cables and determining their potential impact on equipment required for achieving and maintaining safe shutdown of an operating nuclear power plant for the condition of an exposure fire. The Appendix R safe shutdown cable selection criteda are developed to ensure that all cables that could affect the proper operation or that could cause the maloperation of safe shutdown equipment are identified and that these cables are properly related to the safe shutdown equipment whose functionality they could affect. Through this cable-to-equipment relationship, cables become part of the safe shutdown path assigned to the equipment affected by the cable.Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 50 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1 Criteria /Assumptions Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance To identify an impact to safe shutdown equipment based on cable routing, the equipment must have cables that affect it identified.

Carefully consider how cables are related to safe shutdown equipment so that impacts from these cables can be properly assessed in terms of their ultimate impact on safe shutdown system equipment.

Consider the following criteria when selecting cables that impact safe shutdown equipment:

Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 51 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.1 [Cable Selection]

NEI 00-01 Guidance The list of cables whose failure could impact the operation of a piece of safe shutdown equipment includes more than those cables connected to the equipment.

The relationship between cable and affected equipment is based on a review of the electrical or elementary wiring diagrams.

To assure that all cables that could affect the operation of the safe shutdown equipment are identified, investigate the power, control, instrumentation, interlock, and equipment status indication cables related to the equipment.

Consider reviewing additional schematic diagrams to identify additional cables for interlocked circuits that also need to be considered for their impact on the ability of the equipment to operate as required in support of post-fire safe shutdown.

As an option, consider applying the screening criteria from Section 3.5 as a part of this section. For an example of this see Section 3.3.1.4.Comments Applicabilit Applicable Alignment Statement Aligns Alignment Basis The cables were selected using the component's electrical elementary diagram as a guide and performing a point to point review of the associated connection diagrams.

During the cable selection process, a circuit fault analysis for each Appendix R component was not initially performed.

This made the initial compliance analysis bounding.

Further analysis to determine the effects of a fire induced hot short, open circuit and short to ground as applicable was performed during the fire area compliance assessment task.Comments Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Dog. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3,10/18/2008 Sections 3.1, 3.2, 3.4 and 8.2 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 52 of 112 10/30/2008 Transition Toot Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.2 [Cables Affecting Multiple Components]

Applicability Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance In cases where the failure (including spurious actuations) of a single cable could impact more than one piece of safe shutdown equipment, include the cable with each piece of safe shutdown equipment.

Comments Alignment Basis For control logic circuits where multiple components receive signals from common control logic, the control logic was analyzed as a primary component and a pseudo component was created for the logic with cables selected accordingly.

This same methodology was used for similar circuit scenarios such as common power supplies.Whereas this approach does not assign the cable to each individual component, the effects on each component due to fire damage was evaluated.

This meets the intent of the guidance.Comments Unit Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.1, 3.2, and 8.2 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 53 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.3 [Isolation Devices]Applicabilit Applicable Alignment Statement Aligns NEI 00-01 Guidance Electrical devices such as relays, switches and signal resistor units are considered to be acceptable isolation devices. In the case of instrument loops, review the isolation capabilities of the devices in the loop to determine that an acceptable Isolation device has been installed at each point where the loop must be isolated so that a fault would not impact the performance of the safe shutdown instrument function.Comments Alignment Basis The cables were selected using the component's electrical elementary diagram as a guide and performing a point to point review of the associated connection diagrams.

During the cable selection process, a circuit fault analysis for each Appendix R component was not initially performed.

However, all circuits/cables that are electrically connected to the circuit under analysis were then identified up to a credited isolation device including instrument loops.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 Doc. Details Sections 3.1, 3.2,, 3.4 and 8.2 ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 417/2008 Page 54 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.4 [Identify "Not Required" Cables)Applicabilit Applicable Alignment Statement Aligns NEI 00-01 Guidance Screen out cables for circuits that do not impact the safe shutdown function of a component (i.e., annunciator circuits, space heater circuits and computer input circuits) unless some reliance on these circuits is necessary.

However, they must be isolated from the component's control scheme in such a way that a cable fault would not impact the performance of the circuit.Comments Alignment Basis The cables were selected using the component's electrical elementary diagram as a guide and by performing a point to point review of the associated connection diagrams.During the cable selection process, a circuit fault~analysis for each Appendix R component was performed.

Cables associated with outputs from auxiliary contacts to computer points, annunciators or motor heaters were excluded from cable selection when it was concluded that the cable failure will not impact the primary component.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3,1011812008 Doc. Details Sections 3.1, 3.2, 3.4, and 8.2 ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 417/2008 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 55 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Salety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.5 [Identification of Power Supplies]NEI 00-01 Guidance For each circuit requiring power to perform its safe shutdown function, identify the cable supplying power to each safe shutdown and/or required interlock component.

Initially, identify only the power cables from the immediate upstream power source for these interlocked circuits and components (i.e., the closest power supply, load center or motor control center). Review further the electrical distribution system to capture the remaining equipment from the electrical power distribution system necessary to support delivery of power from either the offsite power source or the emergency diesel generators (i.e., onsite power source) to the safe shutdown equipment.

Add this equipment to the safe shutdown equipment list. Evaluate the power cables for this additional equipment for associated circuits concerns.Comments Applicability Applicable Alignment Statement Aligns Alignment Basis The cables were selected using the component's electrical elementary diagram as a guide and by performing a point to point review of the associated connection diagrams.During the cable selection process, power supplies and interlocks were identified.

The cascading power supplies, pseudo-components created for power supply interlocks and the cascading interlocks all serve to identify required power supplies and their interconnections and dependencies to ensure credited safe shutdown components are supplied with motive electrical power.Comments Unit Reference Document Doc, Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.1. 3.2, 3.4, 8.2, 8.4, and Att. C, G& P ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 56 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ret 3.3.1.6 [Auto Initiation Logic]NEI 00-01 Guidance The automatic initiation logics for the credited post-fire safe shutdown systems are not required to support safe shutdown.

Each system can be controlled manually by operator actuation in the main control room or emergency control station. If operator actions outside the MCR are necessary, those actions must conform to the regulatory requirements on manual actions. However, if not protected from the effects of fire, the fire-induced failure of automatic initiation logic circuits must not adversely affect any post-fire safe shutdown system function.Comments Applicability Applicable Alignment Statement Does not Align Alignment Basis Comments Unit Reference Document Doc. Details.Automatic initiation logic was not credited for performance of safe shutdown functions.

Manual operation of components from the Main Control Room, SSF or locally were identified during the fire area compliance assessment task as needed. To preclude adverse impact from automatic initiation logic circuits or control logic circuits where multiple components receive signals from common control logic, the control logic was analyzed as a primary component and a pseudo component was created for the logic with cables selected accordingly.

This same methodology was used for similar circuit scenarios such as common power supplies.

In this way the effects of a fire induced failure causing spurious component operation were fully evaluated.

Local manual actions to achieve hot standby were used but are not within the regulatory requirements for a deterministic analysis; open items were created to address these actions. The use of these HSB manual actions does not align with the guidance.Open Item Description The use of manual actions for HSB does not meet regulatory requirements.

Open Item ID 3.3.1.6 Oconee Disposition See treatment in Section 4.8.2.2 of the Transition Report. This item will remain open pending approval of the LAR Page 57 of 112 Ooen/Closed Open Date Entered 5/23/2008 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4,2.2 Nuclear Safety Capability Circuit Analysis Corrective Action Reference PiP 0-08-02444 Include in LARITR Yes Chanoe Eval / Modification Reference Oconee Page 58 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.1.7 [Circuit Coordination]

NEI 00-01 Guidance Cabling for the electrical distribution system is a concern for those breakers that feed associated circuits and are not fully coordinated with upstream breakers.

With respect to electrical distribution cabling, two types of cable associations exist. For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component.

For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to an MCC supports the MCC. However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center.Comments Applicability Applicable Alignment Statement Does not Align Open Item 1.3.3.1.7 Alignment Basis Proper coordination of common power supplies for all circuits was an assumption of the analysis.

Oconee's existing coordination study does not include all SSEL related power supplies.

The coordination study needs to be updated with the additional power supplies to ensure that the assumptions of the EIR remain valid.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 8.2 Date Entered 4/8/2008 Open Item Description The circuit coordination analysis for Oconee needs to be updated. The assumption of circuit coordination in the safe shutdown analysis needs to be validated.

Disposition This open item is being closed to PIP Corrective Action #1 which will track the completion of the analysis.Open/Closed Closed Corrective Action Reference Include in LAR/TR PI P 0-08-02444 No Change Eval / Modification Reference Oconee ONS -LAR No 2008-01 Supplement.mdb Page 59 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B.2 Table Rev. 1..... Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section; 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.2 Associated Circuit Cables NEI 00-01 Guidance Appendix R,Section III.G.2, requires that separation features be provided for equipment and cables, including associated nonsafety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve hot shutdown.

The three types of associated circuits were identified in Reference 6.1.5 and further clarified in a NRC memorandum dated March 22, 1982 from R. Mattson to D. Eisenhut, Reference 6.1.6. They are as follows: o Spurious actuations o Common power source a Common enclosure.

Comments Applicability Applicable Alignment Statement Alignment Basis Comments Unit Reference Document Doc. Details Not Required Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Oconee ONS -LAR No 2008-01 Supplement.mdb Page 60 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section; 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.2 [A] Associated Circuit Cables -Cables Whose Failure May Cause Spurious Actuations Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Safe shutdown system spurious actuation concerns can result from fire damage to a cablewhose failure could cause the spurious actuation/mal-operation of equipment whose operation could affect safe shutdown.

These cables are identified in Section 3.3.3 together with the remaining safe shutdown cables required to support control and operation of the equipment.

Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Page 61 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 1013012008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.2 [B] Associated Circuit Cables -Common Power Source Cables Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance The concern for the common power source associated circuits is the loss of a safe shutdown power source due to inadequate breaker/fuse coordination.

In the case of a fire-induced cable failure on a non-safe shutdown load circuit supplied from the safe shutdown power source, a lack of coordination between the upstream supply breaker/fuse feeding the safe shutdown power source and the load breaker/fuse supplying the non-safe shutdown faulted circuit can result in loss of the safe shutdown bus. This would result in the loss of power to the safe shutdown equipment supplied from that power source preventing the safe shutdown equipment from performing its required safe shutdown function.

Identify these cables together with the remaining safe shutdown cables required to support control and operation of the equipment.

Refer to Section 3.5.2.4 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc, Details Page 62 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.2 [C] Associated Circuit Cables -Common Enclosure Cables Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance The concern with common enclosure associated circuits is fire damage to a cable whose failure could propagate to other safe shutdown cables in the same enclosure either because the circuit is not properly protected by an isolation device (breaker/fuse) such that a fire-induced fault could result in ignition along its length, or by the fire propagating along the cable and into an adjacent fire area. This fire spread to an adjacent fire area could impact safe shutdown equipment in, that fire area, thereby resulting in a condition that exceeds the criteria and assumptions of this methodology (i.e., multiple fires). Refer to Section 3.5.2.5 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee Page 63 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.3 Methodology for Cable Selection and Location Applicablilty Applicable Alignment Statement Not Required NEI 00-01 Guidance Refer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for performing a post-fire safe shutdown analysis.Use the following methodology to define the cables required for safe shutdown including cables that may cause associated circuits concerns for a post-fire safe shutdown analysis:[Refer to hard copy of NEI 00-01 for Figure 3-4]Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc, Details-Oconee ONS -LAR No 2008-01 Supplement.mdb Page 64 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Guidance 3.3.3.1 Identify Circuits For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including the following documentation to identify the Required for the Operation of circuits (power, control, instrumentation) required for operation or whose failure may impact the operation of each piece of equipment:

the Safe Shutdown Equipment o Single-line electrical diagrams o Elementary wiring diagrams o Electrical connection diagrams o Instrument loop diagrams.For electrical power distribution equipment such as power supplies, identify any circuits whose failure may cause a coordination concern for the bus under evaluation.

If power is required for the equipment, include the closest upstream power distribution source on the safe shutdown equipment list. Through the iterative process described in Figures 3-2 and 3-3, include the additional upstream power sources up to either the offsite or the emergency power source.Applicability Comments Applicable Alignment Statement Alignment Basis Comments Unit Reference Document Doc, Details Aligns The circuits were identified utilizing the single line, elementary, and connection diagrams along with instrument loop drawings.

The iterative process of figures 3-2 and 3-3 of NEI 00-01 were used to include upstream power sources. For a given safe shutdown component, all cables that had the potential to impact the function of the component were initially identified to ensure that a bounding population of cables was provided for compliance analysis.

Only those cables which were adequately isolated from the component such as those associated with certain indicating lights and computer inputs were excluded, Oconee Page 65 of 112 10/30/2008 ONS -LAR No 2008-01 Supplement.mdb Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.3.3.2 Identify Interlocked Circuits and Cables Whose Spurious Operation or Mal-operation Could Affect Shutdown Applicabilit

'Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance In reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and equipment.

Assign to the equipment any cables for interlocked circuits that can affect the equipment.

While investigating the interlocked circuits, additional equipment or power sources may be discovered.

Include these interlocked equipment or power sources in the safe shutdown equipment list (refer to Figure 3-3) if they can impact the operation of the equipment under consideration.

Comments Alignment Basis For control logic circuits where multiple components receive signals from common control logic or interlocks, the control logic was analyzed as a primary component and a pseudo component was created on the SSEL for the logic with cables selected accordingly.

Pseudo-components whose associated cabling can affect another primary component based on common power were identified in the cable selection for the affected component as an interlocked primary component.

The cascading power supply and cascading interlocks analyses evaluate these interlocked components.

The Oconee approach of assigning cables to 'pseudo' components instead of to the equipment under consideration meets the intent of the guidance.Comments Unit Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3,10/18/2008 Sections 3.1, 3.2, 3.4, and 8.2 Oconee Page 66 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis, NEI 00-01 Ref 3.3.3.3 Assign Cables to the Safe Shutdown Equipment NEI 00-01 Guidance Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in maloperation of each piece of safe shutdown equipment.

Tabulate the list of cables potentially affecting each piece of equipment in a relational database including the respective drawing numbers, their revision and any interlocks that are investigated to determine their impact on the operation of the equipment.

In certain cases, the same cable may support multiple pieces of equipment.

Relate the cables to each piece of equipment, but not necessarily to each supporting secondary component.

If adequate coordination does not exist for a particular circuit, relate the power cable to the power source.affected equipment in the fire areas where the cable may be damaged.Comments This will ensure that the power source is identified as Applicability Applicable Alignment Statement Does not Align Aligqnment Basis Cables associated with SSEL components were selected in accordance with Section 3.3.1 and entered into ARTRAK for that component.

In some instances where cables affected multiple components, pseudo components were used and cables were assigned to them instead of the primary equipment.

ARTRAK also contains the direct and indirect power supplies for the safe shutdown components and any interlocks that could impact component operation.

SSEL component cables were also associated with interlocks and power supplies.

Coordination of power supplies was assumed when assigning cables to the safe shutdown equipment; an open item has been placed in the corrective action program to evaluate breaker coordination and resolve any issues if identified.

Oconee does not meet the intent of the guidance since it did not consider inadequate breaker coordination when selecting cables.Comments Unit Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Open/Closed Sections 3.1, 3.2, 3.4, and 8.2 Open Item lb Open Item Description Disposition Date Entered Oconee ONS -LAR No 2008-01 Supplement.mdb Page 67 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 3.3.3.3 Breaker coordination was assumed when assigning This open item is being closed to PIP cables to safe shutdown equipment.As a result, cables Corrective Action #1 which will track the whose fire-induced failure may impact safe shutdown completion of the analysis.equipment were not identified.

Corrective Action Reference P 0-8-02444 Closed 5/23/2008 Include in LARiTR No Change Eval / Modification Reference Oconee ONS -LAR No 2008-01 Supplement.mdb.Page 68 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5 Circuit Analysis and Evaluation Applicability Applicable Alignment Statement NEI 00.01 Guidance This section on circuit analysis provides information on the potential impact of fire on circuits used to monitor, control and power safe shutdown equipment.

Applying the circuit analysis criteria will lead to an understanding of how fire damage to the cables may affect the ability to achieve and maintain post-fire safe shutdown in a particular fire area. This section should be used in conjunction with Section 3.4, to evaluate the potential fire-induced impacts that require mitigation.

Appendix R Section 1ll.G.2 identifies the fire-induced circuit failure types that are to be evaluated for Impact from exposure fires on safe shutdown equipment.

Section Ill.G.2 of Appendix R requires consideration of hot shorts, shorts-to-ground and open circuits.Comments Alignment Basis Comments Unit Reference Document Doc. Details Not Required Generic paragraph.

Detailed alignment discussed in subsequent reference-paragraphs.

Oconee ONS -LAR No 2008-01 Supplement.mdb Page 69 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review ,NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.1 Criteria / Assumptions Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Apply the following criteria/assumptions when performing fire-induced circuit failure evaluations.

Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee' Page 70 of 112 ONS,- LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table 5-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.1.1 [Circuit Failure Types and Impact]NEI 00-01 Guidance Consider the following circuit failure types on each conductor of each unprotected safe shutdown cable to determine the potential impact of a fire on the safe shutdown equipment associated with that conductor.

o A hot short may result from a fire-induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage or signal on a specific conductor.

A hot short may cause a spurious operation of safe shutdown equipment.

o An open circuit may result from a fire-induced break in a conductor resulting in the loss of circuit continuity.

An open circuit may prevent the ability to control or power the affected equipment.

An open circuit may also result in a change of state for normally energized equipment. (e.g. [for BWRs] loss of power to the Main Steam Isolation Valve (MSIV) solenoid valves due to an open circuit will result in the closure of the MSIVs). Note that RIS 2004-03 indicates that open circuits, as an initial mode of cable failures, are considered to be of very low likelihood.

The risk-informed inspection process will focus on failures with relatively high probabilities..o A short-to-ground may result from a fire-induced breakdown of a cable insulation system, resulting in the potential on the conductor being applied to ground potential.

A short-to-ground may have all of the same effects as an open circuit and, In addition, a short-to-ground may also cause an impact to the control circuit or power train of which it is a part.Consider the three types of circuit failures identified above to occur individually on each conductor of each safe shutdown cable on the required safe shutdown path in the fire area.Comments.Applicabilit Applicable Alignment Statement Aligns with Intent Altqnment Basis AJI combinations of circuit failures except Intercable hot shorts are considered and evaluated to determine if spurious component actuation can occur. Intercable hot shorts were not considered due to the use of armored cable at Oconee; the armor jacketing of the cables prevent conductors from one cable shorting to conductors of another cable. In some cases, circuit analysis did not have to be performed because the entire population of cables associated with a safe shutdown component was adequately separated as required by the regulations from redundant components and cabling. Oconee meets the intent of the guidance except cable-to-cable interactions were not considered because the armor jacketing of the cables preclude hot short interactions.

Additionally cables which meet separation requirements are not postulated to fail, therefore performing circuit analysis was not required.Comments Unit Refe.rnce Document Doc, Details EI R 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.4 and 8.4 Oconee Page 71 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.1.2 [Circuit Contacts and Operational Modes]Aoplicabllitv Applicable Alignment Statement Aligns NEI 00-01 Guidance Assume that circuit contacts are positioned (i.e., open or closed) consistent with the normal mode/position of the safe shutdown equipment as shown on the schematic drawings.

The analyst must consider the position of the safe shutdown equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the safe shutdown equipment.

Comments Aliqnment Basis Analysis assumes that circuit contacts are positioned (i.e., open or closed) consistent in the normal mode/position of the safe shutdown equipment as shown on the schematic drawings or defined by procedure.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Sections 3.4, 8.2 and 8.4 Page 72 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.1.3 [Duration of Circuit Failures]Applicability Applicable Alignment Statement Does not Align, but has previous approval NEI 00-01 Guidance Assume that circuit failure types resulting in spurious operations exist until action has been taken to isolate the given circuit from the fire area, or other actions have been taken to negate the effects of circuit failure that is causing the spurious actuation.

The fire is not assumed to eventually clear the circuit fault. Note that RIS 2004-03 indicates that fire-induced hot shorts typically self-mitigate after a limited period of time.Comments Alignment Basis Comments Unit Reference Document Doc. Details Spurious operation of valves are assumed not D 1982-09-20, RAI On ONS to occur due to a fire postulated within the first Standby Shutdown Facility, 10 minutes of the event. After 10 minutes 9/20/1982 spurious operations exist until actions have been taken to either isolate the affected circuit or negate the effects of the spurious operation.

EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 FAQ 08-0051, Duration of Spurious Operation, Rev.draft, 4/15/2008 Section 8.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 73 of 112 10/3012008 Transition Tool Version 1,0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety CapabilityCircuit Analysis NEI 00-01 Ref 3.5.1.4 [Cable Failure Configurations]

Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance When both trains are in the same fire area outside of primary containment, all cables that do not meet the separation requirements of Section IllI.G.2 are assumed to fail in their worst case configuration.

Comments Alignment Basi All unprotected cables and equipment within the fire area that did not meet the separation requirements of Section IIl.G.2 were assumed to fail in their worst case configuration.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.2, 3.4 and 8.4 Page 74 of 112 Oconee ONS -LAR No 2006-01 Supplement.mrdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsitlon B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEt 00-01 Ref 3.5.1.5 [A, Circuit Failure Risk Assessment Guidance]Applicabillit Applicable Alignment Statement Not Required Open Item ID 3.5.1.5.A Corrective Action Reference Include In LARITR Change Eval I Modification Reference NEI 00-01 Guidance The following guidance provides the NRC inspection focus from Bin 1 of RIS 2004-03 in order to identify any potential combinations of spurious operations with higher risk significance.

Bin 1 failures should also be the focus of the analysis; however, NRC has indicated that other types of failures required by the regulations for analysis should not be disregarded even if in Bin 2 or 3. If Bin 1 changes in subsequent revisions of RIS 2004-03, the guidelines in the revised RIS should be followed.Comments Alignment Basis Con Generic Paragraph.

Specific alignment discussed in subsequent reference sections.Open Item Description Due to ongoing industry issues related to this topic, an open item is created to track resolution of Multiple Spurious Operations per FAQ 07-0038.nments Unit Reference Document Open/Closed Open Doc. Details Date Entered 41812008 Disposition See treatment in Section 4.8.2.1 of Transition Report.Open pending LAR approval.PIP 0-08-02444 Yes Oconee ONS -LAR No 2008-01 Supplement.mdb Page 75 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Guidance 3.5.1.5 [B, Cable Failure For multiconductor cables testing has demonstrated that conductor-to-conductor shorting within the same cable is the most common mode of failure. This is often Modes] referred to as "intra-cable shorting." It is reasonable to assume that given damage, more than one conductor-to-conductor short will occur in a given cable. A second primary mode of cable failure is conductor-to-conductor shorting between separate cables, commonly referred to as "inter-cable shorting." Inter-cable shorting is less likely than intra-cabie shorting.

Consistent with the current knowledge of fire-induced cable failures, the following configurations should be considered:

A. For any individual multiconductor cable (thermoset or thermoplastic), any and all potential spurious actuations that may result from intra-cable shorting, including any possible combination of conductors within the cable, may be postulated to occur concurrently regardless of number. However, as a practical matter, the number of combinations of potential hot shorts increases rapidly with the number of conductors within a given cable. For example, a multiconductor cable with three conductors (3C) has 3 possible combinations of two (including desired combinations), while a five conductor cable (5C) has 10 possible combinations of two (including desired combinations), and a seven conductor cable (7C) has 21 possible combinations of two (including desired combinations).

To facilitate an inspection that considers most of the risk presented by postulated hot shorts within a multiconductor cable, inspectors should consider only a few (three or four) of the most critical postulated combinations.

B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration of thermoset cable inter-cable shorts is deferred pending additional research.)

C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently.

The spurious actuations should be evaluated as previously described.

The consideration of more than two cables being damaged (and subsequent spurious actuations) is deferred pending additional research.D. For cases involving direct current (DC) circuits, the potential spurious operation due to failures of the associated control cables (even if the spurious operation requires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus and minus-to-minus) should be considered when the required source and target conductors are each located within the same multiconductor cable.E. Instrumentation Circuits.

Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits.

There is one case where an instrument circuit could potentially be considered an associated circuit. If fire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly.

Applicability Comments Applicable Alignment Statement Aligqnment Basis Comments Unit Reference Document Doc, Details Oconee Page 76 of 112 10/30/2008 ONS -LAR No 2008-01 Supplement.mdb Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Aligns with Intent A. Three types of circuit failures (intra-cable hot shorts, open circuits and shorts-to-ground) were considered to occur on each conductor of each safe shutdown cable associated with a component of the required safe shutdown path in each given fire area. If a complete circuit failure analysis was not performed, a conservative worst-case failure was assumed with respect to the required SSD component/system.

B. Oconee has thermoplastic covering over its armored sheathing, but the conductor insulation is thermoset.

Inter-cable hot shorts are not postulated.

C. No limit is placed on the number of cables damaged by the fire, however multiple spurious operation is being resolved generically by the Industry via the FAQ process for NEI 04-02.0. DC circuit control cables are included in the analysis.

Oconee does not have cable configurations where two concurrent hot shorts of the proper polarity within the same cable could short to cause spurious operation.

Cable-to-cable hot shorts are not postulated for armor Iacketed cables.E. Instrument cables are included in the analysis and associated with pseudo components for logic circuits.Oconee aligns with this guidance except for item B. Oconee meets the intent of the item B guidance except cable-to-cable interactions were not considered because the armor jacketing of the cables preclude hot short interactions.

Open Item Description Due to ongoing industry issues related to this topic, an open item is created to track resolution of Multiple Spurious Operations per FAQ 07-0038.EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.1, 3.2, 3.4, 8.2, and 8.4.16 Open Item ID 3.5.1.5.n Oconee Disposition Open/Closed Date Entered 4/7/2008 See treatment in Section 4.8.2.1 of Transition Open Report.Open pending LAR approval.Page 77 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Corrective Action Reference PIP 0-8-02444 Include in LARTTR Yes Change Eval / Modification Reference Oconee Page 78 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment-Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2 Types of Circuit Failures NEI 00-01 Guidance Appendix R requires that nuclear power plants must be designed to prevent exposure fires from defeating the ability to achieve and maintain post-fire safe shutdown.

Fire damage to circuits that provide control and power to equipment on the required safe shutdown path and any other equipment whose spurious operation/mal-operation could affect shutdown In each fire area must be evaluated for the effects of a fire in that fire area. Only one fire at a time is assumed to occur. The extent of fire damage is assumed to be limited by the boundaries of the fire area. Given this set of conditions, it must be assured that one redundant train of equipment capable of achieving hot shutdown is free of fire damage for fires in every plant location.

To provide this assurance, Appendix R requires that equipment and circuits required for safe shutdown be free of fire damage and that these circuits be designed for the fire-induced effects of a hot short, short-to-ground, and open circuit. With respect to the electrical distribution system, the issue of breaker coordination must also be addressed.

This section will discuss specific examples of each of the following types of circuit failures: o Open circuit o Short-to-ground o Hot short.Comments Applicabtlitv Applicable Alignment Statement Not Required Aliqnment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 79 of 112 10/30/2008 Transition-Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2 1 Circuit Failures Due to an Open Circuit Applicability Applicable

-Alignment Statement NEI 00-01 Guidance This section provides guidance for addressing the effects of an open circuit for safe shutdown equipment.

An open circuit is a fire-induced break in a conductor resulting in the loss of circuit continuity.

An open circuit will typically prevent the ability to control or power the affected equipment.

An open circuit can also result in a change of state for normally energized equipment.

For example, a loss of power to the main steam isolation valve (MSIV) solenoid valves [for BWRs] due to an open circuit will result in the closure of the MSIV.NOTE: The EPRI circuit failure testing indicated that open circuits are not likely to be the initial fire-induced circuit failure mode. Consideration of this may be helpful within the safe shutdown analysis.

Consider the following consequences in the safe shutdown circuit analysis when determining the effects of open circuits: Loss of electrical continuity may occur within a conductor resulting in de-energizing the circuit and causing a loss of power to, or control of, the required safe shutdown equipment.

In selected cases, a loss of electrical continuity may result in loss of power to an interlocked relay or other device. This loss of power may change the state of the equipment.

Evaluate this to determine if equipment fails safe.Open circuit on a high voltage (e.g., 4.16 kV) ammeter current transformer (CT) circuit may result in secondary damage.Figure 3.5.2-1 shows an open circuit on a grounded control circuit.[Refer to hard copy of NEI 00-01 for Figure 3.5.2-1]Open circuit No. 1: An open circuit at location No. 1 will prevent operation of the subject equipment.

Open circuit No. 2: An open circuit at location No. 2 will prevent opening/starting of the subject equipment, but will not impact the ability to close/stop the equipment.

Comments Alignment Basis Comments .Unit Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 80 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Does not Align Open circuits are analyzed as shown on the referenced figures from NEI 00-01. However, an assumption is made about the secondary windings of CT's and open circuits based on EPRI data causing a fire as being of sufficiently low probability as to not be a credible event. In addition, CT's are designed to maintain integrity upon a secondary open circuit and they are contained within metal-clad switchgear which should contain any damage should there be an energetic failure. This is an open item to be considered within the scope of the Circuit Coordination Study update.Because of an assumption concerning not postulating an open circuit on a high voltage CT circuit, Oconee does not aligns with the guidance.Open Item Description The circuit coordination analysis for Oconee needs to be updated. The assumption of circuit coordination in the safe shutdown analysis needs to be validated.

Included within the scope of the study is the need for documenting the impact of open circuits on the secondary windings of.current transformers., EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.1, 3.4 and 8.4 Open Item ID 3.5.2.1 Disposition This open item is being closed to PIP Corrective Action #1 which will track the completion of the analysis.Open/Closed Closed-Date Entered 5/15/2008 Corrective Action Reference Include in LARITR.Chanqe Eval / Modification Reference PIP 0-08-02444 No Oconee ONS -LAR No 2008-01 Supplement.mdb Page 81 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2.2 Circuit Failures Due to a Short-to-Ground

[General]Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance This section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment.

A short'to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential.

A short-to-ground can cause a loss of power to or control of required safe shutdown equipment.

In addition, a short-to-ground may affect other equipment in the electrical power distribution system in the cases where proper coordination does not exist.Consider the following consequences in the post-fire safe shutdown analysis when determining the effects of circuit failures related to shorts-to-ground:

o A short to ground in a power or a control circuit may result in tripping one or more isolation devices (i.e. breaker/fuse) and causing a loss of power to or control of required safe shutdown equipment.

o In the case of certain energized equipment such as HVAC dampers, a loss of control power may result in loss of power to an interlocked relay or other device that may cause one or more spurious operations.

Comments Alignment Basis Generic Paragraph.

Alignment discussed in subsequent sections.Comments Unit Reference Document Doc. Details Oconee Page 82 of 112 ONS -LAR No 2008-01 Supplement.mdb 10130/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 3.5.2.2 Circuit Failures Due to a Short-to-Ground

[A, Grounded Circuits]NEI 00-01 Guidance This section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment.

A short-to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential.

A short-to-ground can cause a loss of power to or control of required safe shutdown equipment.

In addition, a short-to-ground may affect other equipment in the electrical power distribution system in the cases where proper coordination does not exist.Short-to-Ground on Grounded Circuits Typically, in the case of a grounded circuit, a short-to-ground on any part of the circuit would present a concem for tripping the circuit isolation device thereby causing a loss of control power.Figure 3.5.2-2 illustrates how a short-to-ground fault may impact a grounded circuit.[Refer to hard copy of NEI 00-01 Rev. 1 for Figure 3.5.2-2]Short-to-ground No. 1: A short-to-ground at location No. I will result in the control power fuse blowing and a loss of power to the control circuit. This will result an inability to operate the equipment using the control switch. Depending on the coordination characteristics between the protective device on this circuit and upstream circuits, the power supply to other circuits could be affected.Short-to-ground No. 2: A short-to-ground at location No. 2 will have no effect on the circuit until the close/stop control switch is closed. Should this occur, the effect would be identical to that for the short-to-ground at location No. 1 described above. Should the open/start control switch be closed prior to closing the close/stop control switch, the equipment will still be able to be opened/started.

Comments Applicability Applicable Alignment Statement Aligns Oconee Aliqnment Basis Certain cables were excluded if all postulated fire induced faults (open circuit, hot-short or short to ground) have no adverse consequences for the component.

Fire Area analysis methodology assumes multiple fire induced failures.

The analysis technique for Short-to-Ground for grounded circuits as shown in the referenced NEI 00-01 figures were utilized.Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Section 3.4 Page 83 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFPR nsition B-2 Table Rev. 1 Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2.2 Circuit Failures Due to a Short-to-Ground (B, Ungrounded Circuits]NEI 00-01 Guidance Short-to-Ground on Ungrounded Circuits In the case of an ungrounded circuit, postulating only a single short-to-ground on any part of the circuit may not result in tripping the circuit isolation device. Another short-to-ground on the circuit or another circuit from the same source would need to exist to cause a loss of control power to the circuit.Figure 3.5.2-3 illustrates how a short to ground fault may impact an ungrounded circuit.[Refer to hard copy of NEI 00-01 Rev. 1 for Figure 3.5.2-3]Short-to-ground No. 1: A short-to-ground at location No. 1 will result in the control power fuse blowing and a loss of power to the control circuit if short-to-ground No.3 also exists either within the same circuit or on any other circuit fed from the same power source. This will result in an inability to operate the equipment using the control switch. Depending on the coordination characteristics between the protective device on this circuit and upstream circuits, the power supply to other circuits could be affected.Short-to-ground No. 2: A short-to-ground at location No. 2 will have no effect on the circuit until the close/stop control switch is closed. Should this occur, the effect would be identical to that for the short-to-ground at location No. 1 described above. Should the open/start control switch be closed prior to closing the close/stop control switch, the equipment will still be able to be opened/started.

Comment.s Applicabilit Applicable Alignment Statement Aligns Alignment Basis The methodology assumes multiple fire induced failures including hot-shorts, shorts-to ground and open circuits, All postulated cable and component failures were identified utilizing the techniques of the referenced NEI 00-01 figures for ungrounded circuits.Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.4 and 8.2 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 84 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2.3 Circuit Failures Due to a Hot Short [General]NEI 00-01 Guidance This section provides guidance for analyzing the effects of a hot short on circuits for required safe shutdown equipment.

A hot short is defined as a fire-induced insulation breakdown between conductors of the same cable, a different cable or some other external source resulting in an undesired impressed voltage on a specific conductor.

The potential effect of the undesired impressed voltage would be to cause equipment to operate or fail to operate in an undesired manner.Consider the following specific circuit failures related to hot shorts as part of the post-fire safe shutdown analysis: o A hot short between an energized conductor and a de-energized conductor within the same cable may cause a spurious actuation of equipment.

The spuriously actuated device (e.g., relay) may be interlocked with another circuit that causes the spurious actuation of other equipment.

This type of hot short is called a conductor-to-conductor hot short or an internal hot short.0 A hot short between any external energized source such as an energized conductor from another cable (thermoplastic cables only) and a de-energized conductor may also cause a spurious actuation of equipment.

This is called a cable-to-cable hot short or an external hot short, Cable-to-cable hot shorts between thermoset cables are not postulated to occur pending additional research.Comments Applicabilit Applicable Alqgnment Statement Not Required Alignment Basis Generic Paragraph.

Alignment discussed in subsequent sections.Comments Unit Reference Document Doc. Details Page 85 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291--

NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref 3.5.2.3 Circuit Failures Due to a Hot Short [A, Grounded Circuits]NEI 00-01 Guidance A Hot Short on Grounded Circuits A short-to-ground is another failure mode for a grounded control circuit. A short-to-ground as described above would result in de-energizing the circuit. This would further reduce the likelihood for the circuit to change the state of the equipment either from a control switch or due to a hot short. Nevertheless, a hot short still needs to be considered.

Figure 3.5.2-4 shows a typical grounded control circuit that might be used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted, since these devices are not required to understand the concepts being explained in this section. In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot shorts depicted.

The following discussion describes how to address the impact of these individual cable faults on the operation of the equipment controlled by this circuit.[Refer to hard copy of NEI 00-01 Rev. 1 for Figure 3.5.2-4]Hot short No. 1: A hot short at this location would energize the close relay and-result in the undesired closure of a motor-operated valve.Hot short No. 2: A hot short at this location would energize the open relay and result in the undesired opening of a motor-operated valve.Comments Applicability Applicable Alignment Statement Aligns with Intent Alignment Basis Intra-cable conductor to conductor hot shorts are analyzed; external hot shorts are not considered credible at Oconee due to the armored cable configuration.

The methodology assumes multiple fire induced failures including hot-shorts if energized conductors are present in the cable. Postulated cable and component failures were identified utilizing the techniques of the referenced NEI 00-01 figures for grounded circuits.

Hot shorts need not be postulated if energized conductors are not present in the cable; cable-to-cable hot shorts are not postulated between armored cables.This approach meets the intent of the guidance.Comments Unit Reference Document Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Section 3.4 Oconee Page 86 of 112 ONS -LAR No 2008-01 Supplement.mdb 10130/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section; 2.4,2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref NEI 00-01 Ggidance 3.5.2.3 Circuit Failures Due to A Hot Short on Ungrounded Circuits a Hot Short [8, Ungrounded Circuits]

In the case of an ungrounded circuit, a single hot short may be sufficient to cause a spurious operation.

A single hot short can cause a spurious operation if the hot short comes from a circuit from the positive leg of the same ungrounded source as the affected circuit.In reviewing each of these cases, the common denominator is that in every case, the conductor in the circuit between the control switch and the start/stop coil must be involved.Figure 3.5.2-5 depicted below shows a typical ungrounded control circuit that might be used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted,.since these devices are not required to understand the concepts being explained in this section.In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot shorts depicted.

The discussion provided below describes how to address the impact of these cable faults on the operation of the equipment controlled by this circuit,[Refer to hard copy of NEI 00-01 Rev. 1 for Figure 3.5.2-5]Hot short No. 1: A hot short at this location from the same control power source would energize the close relay and result in the undesired closure of a motor operated valve.Hot short No. 2: A hot short at this location from the same control power source would energize the open relay and result in the undesired opening of a motor operated valve.Applicability Comments Applicable Alignment Statement Alignment Basis Comments Unit Reference Document Doc. Details Aligns with Intent Intra-cable conductor to conductor hot shorts EIR 51-5044354-003, Section 3.4 are analyzed; external hot shorts are not Oconee Appendix R Fire considered credible at Oconee due to the Safe Shutdown Analysis, armored cable configuration.

The methodology Rev. 3, 10/18/2008 assumes multiple fire induced failures including hot-shorts if energized conductors are present in the cable. Postulated cable and component failures were identified utilizing the techniques of the referenced NEI 00-01 figures for ungrounded circuits.

Hot shorts need not be postulated if energized conductors are not present in the cable; cable-to-cable hot shorts are not postulated between armored cables.This approach meets the intent of the guidance.Oconee Page 87 of 112 10/30/2008 ONS -LAR No 2008-01 Supplement.mdb Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Saiety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location.Nuclear Safety Equipment and Cable Location.

Physical location of equipment and cables shall be identified.

NEI 00-01 Ref 3.3.3.4 Identify Routing of Cables Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance Identify the routing for each cable including all raceway and cable endpoints.

Typically, this information is obtained from joining the list of safe shutdown cables with an existing cable and raceway database Comments Alignment Basis ARTRAK is a relatonal database that contains the data from the existing ONS Cable and Raceway Tracking Databases.

Cable identification Numbers. Endpoints, Drawing references and cable routing data are contained in ARTRAK and tied to safe shutdown component and fire area location data.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.1 and 3.2 ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 88 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location.NEI 00-01 Ref 3.3.3.5 Identify Location of Raceway and Cables by Fire Area Applicabillty Applicable Alignment Statement Aligns NEI 00-01 Guidance Identify the fire area location of each raceway and cable endpoint identified in the previous step and join this information with the cable routing data. In addition, identify the location of field-routed cable by fire area. This produces a database containing all of the cables requiring fire area analysis, their locations by fire area, and their raceway.Comments Alig nment Basis A listing of all required cables along with associated endpoints and raceway / junction points was obtained from ARTRAK. A copy of the applicable ONS layout drawings which depict fire zones and areas was transposed/overlaid onto the electrical equipment layout drawings.

A Cable Routing Worksheet for each cable was completed using ARTRAK and the route verified to assure it was contiguous and that all necessary fire zones were assigned to the route.Comments Unit Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 41712008 Doc. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10118/2008 Sections 3.1, 3.2 and Att. K Oconee ONS -LAR No 2008-01 Supplement.mdb Page 89 of 112 10/3012008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location.NEI 00-01 Ref 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination Applicability Applicable Alignment Statement NEI 00-01 Guidance The evaluation of associated circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown.

The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.

For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. T6 assure that there is no impact to this Train A pump due to the associated circuits'common power source breaker coordination issue, load breaker 4 mulst be fully coordinated with the feeder breaker to the Train A bus.[Refer to hard copy of NEI 00-01 Rev. 1 for Figure 3.5.2-6]A coordination study should demonstrate the coordination status for each required common power source, For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus, Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows: o Identify the power sources required to supply power to safe shutdown equipment.

o For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.o For each power source, demonstrate proper circuit coordination using acceptable industry methods.o For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse.

Evaluate the potential for disabling power to the bus in each of the fire areas In which the associated circuit cables of concem are routed and the power source is required for safe shutdown.

Prepare a list of the following information for each fire area: o Cables of concern.o Affected common power source and its path.o Raceway in which the cable is enclosed.o Sequence of the raceway in the cable route.o Fire zone/area in which the raceway is located.For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods.Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source. Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.Comments Aliqnment Basis Comments Unit Reference Document DOC. Details Oconee Page 90 of 112 ONS -LAR No 2008-01 Supplement.mdb 1013012008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location.Does not Align Proper coordination of common power supplies for all circuits was an assumption of the analysis.

Oconee's existing coordination study does not include all SSEL related power supplies.

The coordination study needs to be updated with the additional power supplies to ensure that the assumptions of the EIR remain valid.Open Item Description EfR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 1011812008 Sections 3.4 and 8.2 Open Item ID 3.5.2.4 Disposition Open/Closed Closed Date Entered 5/5/2008 The circuit coordination analysis for Oconee needs to be This open item is being closed to PIP updated. The assumption of circuit coordination in the Corrective Action #1 which will track the safe shutdown analysis needs to be validated.

completion of the analysis.Corrective Action Reference Include in LAR/TR Change Eval I Modification Reference PIP No Oconee ONS -LAR No 2008-01 Supplement.mdb Page 91of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4,2.3 Nuclear Safety Equipment and Cable Location.NEI 00-01 Ref 3.5.2.5 Circuit Failures Due to Common Enclosure Concerns NEI 00-01 Guidance The common enclosure associated circuit concern deals with the possibility of causing secondary failures due to fire damage to a circuit either whose isolationr device fails to isolate the cable fault or protect the faulted cable from reaching its ignition temperature, or the fire somehow propagates along the cable into adjoining fire areas, The electrical circuit design for most plants provides proper circuit protection in the form of circuit breakers, fuses and other devices that are designed to isolate cable faults before ignition temperature is reached. Adequate electrical circuit protection and cable sizing are included as part of the original plant electrical design maintained as part of the design change process. Proper protection can be verified by review of as-built drawings and change documentation.

Review the fire rated barrier and penetration designs that preclude the propagation of fire from one fire area to the next to demonstrate that adequate measures are in place to alleviate fire propagation concerns.Comments Applicabilit, Applicable Alignment Statement Does not Align Aliqnment Basis The electrical circuit design for Oconee-is assumed to provide proper circuit protection in the form of circuit breakers, fuses and other devices that are designed to isolate cable faults before ignition temperature is reached.Adequate electrical circuit protection and cable sizing were included as part of Oconee's plant electrical design. However, the breaker coordination study for Oconee does not include all safe shutdown equipment and the analysis is required to be updated to ensure coordination exists. Should any coordination issues be identified, they will be resolved using the correctiveaction process. Oconee's fire barrier and penetration designs preclude the propagation of fire from one fire area to the next. Due to the uncertainty of breaker coordination, Oconee does not meet the intent of the guidance.Comments Unit Reference Document EIR 51-5044354.003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 8.2 and 8.4 DC-3.12, Cable Ampacity Design Criteria, Rev. 2, 8[1612001 Open/Closed Closed Open item 10 3.5.2.5 Oconee Open Item Description Breaker coordination calculations have not been performed for all safe shutdown power supplies and the effects of inadequate breaker coordination on circuits in common enclosures has not been considered.

Disposition This open item is being closed to PIP Corrective Action #1 which will track the completion of the analysis.Date Entered 5/23/2008 Page 92 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location.Corrective Action Reference PIP 0-08-02444 Include in LAR/TR No Changie Eval I Modification Reference Oconee ONS -LAR No 2005-01 Supplement.mdb Page 93 of 112 10/30/2008 Transition Too] Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4,2.4 Fire Area Assessment.

Fire Area Assessment.

An engineering analysis shall be performed in accordance with the requirements of Section 2.3 for each fire area to determine the effects of fire or fire suppression activities on the ability to achieve the nuclear safety performance criteria of Section 1.5. (See Chapter 4 for methods of achieving these performance criteria (performance-based or deterministic).

NEI 00-01 Ref 3.4 Fire Area Assessment and Compliance Assessment NEI 00-01 Guidance By determining the location of each component and cable by fire area and using the cable to equipment relationships described above, the affected safe shutdown equipment in each fire area can be determined.

Using the list of affected equipment in each fire area, the impacts to safe shutdown systems, paths and functions can be determined.

Based on an assessment of the number and types of these impacts, the required safe shutdown path for each fire area can be determined.

The specific impacts to the selected safe shutdown path can be evaluated using the circuit analysis and evaluation criteria contained in Section 3.5 of this document.Having identified all impacts to the required safe shutdown path in a particular fire area, this section provides guidance on the techniques available for individually mitigating the effects of each of the potential impacts.Comments Applicabilit Applicable Alignment Statement Alignment Bast Comments Unit Reference Document Doc. Details Not Required Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Oconee ONS -LAR No 2008-01 Supplement.mdb Page 94 of 112.10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1 Criteria / Assumptions Applicabilit Applicable Alignment Statement Not Required NEI 00-01 Guidance The following criteria and assumptions apply when performing fire area compliance assessment to mitigate the consequences of the circuit failures identified in the previous sections for the required safe shutdown path in each fire area.Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Oconee Page 95 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref NEI 00-01 Guidance 3.4.1.1 [Number of Postulated Assume only one fire in any single fire area at a time.Fires]Apolicability Comments Applicable Alignment Statement Alignment Basis Co Aligns Only one fire in a single fire area is assumed to occur.omments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10118/2008 Doc. Details Section 8.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 96 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFPA asition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.2 [Damage to Unprotected Equipment and Cables]Applicabili Applicable Alignment Statement Aligns NEI 00-01 Guidance Assume that the fire may affect all unprotected cables and equipment within the fire area. This assumes that neither the fire size nor the fire intensity is known, This is conservative and bounds the exposure fire that is required by the regulation.

Comments Alignment Basis All equipment and cabling within a given fire area are assumed damaged by the fire.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.4 and 8.4 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 97 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. 1 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.3 [Assess Impacts to Required Components]

Applicability Applicable Alignment Statement Aligns Oconee NEI 00-01 Guidance Address all cable and equipment impacts affecting the required safe shutdown path in the fire area, All potential impacts within the fire area must be addressed.

The focus of this section is to determine and assess the potential impacts to the required safe shutdown path selected for achieving post-fire safe shutdown and to assure that the required safe shutdown path for a given fire area is properly protected.

Comments Alignment Basis The fire area analysis methodology assumes multiple fire induced failures and multiple spurious actuations based on the cables and components present in the fire area of concern. All postulated cable and component failures were identified and only those cables causing non-cofnpliance were analyzed for circuit failure results. The credited safe -shutdown success path was analyzed so that mitigating strategies could be developed and documented in the fire area compliance assessment.

Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc, Details Sections 3.4, 8.4 and Att. K Page 98 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP, isition B-2 Table Rev. I Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.4 [Manual Actions]Applicability Applicable Alignment Statement Does not Align NEI 00-01 Guidance Use manual actions where appropriate to achieve and maintain post-fire safe shutdown conditions inaccordance with NRC requirements.

Comments Alignment Basis Comments Unit The credited safe shutdown success path was analyzed and mitigating strategies (manual actions, repair actions or modifications) were developed and documented in the fire area compliance assessment.

One of the mitigating strategies is manual actions to mitigate the operational effects from fire damage. The NRC has stated the use of hot standby manual actions in a deterministic analysis are not allowed. Open items were written to evaluate the use of hot standby manual actions.Certain manual actions, such as cold shutdown actions, are already accepted by the NRC as allowed or approved and have been utilized by Oconee as a mitigating strategy, Because the use of hot standby manual actions do not meet NRC requirements; Oconee does not align with the guidance.Open Item Description Due to ongoing industry issues related to this topic, an open item is created to track resolution of Operator Manual Actions per FAQ 06-0012 and FAQ 07-0030.Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/1812008 Doc. Details Section 3.4 and Attachment L Open Item ID 3.4.1.4 Disposition Open/Closed Date Entered 4/7/2008 See treatment in Section 4.8.2.2 of Transition Open Report. This item will remain open pending approval of the LAR.Corrective Action Reference Include in LAR/TR Change Eval / Modification Reference PIP 0-08-02444 Yes Oconee ONS -LAR No 2008-01 Supplement:mdb Page 99 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.5 (Repairs]Applicability Applicable Alignment Statement Aligns NEI 00-01 Guidance Where appropriate to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, use repairs to equipment required in support of post fire shutdown.Comments Alignment Basis The credited safe shutdown success path was analyzed and mitigating strategies (procedural actions, repair actions or modifications) were developed and documented in the fire area compliance assessment.

One of the mitigating strategies for cold shutdown is to perform a repair action to restore required equipment.

ONS has procedures in place and has demonstrated the ability to perform the repairs and get to cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, Comments Unit Reference Document EIR 51-5044354-003, Ocoi~ee Appendix R Fire Safe Shutdown Analysis, Rev. 3,10/18/2008 Doc. Details Sections 3.4 and Attachment L Oconee ONS -LAR No 2008-01 Supplement.mdb Page 100 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.6 [Assess Compliance with Deterministic Criteria]Applicability Applicable Alignment Statement Aligns with Intent NEI 00.01 Guidance Appendix R compliance requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage (lll.G.l.a).

When cables or equipment, including associated circuits, are within the same fire area outside primary containment and separation does not already exist, provide one of the following means of separation for the required safe shutdown path(s): o Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area by a fire barrier having a 3-hour rating (lll.G.2.a) o Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area 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 (llI.G2.b).

o Enclosure of cable and equipment and associated non-safety circuits of one redundant train within a fire area in a fire barrier having a one-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (lll.G.2,c).

For fire areas inside noninerted containments, the following additional options are also available:

o Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards (Ill.G.2.d);

o Installation of fire detectors and an automatic fire suppression system in the fire area (lIl.G.2.e);

or o Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield (IIl.G.2.f).

Use exemptions, deviations and licensing change processes to satisfy the requirements mentioned above and to demonstrate equivalency depending upon the plant's license requirements.

Comments Alicnment Basis The credited safe shutdown success path was analyzed and mitigating strategies (procedural actions, repair actions or modifications) were developed and documented in the fire area compliance assessment.

Appendix R section III.G.1 or II.G.2 (or provide 20 feet separation or greater and suppression and detection to comply with Appendix R section 111.G.2.b) was used in the Oconee determination in selecting shutdown strategies.

Cables in the reactor buildings associated with PZR level on Unit 1 do not meet the requirements of III.G.2. Based on an acceptable justification, an exemption to Ill.G.2 was granted by the NRC for the reactor buildings.

Crediting the exemption, Oconee meets the intent of the guidance, Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.4, 11 and Attachments J and K Oconee ONS -LAR No 2008-01 Supplement.mdb Page 101 of 112 10/30/2008 Transition Tool Version 1.0,6 OSC-9291 -NFP nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.7 [Consider Additional Equipment]

Applicability Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Consider selecting other equipment that can perform the same safe shutdown function as the impacted equipment.

In addressing this situation, each equipment impact, including spurious operations, is to be addressed in accordance with regulatory requirements and the NPP's current licensing basis.Comments Alignment Basis The analysis initially identified all equipment which could perform a safe shutdown function.The credited safe shutdown success path was chosen from this equipment based on impacted equipment in an area; if necessary mitigating strategies for recovering components were provided.

This methodology took into account other equipment that may be available to fulfill safe shutdown functions because all potential safe shutdown equipment and cabling is identified before fire impacts are assessed.

Choosing the 'success path' from all analyzed equipment (instead of from a single chosen 'path' of equipment) meets the intent of the guidance.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Sections 3.4 and 11 Att.B, C, &G Oconee ONS -LAR No 2008-01 Supplement.mdb Page 102 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP, nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.1.8 [Consider Instrument Tubing Effects]NEI 00-01 Guidance Consider the effects of the fire on the density of the fluid in instrument tubing and any subsequent effects on instrument readings or signals associated with the protected safe shutdown path in evaluating post-fire safe shutdown capability.

This can be done systematically or via procedures such as Emergency Operating Procedures.

Comments Applicability Applicable Alignment Statement Aligns Oconee Aliqnment Basis*An evaluation of instrument tubing has been performed for Oconee. The evaluation treated the tubing like cabling and associated it with the instrument.

The underlying assumption being that the fire impact to an instrument's reading would be adverse and an alternate instrument would be required to fulfill the safe shutdown function.Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Section 3.3 and Attachment 0 Page 103 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEl 00-01 Ref 3.4.2 Methodology for Fire Area Assessment Applicability Applicable Alignment Statement Not Required NEI 00-01 Guidance Refer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.

Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:

[Refer to hard copy of NEI 00-01 for Figure 3-5]Comments Alignment Basis Generic paragraph.

Detailed alignment discussed in subsequent reference paragraphs.

Comments Unit Reference Document Doc. Details Page 104 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.2.1 Identify the Affected Equipment by Fire Area Applicabili Applicable Alignment Statement Aligns NEI 00-01 Guidance Identify the safe shutdown cables, equipment and systems located in each fire area that may be potentially damaged by the fire. Provide this information in a report format. The report may be sorted by fire area and by system in order to understand the impact to each safe shutdown path within each fire area (see Attachment 5 for an example of an Affected Equipment Report).Comments Alignment Basis The ARTFkAK database provides a listing of the safe shutdown equipment and cables by fire area.Comments Unit Reference Document ARTRAK, Oconee Appendix R Analysis Database Management System, Rev.1.0, 4/7/2008 EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Attachments B, G & J Page 105 of 112 Oconee ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Toot Version 1.0.6 OSC-9291 -NFP. .nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.2.2 Determine the Shutdown Paths Least Impacted By a Fire in Each Fire Area NEt 00-01 Guidance Based on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are either unaffected or least impacted by a postulated fire within the fire area. Typically, the safe shutdown path with the least number of cables and equipment in the fire area would be selected as the required safe shutdown path. Consider the circuit failure criteria and the possible mitigating strategies, however, in selecting the required safe shutdown path in a particular fire area. Review support systems as a part of this assessment since their availability will be important to the ability to achieve and maintain safe shutdown.

For example, impacts to the electric power distribution system for a particular safe shutdown path could present a major impediment to using a particular path for safe shutdown.

By identifying this early in the assessment process, an unnecessary amount of time is not spent assessing impacts to the frontline systems that will require this power to support their operation.

Based on an assessment as described above, designate the required safe shutdown path(s) for the fire area. Identify all equipment not in the safe shutdown path whose spurious operation or mal-operation could affect the shutdown function.

Include these cables in the shutdown function list. For each of the safe shutdown cables (located in the fire area) that are part of the required safe shutdown path in the fire area, perform an evaluation to determine the impact of a fire-induced cable failure on the corresponding safe shutdown equipment and, ultimately, on the required safe shutdown path.When evaluating the safe shutdown mode for a particular piece of equipment, it is important to consider the equipment's position for the specific safe shutdown scenario for the full duration of the shutdown scenario.

It is possible for a piece of equipment to be in two different states depending on the shutdown scenario or the stage of shutdown within a particular shutdown scenario.

Document information related to the normal and shutdown positions of equipment on the safe shutdown equipment list.Comments Applicability Applicable Alignment Statement Aligns Alignment Basis The credited safe shutdown success path was analyzed and mitigating strategies (procedural actions, repair actions or modifications) were identified and documented in the fire area compliance assessment.

Safe shutdown logic diagrams were then highlighted to show the credited safe shutdown paths for a given fire area which credits certain mitigating strategies.

The Safe Shutdown Equipment List documents both hot and cold shutdown positions and mitigating strategies for each mode. Potential spurious impact of non-credited equipment was evaluated by their inclusion in the fire area compliance analysis.Comments uitnl Reference Document Dce. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Sections 3.4, 8.2, 8.3, 8.4 and 11 Oconee ONS -LAR No 2008-01 Supplement.mdb Page 106 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP. nsition B-2 Table Rev. I Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.2.3 Determine Safe Shutdown Equipment Impacts Applicability Applicable Alignment Statement Aligns with Intent NEI 00-01 Guidance Using the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment that can Impact safe shutdown and that can potentially be impacted by a fire in the fire area, and what those possible impacts are.Comments Alignment Basis Comments Unit The Safe Shutdown Equipment List (SSEL)and logics were developed based on potential spurious operations and other plant impacts by'their selection from a functional basis. The fire area analysis methodology assumes multiple fire induced failures and multiple spurious actuations, based on the safe shutdown cables and components present in the fire area of concern. All postulated safe shutdown cable and component failures were identified and a resolution provided at the cable or component level. However it is not possible to evaluate all the possible combinations of multiple spurious actions that could occur as a result of the fire and the overall affect of these combinations on safe shutdown.

Oconee meets the intent of the guidance as presently understood by the industry.Open Item Description Due to ongoing industry issues related to this topic, an open item is created to track resolution of Multiple Spurious Operations per FAQ 07-0038.Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Doc. Details Attachments J, K, and 0 Open Item ID 3.4.2.3 -MSO Disposition Open/Closed Date Entered 4/8/2008 See treatment in Section 4.8.2.1 of Transition Open Report. This item will remain open pending approval of the LAR.Corrective Action Reference Include in LARJTR Chance Eval I Modification Reference Open Item ID 3.4.2.3 -OMA PIP 0-08-02444 Yes Open Item Description Due to ongoing industry issues related to this topic, an open item is created to track resolution of Operator Manual Actions per FAQ 06-0012 and FAQ 07-0030, Disposition Open/Closed Date Entered 4/8/2008 See treatment in Section 4.8.2.2 of Transition Open Report. This item will remain open pending approval of the LAR.Oconee ONS -LAR No 2008-01 Supplement.mdb Page 107 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

Corrective Action Reference PIP 0-08-02444 Include in LAR/TR Yes Change Eval I Modification Reference Oconee Page 108 of 112 ONS -LAR No 2008-01 Supplement.mdb 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear SaTety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.2,4 Develop a Compliance Strategy or Disposition to Mitigate the Effects Due to Fire Damage to Each Required Component or Cable Applicability Applicable Alignment Statement NEI 00-01 Guidance The available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Figure 1-2): o Provide a qualified 3-fire rated barrier.o Provide a 1-hour fire rated barrier with automatic suppression and detection.

o Provide separation of 20 feet or greater with automatic suppression and detection and demonstrate that there are no intervening combustibles within the 20 foot separation distance.o Reroute or relocate the circuit/equipment, or perform other modifications to resolve vulnerability.

o Provide a procedural action in accordance with regulatory requirements.

o Perform a cold shutdown repair in accordance with regulatory requirements.

o Identify other equipment not affected by the fire capable of performing the same safe shutdown function.o Develop exemptions, deviations, Generic Letter 86-10 evaluation or fire protection design change evaluations with a licensing change process.Additional options are available for non-inerted containments as described in 10 CFR 50 Appendix R section lilG.2.d, e and f.Comments Allanment Basis Comments Uni. t Reference Document Doc. Details Oconee ONS -LAR No 2008-01 Supplement.mdb Page 109 of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Satety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire A Does not AlignAssessment.

The credited safe shutdown success path was analyzed so that mitigating strategies (procedural actions, repair actions or modifications) could be developed and documented in the lire area compliance assessment.

These potential impacts were resolved by specifying one of the following:

o A procedural action to mitigate the effects of fire damage.o A repair action to restore required equipment o An electrical raceway fire barrier for affected cables o Re-routing cables to comply with Section Ill.G.1 of Appendix R o Sub-divide fire areas and/or upgrade fire area barriers to comply with section llI.G.1 or III.G.2 of Appendix R o 20 feet separation or greater and suppression and detection to comply with section III.G.2.b of Appendix R o Approved Exemption or Deviation.

Most of these strategies were invoked during the analysis, however plant modifications were not performed to provide the features specified.

Credit for existing features was taken wherever possible and procedural (manual) action specified as a last resort. The manual actions used for hot standby are not allowed by current regulations for a deterministic analysis.

Thus their use to mitigate the effects of circuit failures does not align with the guidance.Open Item Description The use of manual action for HSB does not meet regulatory requirements for a deterministic analysis.Open Item I1 3.4.2.4 Disposition Open/Closed Date Entered 5123/2008 Seetreatment in Section 4.8.2.2 of Transition Open Report. This item will remain open pending approval of the LAR.Corrective Action Reference Include in LARITR Change Eval / Modification Reference PIP 0-08-02444 Yes Oconee ONS -LAR No 2008-01 Supplement.mdb Page 110.of 112 10/30/2008 Transition Tool Version 1.0.6 OSC-9291 -NFP nsition B-2 Table Rev. 1 Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.4.2.5 Document the Compliance Strategy or Disposition Determined to Mitigate the Effects Due to Fire Damage to Each Required Component or Cable Appllcability Applicable Alignment Statement Aligns Oconee NEI 00-01 Guidance Assign compliance strategy statements or codes to components.or cables to identify the justification or mitigating actions proposed for achieving safe shutdown.The justification should address the cumulative effect of the actions relied upon by the licensee to mitigate a fire in the area. Provide each piece of safe shutdown equipment, equipment not in the path whose spurious operation or mal-operation could affect safe shutdown, and/or cable for the required safe shutdown path with a specific compliance strategy or disposition, Refer to Attachment 6 for an example of a Fire Area Assessment Report documenting each cable disposition.

Comments Alignment Basis Compliance assessment dispositions codes and their descriptions (i.e., resolution of component hits) were modeled into the ARTRAK database.

Components which were only affected by a power supply loss were dispositioned only if the component was in the credited success path and if the component failed in an undesired position for safe shutdown.

The cumulative effect of the actions relied upon to mitigate the effects of a fire in the area have been evaluated.

Comments Unit Reference Document Doe. Details EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis.Rev. 3, 10118/2008 Sections 3.4 13 and Attachments L and M Page 111 of 112 10/30/2008 Transition Tool Version 1.0.6 ONS -LAR No 2008-01 Supplement.mdb OSC-9291 -NFP :nsition B-2 Table Rev. I Table B-2 Nuclear Sarety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment.

NEI 00-01 Ref 3.5.1.5 [C, Likelihood of Undesired Consequences]

Applicability Applicable Alignment Statement Does not Align NEI 00-01 Guidance Determination of the potential consequence of the damaged associated circuits is based on the examination of specific NPP piping and instrumentation diagrams (P&IDs) and review of components that could prevent operation or cause maloperation such as flow diversions, loss of coolant, or other scenarios that could significantly impair the NPP's ability to achieve and maintain hot shutdown.

When considering the potential consequence of such failures, the [analyst]

should also consider the time at which the prevented operation or maloperation occurs. Failures that impede hot shutdown within the first hour of the fire tend to be most risk significant in a first-order evaluation.

Consideration of cold-shutdown circuits is deferred pending additional research.Comments Alignment Basis Treatment of multiple spurious actuations has not been previously addressed and is being resolved through transition to NFPA-805 and resolution of FAQ 07-0038.Open Item Description Comments Unit Reference Document EIR 51-5044354-003, Oconee Appendix R Fire Safe Shutdown Analysis, Rev. 3, 10/18/2008 Open/Closed Open Doc. Details Sections 3.1, 3.2 , 3.4 and 8.2 Open Item ID 3.5.1.5 Resolution of MSO's is being addressed on an Industry basis through FAQ 07-0038 and transition to NFPA-805 Disposition See treatment in Section 4.8.2.1 of Transition Report. This item will remain open pending approval of the LAR.Date Entered 4/7/2008 Corrective Action Reference Include In LAR/TR Change Eval i/ Modification Reference PIP 0-08-02444 Yes Oconee ONS -LAR No 2008-0! Supplement.mdb Page 112 of 112 10/3012008 Transition Tool Version 1.0.6 Calculation No.: Applicable Units: OSC-9291 Oconee Unit 1, 2. & 3 Revision No.: 0 Attachment 2 Attachment 2 Extracted pages from NEI 00-01 for Figures referenced in Table B-2 12 total pages OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Figure 1-2 Deterministic Post-fire Safe Shutdown Overview Functions: (a) SSD Functions: " Reactivity Control;" Pressure Control;" Inventory Control;" DecayHeat Removal;* Process Monitoring;" Support Functions (b) Spurious Operations:

• RPV Inventory Loss;" Flow Blockage/Diversion" (Inventory Control; DHR)Identified Associated Circuit from Common Power Source &Common Enclosure 0 S U Mitigation Techniques Reroute Circuit Wrap Raceway Manual Action/Repair (repair allowed for cold shutdown only)Other Equipment Other Plant Unique Approach Exemption Deviation GL 86-10 Fire Hazards Evaluation Fire Protection Design Change Evaluation 1 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Figure 3-1 Deterministic Guidance Methodology Overview~1*1 Section 2.0 Establish Appendix R Regulatory Requirements Regulatory Guidance on Associated Circuits Regulatory Interpretation on Loss of Offsite Power Section 3.3 Select Safe Shutdown Cables Identify cables required for operation or that can cause maloperation of listed equipment Including improperly coordinated power circuits.Associate cables to equipment Locate cable raceway & endpoints by fire area Join data & identify SSD cables & equipment by fire area Section 3.1 Determine SSD Functions, Systems & Paths Reactivity Control, Pressure Control, Inventory Control, DHR, Process Monitoring, Supporting Functions Section 3.4 Fire Area Assessment Include those that can defeat SSD" RPV/RCS Loss of Inventory

(*)" Flow Diversion

(*)/Blockage" Inventory Makeup System being used for SSD in FA" Decay Heat Removal being used for SSD in FA .* In excess of required makeup Section 3.2 Determine impact to equipment required for SSD functions and establish SSD path for each fire area.Evaluate effects of a hot short, open circuit, &short to ground on each conductor for each cable.Refer to Section 3.5 for Circuit Analysis Criteria.Develop Methods for Mitigation

1. Reroute Cable of Concern 2. Protect Cable of Concern 3. Perform Manual Action 4. Perform Repair for Cold Shutdown only 5. Develop Exemption 6. Develop Deviation 7. Perform GL 86-10 Fire Hazards Evaluation

8. Enter Fire Protection Change Process 9. Identify other equipment to perform same function Items 3 & 4 involve addressing requirements for timing, emergency lighting, manpower, communications and dedicated repair equipment.

These mitigation methods must agree with NRC positions on manual actions.Select Safe Shutdown Equipment Equipment that may perform or defeat SSD functions I 2 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Figure 3-2 Safe Shutdown System Selection and Path Development Define Appendix R requirements.

Refer to Figure 2-1 Step 2 Identify safe shutdown functions.

I Step 3 Identify combinations of systems that satisfy each safe shutdown function.* Additionai

/support systems Lbased on Step4 of Fig. 3-3 Step 4 Define combination of systems for each shutdown path.Step 5 Assign shutdown path to each combination of systems.Refer to Attachment 1 for an example of a Safe 0 Shutdown Path Development List.3 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision I January 2005 Figure 3-3 Safe Shutdown Equipment Selection Step 2 Identify-the system flow pa for each shutdown path.Refer to Attachment 2 fo an example of an annotated P&ID.Step 3 Identify combinations of equipment that satisfy eac Yes safe shutdown function.Step 5 Develop a list of safe shutdov equipment and assign the corresponding.system and shutdown pat(s).Refer to Attachment 3 for an example of a Safe Shutdown Equipment List Step 6 Identify equipment information related to the safe shutdown analysis.Step 7 Identify dependencies etween equipment, support equipment, systems and paths.Refer to Attachment 4 for an example of a Safe Shutdown Logic Diagram 4 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision-1 January 2005 Figure 3-4 Safe Shutdown Cable Selection Step I Define safe shutdown equipment Refer to Figure 3-3 Step 2 Identify circuits (power, control, instrumentation) required for the operation of each safe shutdown equipment.

(*)i Step 3 Identify equipment whose spurious operation or mal-operation could affect safe shutdown I Step 4 Identify interlocked circuits and cables whose failure may cause spurious actuations.

(*)Yes 14" Step 7 Assign cables to equipment.

Step 8 Identify routing of cables.Identify location of cables by fire area.Step 6 Identify closest upstream power supply and verify that it is on the safe shutdown list.Refer to Step 5 in Fig. 3-3.(*) For electrical distribution equipment including power supplies, identify circuits whose failure may cause a coordination concern for the bus under evaluation.

5 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Figure 3-5 Fire Area Assessment Flowchart C ldentify and locate safe shutdown cables by fire area)I Step 2 Determine the cables and equipment affected in the fire area.I for an example of anRefer to Attachment 5 Affected Equipment Report by fire area.I Step 3 Determine the shutdown path least impacted by the fire in each fire area and designate it as the Required Safe Shutdown Path.Step 4 Determine the equipment impacts to the Required Safe Shutdown Path using the circuit failure criteria in Section 3.5.4 Step 5 Develop a compliance strategy or disposition to mitigate the effects due to fire damage to each required equipment or cable.Step 6.Document the compliance strategy or disposition determined to mitigate the effects of the potential fire damage to each equipment or cable of the required safe shutdown path.Provide a qualified 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier.Provide a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier with automatic suppression and detection.

Provide >20 ft separation with auto suppression

&detection

& no intervening combustibles.

Reroute or relocate the circuit/equipment.

Provide a procedural action.*Perform a repair for cold shutdown only.Identify other equipment capable of performing the.same shutdown function.Develop an exemption.

Develop a deviation.

Develop a GL 86-10 Fire Hazards Evaluation.*

Develop a fire protection change process.*Refer to Attachment 6 for an example of a Fire Area Assessment Report 1*Seek regulatory approval where necessary 6 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Figure 3.5.2-1 shows an open circuit on a grounded control circuit.Figure 3.5.2-1 Open Circuit (Grounded Control Circuit)'5 0 C 0 (~2~0'5 V n 0 (9 I I Open Circuit No. I Cable K Control Switch t-Energize to Energize to Open/Start Close/Stop Grounded Circuit Open circuit No. 1: An open circuit at location No. 1 will prevent equipment.

operation of the subject Open circuit No. 2: An open circuit at location No. 2 will prevent opening/starting of the subject equipment, but will not impact the ability to close/stop the equipment.

3.5.2.2 Circuit Failures Due to a Short-to-Ground This section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment.

A short-to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential.

A short-to-ground can cause a loss of power to or control of required safe shutdown equipment.

In addition, a short-to-ground may affect other equipment in the electrical power distribution system in the cases where proper coordination does not exist.7 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Consider the following consequences in the post-fire safe shutdown analysis when determining the effects of circuit failures related to shorts-to-ground:

A short to ground in a power or a control circuit may result in tripping one or more isolation devices (i.e. breaker/fuse) and causing a loss of power to or control of required safe shutdown equipment.

In the case of certain energized equipment such as HVAC dampers, a loss of control power may result in loss of power to an interlocked relay or other device that may cause one or more spurious operations.

Short-to-Ground on Grounded Circuits Typically, in the case of a grounded circuit, a short-to-ground on any part of the circuit would present a concern for tripping the circuit isolation device thereby causing a loss of control power.Figure 3.5.2-2 illustrates how a short-to-ground fault may impact a grounded circuit.Figure 3.5.2-2 Short-to-Ground (Grounded Control Circuit)Fuse (Typ.)F T Short-to-Ground C [ control Switch~No. 1 No.1 Short-to-Ground No.'2 Energize to Energize to Open/Start Close/Stop 2 Grounded Circuit Short-to-ground No. 1: A short-to-ground at location No. 1 will result in the control power fuse blowing and a loss of power to the control circuit. This will result an inability to operate the equipment using the control switch. Depending on the coordination 8 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 characteristics between the protective device on this circuit and upstream circuits, the power supply to other circuits could be affected.Short-to-wround No. 2: A short-to-ground at location No. 2 will have no effect on the circuit until the close/stop control switch is closed. Should this *occur, the effect would be identical to that for the short-to-ground at location No. 1 described above.Should the open/start control switch be closed prior to closing the close/stop control switch, the equipment will still be able to be opened/started.

Short-to-Ground on Ungrounded Circuits In the case of an ungrounded circuit, postulating only a single short-to-ground on any part of the circuit may not result in tripping the circuit isolation device.Another short-to-ground on the circuit or another circuit from the same source would need to exist to cause a loss of control power to the circuit.Figure 3.5.2-3 illustrates how a short to ground fault may impact an ungrounded circuit.Figure 3.5.2-3 Short-to-Ground (Ungrounded Control Circuit)Fuse (Typ.)t5 Short-to-Ground Control Switch No.1 Short-to-Ground o No. 2'0"0Energize to Energize to Open/Start Close/Stop 1_ Short-to-Ground-No. 3 Short-to-ground No. 1: A short-to-ground at location No. 1 will result in the control power fuse blowing and a loss of power to the control circuit if short-to-ground No. 3 also exists either within the same circuit or on any other circuit fed from the same power 9 of. 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 short still needs to be considered.

Figure 3.5.2-4 shows a typical grounded control circuit that might be used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted, since these devices are not required to understand the concepts being explained in this section. In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot shorts depicted.

The following discussion describes how to address the impact of these individual cable faults on the operation of the, equipment controlled by this circuit.Figure 3.5.2-4 Hot Short (Grounded Control Circuit)Fuse (Typ.)I Control Switch I---0 0.p 0 II No. 2 Hot Short Energize to Open/Start Energize to Close/Stop No. 1 N 14--1 Grounded Circuit I I Hot short No. 1: A hot short at this location would energize the close relay and result in the undesired closure of a motor-operated valve.Hot short No. 2: A hot short at this location would energize the open relay and result in the undesired opening of a motor-operated valve.10 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 A Hot Short on Un2rounded Circuits In the case of an ungrounded circuit, a single hot short may be sufficient to cause a spurious operation.

A single hot short can cause a spurious operation if the hot short comes from a circuit from the positive leg of the same ungrounded source as the affected circuit.In reviewing each of these cases, the common denominator is that in every case, the conductor in the circuit between the control switch and the start/stop coil must be involved.Figure 3.5.2-5 depicted below shows a typical ungrounded control circuit that might be used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted, since these devices are not required to understand the concepts being explained in this section.In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot.shorts depicted.

The discussion provided below describes how to address the impact of these cable faults on the operation of the equipment controlled by this circuit.Figure 3.5.2-5 Hot Short (Ungrounded Control Circuit)Fuse (Typ.)Y K a.C,)(0 C=F-Control Switch Hot Short Energize to Open/Start No. 2 Energize to Close/Stop No. I m 1 4-I Hot short No. 1: A hot short at this location from the same control power source would energize the close relay and result in the undesired closure of a motor operated valve.11 of 12 OSC-9291, Rev. 0, Attachment 2 NEI 00-01 Revision 1 January 2005 Hot short No. 2: A hot short at this location from the same control power source would energize the open relay and result in the undesired opening of a motor operated valve.3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination The evaluation of associated circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown.

The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.

For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump.To assure that there is no impact to this Train A pump due to the associated circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.Figure 3.5.2-6 Common Power Source (Breaker Coordination)

Fire Area Boundary (Typical)12 of 12