Text

Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805
	ML15147A372
Person / Time
Site:	Beaver Valley
Issue date:	05/27/2015
From:	Larson E A; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-15-150
	Download: ML15147A372 (197)
	v • d • e

RrstEnergy Nuclear Operating Company Eric A. Larson Site Vice President May 27, 2015 L-15-150 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station P.O. Box 4 Shippingport, PA 15077 724-682-5234 Fax: 724-643-8069 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC Nos. MF3301 and MF3302) By letter dated December 23, 2013 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML 14002A086), as supplemented by letter dated February 14, 2014 (ADAMS Accession No. ML 14051A499), FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request to change the Beaver Valley Power Station, Unit Nos. 1 and 2 fire protection program to one based on the National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. The Nuclear Regulatory Commission (NRC) requested additional information in a letter dated March 4, 2015 to complete its review of the license amendment request (ADAMS Accession No. ML 15049A507).

In accordance with Enclosure 2 to the March 4, 2015 letter, the FENOC response due within 60 days was submitted to the NRC in a letter dated April 27, 2015 (ADAMS Accession No. ML 15118A484), and the response that is due within 90 days is attached.

The remaining responses due within 120 days will follow. The probabilistic risk assessment (PRA) model will be updated at the conclusion of these responses to answer PRA questions 3 and 19. A supplement to the license amendment request with the changes described in the responses will then be submitted.

There are no regulatory commitments included in this submittal.

If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager-Fleet Licensing, at (330) 315-6810.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-15-150 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on May J 7-, 2015. Sincerely, Eric A. Larson

Attachment:

Response to Request for Additional Information cc: Regional Administrator, NRC Region I NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative Attachment L-15-150 Page 1 Attachment L-15-150 Response to Request for Additional Information Page 1 of 195

The Nuclear Regulatory Commission (NRC) st aff provided a request for additional information (RAI) to FirstEner gy Nuclear Operating Company (FENOC) in a letter dated March 4, 2015 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML15049A507). The NRC requested information to comp lete its review of the FENOC license amendment request (LAR) for Beaver Valley Power Station (BVPS), Unit No. 1 (BVPS-1) and Unit No. 2 (BVPS-2). The LAR would change the fire protection program to one bas ed on the National Fire Protection Association NFPA Standard 805 (NFPA 805), "Perform ance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. The NRC staff's RAI

questions are provided below in bold text followed by the corresponding FENOC response.

Attachment L-15-150 Page 2

Response:

The BVPS Attachment A Table B-1 records we re sorted to identify those records that use "Complies by Previous Approval" as one of their compliance strategies; then those records were reviewed to provide the appropriate licensing citation [excerpts from NRC documents] to support the previous approval.

The results of the review are provided below. This table indicates which attributes in the LAR are included in this review, and which of the following NRC document citations are provided for each one. Following the table are the numbered explanatory paragraphs.

Additionally, the review i dentified records that needed to be corrected from "Complies

by Previous Approval" as the compliance strategy to another compliance strategy.

Those records are listed in the table bel ow with the correct compliance strategy.

Attachment L-15-150 Page 3

N/A; LAR Attachment A1 NFPA 805 Section 3.5.15, Hydrants and Hose Houses Complies by Previous Approval, Licensing Action 18 (14)

N/A; LAR Attachment A1 NFPA 805 Section 3.6.1, Standpipe and Hose Systems -

Class II versus Class III

Requirement Complies by Previous Approval, Licensing Action 29 (16)

N/A; LAR Attachment A1 NFPA 805 Section 3.8.1, Fire Detection Power Supply

System Complies by Previous Approval, Licensing Action 26 (15)

N/A; LAR Attachment A1 NFPA 805 Section 3.11.1, Building Separation Complies by Previous Approval, Licensing Action 03 (7)

N/A; LAR Attachment A1 NFPA 805 Section 3.11.4, Through Penetration Fire Stops Complies by Previous Approval, Licensing Action 03 (7) 1-CR-2 Attribute 3.11.2 - Fire Barriers Performance-based analysis, safe shutdown (SSD) RAI 06

response (1) 1-CR-2 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, SSD RAI 06 response (1) 1-CR-3 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1) 1-CR-3 Attribute 3.11.3 - Fire Barrier Penetrations Performance-based analysis,

SSD RAI 06 response (1) 1-CR-4 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1) 1-CR-4 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, SSD RAI 06 response (1) 1-CS-1 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1)

Attachment L-15-150 Page 4

1-CS-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, SSD RAI 06 response (1) 1-CV-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-CV-2 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-CV-3 Attribute 3.10.1 - Gaseous Suppression Complies by Existing

Engineering Equivalency

Evaluation (EEEE),

fire protection engineering (FPE)

RAI 01 response (5) 1-DG-1 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Appendix to June 6, 1979 Safety

Evaluation (SE) (4) 1-DG-1 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Appendix to June 6, 1979 SE (4) 1-DG-2 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Appendix to June 6, 1979 SE (4) 1-DG-2 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Appendix to June 6, 1979 SE (4) 1-ES-1 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1) 1-ES-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 1-ES-2 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1) 1-ES-2 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3)

Attachment L-15-150 Page 5

1-FB-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 1-MG-1 Attribute 3.11.2 - Fire Barriers Performance-based analysis, SSD RAI 06 response (1) 1-MG-1 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, SSD RAI 06 response (1) 1-MS-1 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-NS-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-PA-1E Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-PA-1G Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 1-PT-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 1-RC-1 Attribute 3.8.2 - Detection Complies by Previous Approval, Licensing Action 11.02 (2) and

Licensing Action 11.16 (2) 1-RC-1 Attribute 3.9.1 - Water-Based Suppression Complies by Previous Approval, Licensing Action 11.02 (2) and

Licensing Action 11.16 (2) 1-SGPD-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3)

Attachment L-15-150 Page 6

1-TB-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) and Performance-based analysis, Stairwell fire doors (17) 2-ASP Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CB-1 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-CB-1 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CB-4 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-CB-5 Attribute 3.11.2 - Fire Barriers Request for NRC approval, SSD RAI 13(c) response (6) 2-CB-5 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-CB-6 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CP-1 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-CV-1 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-CV-1 Attribute 3.11.2 - Fire Barriers Request for NRC approval, SSD RAI 13(c) response (6)

Attachment L-15-150 Page 7

2-CV-1 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CV-2 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-CV-2 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) and Complies by Previous Approval, Licensing Action 06 (10) 2-CV-3 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-CV-3 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CV-4 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-CV-5 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-CV-6 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-CV-6 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) and Complies by Previous Approval, Licensing Action 06 (10) 2-DG-1 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10)

Attachment L-15-150 Page 8

2-DG-1 Attribute 3.

11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-DG-2 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-DG-2 Attribute 3.

11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-FB-1 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6),

and Complies by Previous Approval, Licensing Action 06 (10) 2-MS-1 Attribute 3.

11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-PA-3 Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 05 (9),

Licensing Action 06 (10), and

Licensing Action 08 (11) 2-PA-3 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9),

Licensing Action 06 (10), and

Licensing Action 08 (11) 2-PA-3A Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 08 (11) 2-PA-3A Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 08 (11) 2-PA-3B Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 08 (11)

Attachment L-15-150 Page 9

2-PA-3B Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 08 (11) 2-PA-3C Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 08 (11) 2-PA-3C Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 08 (11) 2-PA-4 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9), and

Licensing Action 06 (10) 2-PA-5 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9), and

Licensing Action 06 (10) 2-PT-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8), and

Licensing Action 05 (9) 2-RC-1 Attribute 3.8.2 - Detection Complies by Previous Approval, Licensing Action 08 (11) 2-RC-1 Attribute 3.9.1 - Water-Based Suppression Complies by Previous Approval, Licensing Action 08 (11) 2-RC-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 31 (12) 2-S-1 Attribute 3.11.3 - Fire Barrier Penetrations Performance-based analysis,

Stairwell or modified fire doors

(17) 2-SB-1 Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 03 (7), and Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6)

Attachment L-15-150 Page 10

2-SB-2 Attribute 3.11.2 - Fire Barriers Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-2 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-3 Attribute 3.10.1 - Gaseous Suppression Complies by Previous Approval, Licensing Action 06 (10) 2-SB-3 Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 03 (7),and

Licensing Action 05 (9) 2-SB-3 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9), and

Licensing Action 06 (10) 2-SB-4 Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 03 (7), and

Licensing Action 05 (9) 2-SB-4 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9), and

Licensing Action 06 (10) 2-SB-5 Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 03 (7), and Licensing Action 05 (9) 2-SB-5 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8),

Licensing Action 05 (9), and

Licensing Action 06 (10) 2-SB-6 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6)

Attachment L-15-150 Page 11

2-SB-7 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-8 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-9 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6) 2-SB-10 Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-SG-1N Attribute 3.9.1 - Water-Based Suppression Complies by EEEE, FPE RAI 01 response (5) 2-SG-1N Attribute 3.11.3 - Fire Barrier Penetrations Request for NRC approval, SSD RAI 13(c) response (6) 2-SG-1S Attribute 3.9.1 - Water-Based Suppression Complies by EEEE, FPE RAI 01 response (5) 2-SG-1S Attribute 3.11.2 - Fire Barriers Complies by Previous Approval, Licensing Action 05 (9) 2-SG-1S Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 04 (8), and

Licensing Action 05 (9) 2-TR-1 Attribute 3.11.2 - Fire Barriers Performance-based evaluation

(13) 2-TR-2 Attribute 3.11.2 - Fire Barriers Performance-based evaluation (13) 2-TR-3 Attribute 3.11.2 - Fire Barriers Performance-based evaluation (13)

Attachment L-15-150 Page 12

2-WH-1 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10) and Request for NRC approval, SSD RAI 13(c) response (6) 3-CR-1 Attribute 3.11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 06 (10),

Licensing Action 11.18 (3) and Request for NRC approval, SSD RAI 13(c) response (6) 3-IS-1 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 3-IS-2 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 3-IS-3 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 3-IS-4 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3) 3-IS-6 Attribute 3.

11.3 - Fire Barrier Penetrations Complies by Previous Approval, Licensing Action 11.18 (3)

The explicit prior approval from Lic ensing Action 11.17, "Cable Spreading Room (1-CS-1) - Lack of 3-Hour Fire Barriers (I II.G.2 criteria)" is for the lack of 3-hour rated barriers for the cable spreading room (1-CS-1). Additional performance-based analysis in support of the response to SSD RAI 06 indicates that Licensing Action 11.17 will not be transitioned. T he following attributes are affected: Fire Compartment 1-CR-2 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 1-CR-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CR-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 1-CR-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CR-4 Attr ibute 3.11.2 - Fire Barriers

Attachment L-15-150 Page 13 Fire Compartment 1-CR-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CS-1 A ttribute 3.11.2 - Fire Barriers Fire Compartment 1-CS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-ES-1 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 1-ES-2 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 1-MG-1 At tribute 3.11.2 - Fire Barriers Fire Compartment 1-MG-1 Attribut e 3.11.3 - Fire Barrier Penetrations Additional performance based analysis has been performed in conjunction with SSD RAI 06(a) and (b) and will be documented within that response. The results of the performance based analysis determined the barriers are acceptable for the

fire severities of the associated adjacent fire compartments.

The Attachment T prior approval clarificati on request #6 will be withdrawn. The explicit prior approval from Licensing Action 11.02, "Reactor Containment

(1-RC-1) - Lack of 20 foot Separation (III.G.2 criteria)" is for lack of 20 feet separation with no intervening co mbustible materials or fi re hazards for redundant trains of safe shutdown cables and equi pment inside a non-inerted containment. The explicit prior approval from Licens ing Action 11.16, "Reactor Containment (1-RC-1) - Lack of 20 foot Separation of Redundant Trains of Circuits Associated with Source Range Monitoring Within Containment (I II.G.2 criteria)" is for lack of 20 feet separation of redundant trains of circuits associated with source range monitoring within containment. The following licensing excerpts below the associated fire compartment attribute list apply: Fire Compartment 1-RC-1 A ttribute 3.8.2 - Detection Fire Compartment 1-RC-1 Attribute 3.9.1 - Water-Based Suppression Licensing Action 11.02, NRC SER titled "Beaver Valley Unit 1 - Transmittal of Fire Protection Technical Exemption (TAC 56566)," dated March 14, 1983, page 6, states: 3. Reactor Containment - RC-1 This fire area includes t he entire area inside contai nment. The redundant trains of safe shutdown components in this area include the containment ventilation, pressurizer pressure controls, pre ssurizer power operated relief valves, pressurizer relief blocking valves, pre ssurizer heaters, steam generator level transmitters, pressurizer level transmitte rs, reactor coolant hot and cold leg temperature instrumentation, pre ssurizer and reactor vessel vents, and associated cables.

Attachment L-15-150 Page 14 The combustible loading in this area consists of approximately 48,000 pounds of cable insulation, 265 gallons of lubr icating oil for each of the three reactor

coolant pumps, and 200 pounds of charc oal in the containment air filter cubicles. All cable insulation is qualified to a test comparable to IEEE Standard 383. The reactor coolant pumps are fitt ed with an oil colle ction system.

Smoke detection systems and water deluge systems are provided only in the cable penetration area and in the residual heat removal pump area. Portable fire extinguishers and manual hose stati ons are provided throughout the fire area. Separation of redundant cables is as follows: Pressurizer Power Operated Relief ValvesThe Train A and Train B control cables are run from the valves (located above the pressurizer cubicle) in c onduit, to points just outside the crane wall. Outside the crane wall, the cont rol cables enter trays approximately 20 feet above the floor which run to the penetration area on either side of column 10 1/4. The control cables then drop down at t he penetration area and are separated by approximately 25 feet. The cables are also separated by a fire barrier and a fire detection and suppression system at the

penetration area.Pressurizer Relief Blocking ValvesThe power cables for both Train A and Train B are run in conduit

approximately 20 feet abov e the floor and from t he motor operated valves located in the pressurizer cubicles to the penetration area at column 10 1/4.

In the penetration area, the cables ent er vertical cable trays which drop down to the next level. The cable tra ys are separated by a fire barrier and are protected by automatic s uppression and detection systems. Pressurizer HeatersThe power cables of both trains are run entirely in tray from the pressurizer cubicle to either side of column 10 1/4.

The trays run parallel to each other at a height of 20 feet, in close proximity until they reach either side of column 10 1/4. At this point, the cables turn down into four trays which run vertically, and are separated by 18 feet. The traver se runs of tray above the operating floor are covered trays. Steam Generator LevelThe instrument cables for Channels I, II and III are run in separate conduits from the penetration area w here the trays are protected by suppression and detection. The conduit runs around t he containment and returns to the penetration area from opposit e directions; Channels I and III from the north and Channel II from the south.

Attachment L-15-150 Page 15 Pressurizer Level TransmittersThe instrument cables for the two level transmitters are in close proximity at elevation 642' [feet] 11" [inches]. The cables are enclosed in conduit and continue in conduit with increasing separ ation. The cables eventually enter trays in the penetration areas which ar e separated by a fire barrier at column 10 1/4, and are protected by a fire detection and suppression system. Reactor Coolant Hot and Cold Leg TemperatureHot leg instruments comprise Channel I while cold leg instruments comprise Channel II. The conduit system for each channel approaches the

penetration area from a di fferent direction. The individual channels run around the containment to local pull boxes. From these boxes separate conduits continue to the temperature detectors.Additionally, the remaining neutral temperature indication from the temperature detector bypass manifold is routed in conduit from each loop to the penetration area.

The protection for redundant trains of safe shutdown equipment inside containment does not meet the techni cal requirements of Section III.G because there is not twent y feet of separation bet ween redundant power cables free of intervening combustibl es. Due to their configuration and location within the containment and to the restricted access of these sub-areas during plant operations, an exposure fire involving the accumulation of significant quantities of transient combustible materials is unlikely.

Because there are only a few cables in these sub-areas and all cables inside containment are qualified to a test comparable to that of IEEE Standard 383 and routed in conduit, a fire of sufficient magnitude to damage redundant cables or components is also unlikely.

Based on the above evaluation, the exis ting protection for the containment area provides a level of fire prot ection equivalent to the technical requirements of Section III.G of A ppendix R. Therefor e, the exemption should be granted. Licensing Action 11.16, NRC SER titled "Beaver Valley Power Station, Unit 1 -

Request for Additional Informations [sic] From Some Requirements of Appendix R To 10 CFR Part 50," dated August 30, 1984, page 10, states:

8. Reactor Containment RC-1

An exemption is requested from Secti on III.G to the extent it requires the separation of redundant trains of the source range monitor within containment by greater than 20 feet.

This fire area includes t he entire area inside contai nment. The redundant trains of safe shutdown components in this area include the containment ventilation, Attachment L-15-150 Page 16 pressurizer pressure controls, pre ssurizer power operated relief valves, pressurizer relief blocking valves, pre ssurizer heaters, steam generator level transmitters, pressurizer level transmitte rs, reactor coolant hot and cold leg temperature instrumentation, and associated cables.

The combustible loading in this area consists of approximately 48,000 pounds of cable insulation, 265 gallons of lubr icating oil for each of the three reactor coolant pumps, and 200 pounds of charc oal in the containment air filter cubicles. All cable insulation is qualified to a test comparable to IEEE Standard 383. The reactor coolant pumps are fitted with an oil collection system. Smoke detection systems and water deluge systems are prov ided only in the cable penetration area and in the residual heat removal pum p area. Portable fire extinguishers and manual hose stations are provi ded throughout the fire area. We had previously approved an exemption for the separation of redundant equipment and cables inside containment. At our request, the licensee has added an additional channel of source range neutron detection. Due to the physical arrangement inside containment, separation of the redundant cables by more than 20-feet is not possible. A minimum separation of approximately

five feet is maintained. Each channel of neutron detection is in a separate conduit. The protection for redundant trains of safe shutdown equipment inside containment does not meet the technica l requirements of Section III.G because redundant power cables are not separated by at l east 20 feet free of combustibles. Due to the configurati on and location of the cables within the containment and to the restricted a ccess of these sub-areas during plant operation, an exposure fire involving t he accumulation of significant quantities of transient combustible materials is unlikely. Because there are only a few cables in these sub-areas and all cables inside containment are qualified to a test comparable to that of IEEE Standard 383 and routed in conduit, a fire of sufficient magnitude to damage redundant cables or components is also unlikely.

Based on the above evaluation, the existing protection for the containment area provides a level of fire protection equiva lent to the technical requirements of Section III.G of Appendix R. Therefore, the exemption should be granted. The explicit prior approval from Licens ing Action 11.18, "Fire Doors - Lack of 3-Hour Fire Barriers (III.G.2 criteria)" is for the lack of 3-hour rated fire doors in BVPS-1. The following licensing excerpt below the associated fire compartment attribute list apply:

Attachment L-15-150 Page 17 Fire Compartment 1-CR-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CR-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CV-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CV-2 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-ES-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-ES-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-FB-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-MG-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-MS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-NS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-PA-1E Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-PA-1G Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-PT-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-SGPD-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-TB-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-CR-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-IS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-IS-2 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-IS-3 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-IS-4 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-IS-6 Attribut e 3.11.3 - Fire Barrier Penetrations NRC SER, "Beaver Valley Unit 1 - Transmittal of Fire Protection Technical

Exemption (TAC 56566)," dat ed December 4, 1986, Enclos ure 2, page 3, states:

2.0 Fire Doors 2.1 Exemptions Requested

Exemptions were requested from Section I II.G.2 to the extent that it requires separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.

Attachment L-15-150 Page 18 The licensee's exemption requests spec ifically pertained to fire door assemblies in walls identified as fire area boundaries.Section III.G.2 of Appendix R to 10 CF R 50 contains requirements for the protection of hot shutdown components located within the same fire area. It does not apply to fire area boundaries. A cceptable guidelines for establishment of fire area boundaries are set forth in Section D.1.(j) of Appendix A to BTP APCSB 9.5-1. Therefore, the fire doors discussed in the licensee's request have been reviewed for conformance with Appendix A guidelines. 2.2 Discussion The licensee has identified 24 fire areas whose boundaries contain fire door assemblies that do not have a fire resi stance rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . A fire door assembly consists of the fire door(s), frame, and hardware. Some of these assemblies were designed and constructed as fire-rated assemblies but have been modified for security or flood contro l purposes, or have not been installed

in strict compliance with nationally accepted standards. Other assemblies are not fire rated, but are similar to fire rated assemblies.

In all, one fire door and 10 door frames ar e not labeled, frames in 18 locations have been modified for security purposes, and frames in 8 locations have been otherwise penetrated by pipe or conduit. Several locations contain multiple deviations. A label is the identifying mark applied to a product as evidence that it complies with the specif ied standards of the Underwriters Laboratories (UL) or other approval agency.

Twenty-one of the 24 fire areas, where these doors are provided, contain safe shutdown equipment. Fire door assemblies se rving the other three fire areas --

the PCA shop (Fire Area SB-1, the locke r room (Fire Area SB-3). and the clean shop (Fire Area SH-1) -- have been modified for security purposes. The combustible loading in 17 of these fire areas is 80,000 Btu per square foot or less, which is equivalent to a fire severity of up to 60 minutes based on the ASTM Standard E-119 time-tem perature curve. Fire protection in these areas consists of portable extinguishers and m anual hose stations. In addition, smoke detectors are installed in the following fire areas: the intake structure (Fire Areas IS-1 through IS-3), the control r oom complex (Fire Zones CR-1, -2, and

-4), the emergency switchgear room (F ire Area ES-2), the motor generator room (Fire Area MG-1), and the normal switchgear r oom (Fire Area NS-1).

The combustible loading in five of t he 24 fire areas is between 80,000 and 120,000 Btu [British thermal units] per square foot, which corresponds to a fire severity of 60 to 90 minutes. Fire protec tion in these fire areas consists of portable extinguishers and m anual hose stations. In addition, sprinkler systems are installed in the PCA shop and the cl ean shop. Detectors are installed in the Attachment L-15-150 Page 19 intake structure and detectors and a to tal flooding carbon dioxide system are installed in the c able spreading room.

The combustible loading in the remain ing two fire areas is between 120,000 and 160,000 Btu per square foo t, which corresponds to a fire severity of 90 to 120 minutes. Fire protection in these two areas (the east and west cable vaults, Fire Areas CV-1 and CV-2, respectively) consists of portable extinguishers, manual hose stations, heat and smoke det ectors, and total flooding carbon dioxide systems.

At the licensee's request, a UL [Underwrit ers Laboratory] repr esentative visited the plant and inspected typical examples of each identified deviation to evaluate each deviation's impact on the l abeling of the doors.

On the basis of the UL evaluation, the licens ee has made corrective modifications to several of these assemblies. The licensee has evaluated the affect ed fire door assemblies (with the corrective modifications) and determined t hat they provide an adequate margin of fire resistance considering the fire loading on both sides of each of the assemblies. This evaluation is described in Section 11.18 of the licensee's January 14, 1985 submittal. The licensee chose not to make corrective modifications to the affected door assemblies in the intake structure. The deviations applicable to the fire door assemblies between Fire Areas IS-1 and IS-2, between Fire Areas IS-3 and IS-4, and from each of these fire areas to the exterior involve the installation of a pipe penetration through the frames. UL recommended that the interior of a ll pipes and conduits penetrating fire door frames should be filled with a fire stop material. The pipes through the intake structure door frames convey pressurized air used to activate sliding flood doors located behind the fire door at eac h opening. The exterior of the pipe penetration has been made tight fitting, but the pipes cannot be sealed internally without interrupting the air supply.

Safe shutdown equipment in the intake st ructure consists of three river water pumps (in separate fire areas) of which only one is required for safe shutdown.

In addition, two auxiliary river water pum ps located in the separate auxiliary intake structure are available as backup systems. Two fire pumps are also located in the intake structure in Fire Areas IS-2 and IS-4.

In case of fire in one of Fire Areas IS

-1 through IS-4, safe shutdown capability would not be affected because redundant systems are available in other fire areas. In addition, the solid wall between Fire Areas IS-2 and IS-3 would prevent a fire in Fire Areas IS-1 or IS-2 from spreading to Fire Areas IS-3 or IS-4.

Attachment L-15-150 Page 20

2.3 Evaluation

The guidelines of Secti on D.1.(j) of Appendix A to BTP APCSB 9.5-1 are not met because a fire door is not labeled (1 location) or because fire door frames are not labeled (10 locations), fire doors have been modified for security purposes (18 locations), or fire doors have been penetrated by pipe or conduit

(8 locations). Several locations contain multiple deviations. However, the equivalent fire severity in each of the affected fire areas is less than 120 minutes and generally less than 60 minutes. The staff has reviewed the licensee's evaluation and concurs with the licensee's assessment that the existing fi re door assemblies with the corrective modifications provide an adequate margin of fire resistance compared to the combustible loading in the affect ed fire areas, with one exception. The exception to the fire resistance discussed above is the doors located in the intake structure. Due to the functional restrictions, the corrective modifications required to upgrade these doors are not possible. However, these door assemblies, in conjunction with the resist ance of the 3-hour fire-rated masonry walls, provide an adequate margin of fi re resistance betw een redundant trains of safe shutdown systems. The staff t herefore concludes that the intake structure door assemblies should be acceptable.

2.4 Conclusion

Based on the above evaluation, the staff concludes that the aforementioned fire door assemblies, combined with the licensee's modifications, provide an acceptable level of protection in acco rdance with the guidelines of Section D.1(j) of Appendix A to BTP APCSB 9.5-1.

The explicit prior approval for the below-lis ted attributes is fo r usage of the fixed carbon dioxide (CO2) fire extinguishing system as the primary automatic suppression system in the Unit 1 diesel generator rooms, and for the doorway between the Unit 1 diesel generator rooms.

The following licens ing excerpt below the associated fire compartment attribute list applies: Fire Compartment 1-DG-1 Attrib ute 3.10.1 - Gaseous Suppression Fire Compartment 1-DG-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-DG-2 Attrib ute 3.10.1 - Gaseous Suppression Fire Compartment 1-DG-2 Attribut e 3.11.3 - Fire Barrier Penetrations Attachment L-15-150 Page 21 Page 5-12 of the appendix to the "Safety Evaluation By The Office Of Nuclear Reactor Regulation Related To Amendment No. 18 To Facility Operating License No. DPR-66 Duquesne Light Company" dated June 6, 1979, states:

5.10 Diesel Gener ator Rooms 5.10.1 Safety-Related Equipment Each of the two redundant diesel generator rooms contains a diesel engine driven air compressor, local control panels, cabling, and fuel day tank. At least one division of this equipment is nece ssary for safe shutdown upon loss of offsite power.

5.10.2 Combustible Materials Combustibles in the diesel generator room area include diesel engine lubricating oil, diesel fuel in fuel lines , day tanks, and electrical cable insulation. 5.10.3 Consequences if No Fire Suppression

An unmitigated fire in one of the two diesel generator rooms could result in the loss of function of one unit with possible damage to the redundant diesel generator located in the adjac ent fire area, by means of fuel passing under the communicating door or by breaching the fire door.

5.10.4 Fire Protection Systems Early warning fire detection is provided by ionization type smoke detectors arranged to alarm in the control room. A total flooding CO2 extinguishing system automatically actuated by thermal detectors is provided in the diesel

generator rooms. The CO2 system has reserve capacity for a second manually actuated discharge. Back up fire suppression capability consists of portable CO2 and dry chemical extinguishers lo cated in each room. Additional manual firefighting capability is provided by yard hydrants. The two diesel generator rooms are enclosed by 3-hour fire rated reinforced concrete walls and ceilings.

The doorway between the two rooms is pr ovided with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire door.

5.10.5 Adequacy of Fire Protection The existing ionization fire detecti on system, portable extinguishers and back up firefighting capability from the yard hydrant is considered acceptable.

The fixed CO2 fire extinguishing system is adequate as the primary automatic suppression system. The location of the manual pull stat ions inside the Attachment L-15-150 Page 22 protected rooms is not acceptable. The int ensity of a potential diesel fuel fire in one of the rooms could make it impossible to enter and reach the pull box.

Provisions are not adequate to insure a fire in one diesel generator room does not affect the redundant diesel gener ator room via oil seepage under the doorway. The manual control for stopping the diesel fuel transfer pump is located within the diesel generator r ooms and could be inaccessible during a fire. A leak in the diesel fuel s upply system could go undetected for a considerable period of time and accumulate on the floor. If significant quantities of fuel entered the floor drains, the possibility exists that fuel could communicate via the drainage system to the adjacent diesel generator room.

The fire door between the two redundant diesel generator rooms may not be capable of withstanding a potential high intensity diesel fuel fire. 5.10.6 Modifications In order to mitigate the po ssibilities of a fire affe cting both redundant diesel generator rooms, the licensee will make the following modifications:

1. Curbing of sufficient height to prevent on [sic] oil leak in one room from entering the adjacent room will be provided at the doorway between the rooms.

2. An additional three (3) hour fire rated door and frame with self-closing hardware will be provided at the door way between rooms. (also discussed under 4.9.1)

3. The manual actuation pull box for the CO2 extinguishing systems will be relocated outside the room it is designed to protect. (also discussed under 4.3-2) 4. A control for shutting off the diesel fuel transfer pump outside of the diesel generator rooms will be provided.

5. Floor drains in the diesel generator rooms will be plugged. 6. A fail safe level detecting device will be installed in a sump close to the day tank to detect an oil accumulation due to a leak. High sump level will be annuciated [sic] in the control room. 7. Fire barrier wall penetration between Diesel Generator rooms will be evaluated and up-graded to a 3 hr barrier.

We find that, upon implementation of the above described modifications, the Diesel Generator Room's fi re protection satisfies t he objectives identified in Section 2.2 of this report and is, therefore, acceptable.

Modifications described in section 5.10.6 above have been installed.

Attachment L-15-150 Page 23 The compliance basis for these fire compartment attributes will be revised to "Complies by EEEE" in the response to FPE RAI 01: Fire Compartment 1-CV-3 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-SG-1N Attribute 3.9.1 - Water-Based Suppression Fire Compartment 2-SG-1S Attribute 3.9.1 - Water-Based Suppression The compliance basis for these fire compartment attributes will be revised to request NRC approval based on the response to SSD RAI 13(c): Fire Compartment 2-ASP Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-5 A ttribute 3.11.2 - Fire Barriers Fire Compartment 2-CB-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-6 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CP-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-1 A ttribute 3.11.2 - Fire Barriers Fire Compartment 2-CV-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-6 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-DG-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-DG-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-FB-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-MS-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-1 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-2 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-2 Attribute 3.11.3 - Fire Barrier Penetrations Attachment L-15-150 Page 24 Fire Compartment 2-SB-6 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-7 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-8 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-9 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-10 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SG-1N Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-WH-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-CR-1 Attribute 3.11.3 - Fire Barrier Penetrations The response to SSD RAI 13(c) will include a request for NRC approval of instances where there are fire dampers installed in series and where ducts have

fire wrap installed to meet the required barrier rating.

The explicit prior approval from Licens ing Action 03, "Conduits/Penetration Seals &

Penetration Seal Design - BTP C.5.a(3)"

is for qualified penetration seals for all fire-rated walls or floor/ceiling assemblies. The following licensing excerpt below the associated fire compartment attribute list applies: NFPA 805 Section 3.11.1, Building Separation NFPA 805 Section 3.11.4, Through Penetration Fire Stops Fire Compartment 2-SB-1 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-4 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-5 Attr ibute 3.11.2 - Fire Barriers NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-2, states: In the SER, the staff stated that the applicant would provide qualified penetration seals for all penetrations of fire-rated walls or floor/ceiling assemblies. In Amendment 14 of the F SAR, the applicant stated that because of installation problems, certain fire barrier penetrations could not be sealed per Section C.5.a(3) of BTP CMEB 9.5-1. The applicant identified approximately 18 penetrations, of 4-inch diameter or greater, which cannot be sealed at the barrier. The applicant proposed to seal these penetrations with fire-seal

material at the first openi ng and wrap the conduit from the seal to the barrier with 1-hour fire-wrap material. Seventeen of the penetrations have detection and automatic suppression on both sides of the barrier. The remaining Attachment L-15-150 Page 25 penetration has detection on both sides with automatic suppression on one side. The applicant also stated that certain penetrations throughout the plant

which are less than 4 inches in diameter and extend less than 5 feet on either side of the barrier cannot be sealed at the barrier. For these cases, the applicant proposed to seal the penetration at the first opening on both sides of

the barrier with a fire-seal material. During the site audit on January 27-30, 1987, seals of both configurations were reviewed in the field and were found to provide an adequate measure of sealing fo r penetrations in fire barriers when the Standard Review Plan (SRP) (NUREG-0800) cannot be met because of installation difficulties. Therefore, the method for sealing penetrations as identified in Amendment 14 to the FSAR is an acceptable deviation from Section C.5.a(3) of BTP CMEB 9.5-1 when installation difficulties do not allow sealing at the barrier. The explicit prior approval from Lic ensing Action 04, "Ventilation Penetration Openings (Fire Dampers) - La ck of Appropriate Fire Damp ers - BTP C.5.a(4)" is for usage of two 1.5-hour rated fi re dampers in series instead of one 3-hour rated damper. The following licens ing excerpt below the asso ciated fire compartment attribute list applies: Fire Compartment 2-PA-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PT-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SG-1S Attribute 3.11.3 - Fire Barrier Penetrations NUREG-1057, Supplement No. 3 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated November 1986, page 9-1, states: 9.5.1.4 General Plant Guidelines Building Design

In the SER, the staff stated that 3-hour fire-rated damper assemblies are provided in all ventilation ducts that penet rate 3-hour fire-rated barriers and that the damper assemblies are U nderwriters Laborator ies, Inc. (UL) labeled. By letter dated March 27, 1985, the applicant in formed the staff th at the 1 1/2-hour-Attachment L-15-150 Page 26 rated fire damper assemblies are installed in series in each duct penetrating a 3-hour fire-rated barrier. Moreover, because the applicant redefined the fire area boundaries, some damper assemb lies had to be installed within completed heating, ventilation, and ai r conditioning (HAVC [sic]) systems.

These damper assemblies are located close to, but not within, the fire barrier penetration. To compensate for the damper location, the applicant enclosed the ductwork from the fire ba rrier to the damper assembly with 3-hour fire-rated barrier material.

In the March 27, 1985, letter, the applicant also informed the staff that although all of the fire damper assemblies were purchased as UL-labeled units, the manufacturer had removed the UL label from the assemblies because they were not tested in the series configuration, and because they were not tested with carbon dioxide fire-suppression-system-actuated release devices.

For a fire to spread between fire areas through an HVAC system duct, it would have to burn through the duct in one fire area, through two 1 1/2-hour fire-rated

dampers, and finally, through the duct in the adjoining area. In the staff's opinion, the two 1 1/2-hour fire-rated dampers will provide the equivalent fire resistance of one 3-hour fire-rated dam per. The 3-hour fire-rated wrap around the ducts constitutes continuous fire-rat ed construction which will prevent fire spread through the ductwork between the fire barrier and the fire dampers. The release device is a plunger-operated pin that is in addition to the fusible link for damper actuation. The device is UL-listed for this service and, in the staff's opinion, will not reduce the effectivene ss of the dampers actuated by the

devices. The staff concludes that the fire dampers, as installed, will prevent fire spread from one fire area to another. The damper insta llation is, therefore, an acceptable deviation from Secti on C.5.a(4) of BTP CMEB 9.5-1. The explicit prior approval from Licensi ng Action 05, "Fire Dam pers and Ventilation Ductwork - Assembly Location and Deviatio n in Ductwork 1-Hour Fire Wrap - BTP C.5.a(4)" is for usage of 1-hour fire wrap for ductwork penetrations from the damper assemblies to the barriers. T he following licensing excerpt below the associated fire compartment attribute list applies: Fire Compartment 2-PA-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PT-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-3 Attribute 3.11.3 - Fire Barrier Penetrations Attachment L-15-150 Page 27 Fire Compartment 2-SB-4 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-5 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-SB-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SG-1S Attribute 3.11.2 - Fire Barriers Fire Compartment 2-SG-1S Attribute 3.11.3 - Fire Barrier Penetrations NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-3, states: In SSER 3, the staff stated that some fire damper assemblies were located outside of the fire barrier because of a r edefining of certain fire areas and that where this took place, the ductwork fr om the barrier to the fire damper assembly would be wrapped with 3-hour fire-ra ted material. Section C.5.a(4) of BTP CMEB 9.5-1 states that, 'penet ration openings for ventilation systems should be protected by fire dampers havi ng a rating equivalent to that required of the barrier.' In a meeting on Nove mber 5, 1986, the applicant stated that 3-hour wrap material could not be used bec ause of weight limitations of the structural supports and stated that t he ductwork would be wrapped with 1-hour rated material. This deviation was included in Amendment 14 to the FSAR following the meeting. Fire dampers r equiring 1-hour wrap are used as fire barriers between Fire Areas PA-3 and PA-5, PA-4 and PA-5, SB-3 and SB-4, SB-4 and SB-5, and PT-1 and SG-1S. The fire loading is less than 1/2 hour on

either side of the subject dampers. Smok e detection is provided in all areas where the 1-hour wrap will be installed and hose racks are provided for fire brigade use. It is expected that a fire would be detec ted in its incipient stage and the plant fire brigade would extinguish it using the installed hose racks.

Providing additional stru ctural support to the ductw ork to accommodate 3-hour wrap would not significantly increase t he level of fire sa fety. Therefore, wrapping ductwork from the barrier to the damper with 1-hour material is an acceptable deviation to Section C.5.a(4) of BTP CMEB 9.5-1. The applicant also identified one damper in Fire Area SB-4 in which a 2-inch

portion of the ductwork could not be wrapped because of interferences and

therefore constituted an additional deviati on from Section C.5.a(4) of BTP CMEB 9.5-1. The fire loading in this area is less than 1/2 hour and detection is provided. The 2-inch portion of the ductwork is above one of the 1-1/2 hour dampers that are in series. Lack of wrap on this 2-inch ductwork section does

not adversely affect plant fire safety and therefore, is an acceptable deviation from Section C.5.a(4) of BTP CMEB 9.5-1.

Attachment L-15-150 Page 28 The applicant stated in Amendment 14 to the FSAR that ventilation ductwork for the battery room exhaust system and the emergency switchgear ventilation system pass through areas not serviced by the two systems. To ensure the

operability of these systems in the event of a fire in an area not using these systems, the ductwork was wrapped with 1-hour material in areas not serviced by the ventilation systems.

Battery room exhaust ducts run through Fire Areas SB-1, SB-2, and SB-4. Each of these ar eas has a fire loading of less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and detection is provided. In the event of a fire in these areas, it is expected that the fire woul d be detected in its incipient stage and that the plant fire brigade would respond and extinguish the fire. Both the battery room exhaust ductwork and the emergency switchgear ventilat ion ductwork run through Fire Areas CV-1, CV-3, and SB-3.

These fire areas have a combustible loading of less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and are provided with detection and automatic

suppression. It would be expected that a fire in these areas would be detected in its incipient stage and t hat the plant fire brigade would respond and control it.

The automatic suppression provides added assurance that a fire would not jeopardize the integrity of the 1-hour wrapped ventilation ducts. On the basis of this evaluation, this method of ensuri ng continuous ventilation to the battery room and emergency switchgear is acceptable. The explicit prior approval from Licensing Action 06, "Fire Doors - Modification of Fire Door Assemblies - BTP C.5.a(5)" is for modification of fi re door assemblies. The following licensing excerpt below the as sociated fire compartment attribute list applies: Fire Compartment 2-ASP Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-1 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-CB-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CB-6 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-1 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-CV-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-2 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-CV-2 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-3 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-CV-3 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-5 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-CV-6 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-CV-6 Attribut e 3.11.3 - Fire Barrier Penetrations Attachment L-15-150 Page 29 Fire Compartment 2-DG-1 Attrib ute 3.10.1 - Gaseous Suppression Fire Compartment 2-DG-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-DG-2 Attrib ute 3.10.1 - Gaseous Suppression Fire Compartment 2-DG-2 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-FB-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-2 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-3 Attri bute 3.10.1 - Gaseous Suppression Fire Compartment 2-SB-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-4 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-5 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-6 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-7 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-8 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-SB-9 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-WH-1 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 3-CR-1 Attribute 3.11.3 - Fire Barrier Penetrations NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-4, states: In the SER, the staff stated that with the exception of two rolling fire doors, door

openings are in compliance with Section C.5.a(5) of BTP CMEB 9.5-1, which states that 'door openings in fire barri ers should be protected with equivalently rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory.' The applicant stated in Amendment 14 to the FSAR that certain doors have been modifi ed by the installation of security hardware and are no longer approved fire doors. The applicant also stated that

there are 'special purpose' doors that are not approved by Underwriters Attachment L-15-150 Page 30 Laboratories (UL). During the site audit of January 27-30, 1987, the applicant identified 40 doors that were modified for security purposes. The applicant demonstrated that all modifications were made in accordance with

recommendations supplied by UL. Although the applicant stated that all doors were originally purchased as UL-approved, it was noticed during the site visit that some UL labels were missing from doors. The applicant committed to have the doors relabeled by the manufacturer or to maintain on file documentation that individual doors are UL approved. This commitment will be implemented by

fuel load. It was also observed that the security modifications consisted primarily of the addition of electric contact switches with a single conduit penetrating the frame. Inst allations appeared to be in accordance with design drawings, which were based on UL recommendations. Therefore, with the

exception of the doors missing labels, the security-modified fire doors are an acceptable deviation from Secti on C.5.a(5) of BTP CMEB 9.5-1. The explicit prior approval from Licensing Action 08, "Safe Shutdown Components

- Lack of Separation of Redundant Trains - BTP C.5.b" is for separation of redundant safe-shutdown components by 3-hour fire-rated barriers. The following licensing excerpts below the associated fi re compartment attribute list apply: Fire Compartment 2-PA-3 Attr ibute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3 Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-3A Attribute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3A Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-3B Attribute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3B Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-PA-3C Attribute 3.11.2 - Fire Barriers Fire Compartment 2-PA-3C Attribute 3.11.3 - Fire Barrier Penetrations re Compartment 2-RC-1 Attr ibute 3.8.2 - Detection Fire Compartment 2-RC-1 Attribute 3.9.1 - Water-Based Suppression NUREG-1057, Supplement No. 3 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated November 1986, page 9-2, states:Safe-Shutdown Components By letter dated March 27, 1985, the appl icant requested a deviation from Section C.5.b of BTP CMEB 9.5-1 for fire area PA-3 to the extent that it requires the separation of redundant safe-shutdown components by 3-hour fire-rated barriers.

Attachment L-15-150 Page 31 This fire area is located on auxiliary building elevation 735 feet 6 inches. The two redundant and one swing charging pumps are located in this area, one in each of three adjacent cubicles. The walls between cubicles are reinforced

concrete with 3-hour fire-rated penetration seals. The west wall of each cubicle is concrete block with a small crane rail opening; the east wall of each cubicle is reinforced concrete with a labyrinth-type opening. A curb is provided across each opening and a drain is provided in each cubicle. The equivalent fire

severity per cubicle is less than 1/2 hour. Existing fire protection consists of portable extinguishers, hose stations, and an area wide ionization-type smoke-

detection system. The staff was concerned that a fire originating either outside of or within one of the pump cubicles would result in loss of safe-shutdown capability. However, because the fuel load in each cubicle is lo w, the staff does not expect a fire of significant magnitude or durati on to occur. If a fire o ccurs anywhere in the fire area, it would be detected by the ioniza tion detectors and extinguished by the plant's fire brigade before spreading into or from a pump cubicle. In the staff's opinion, any fire would, at most, cause damage to one shutdown system, but would not propagate horizont ally and damage the redun dant pump before self-extinguishing or being extinguish ed by the plant's fire brigade.

On the basis of this evaluation, the st aff concludes that the lack of complete 3-hour fire-rated barriers around eac h redundant charging pump is an acceptable deviation from Sect ion C.5.b of BTP CMEB 9.5-1.

NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-5, states: Safe Shutdown Capability The staff review of the fire protection afforded the sa fe shutdown capability of Beaver Valley Unit 2 included the FSAR

[Final Safety Analysis Report], up to and including Amendment 16, the fire protection safe shutdown report (FPSSR) provided by transmittal dated Marc h 24, 1987 and additional information provided by letter dated May 11, 1987.

FSAR Section 9.5.1 describes the overall fire protection program and t he FPSSR discusses the safe shutdown capability, including the potential for s purious operation of equipment in each fire area. FSAR Section 7.4 provi des additional information on safe and alternate shutdown system controls capability. The applicant's safe shutdown analysis demonstrates that systems needed for

hot and cold shutdown are redundant and that one of the redundant systems needed for safe shutdown would be free of fire damage because of separation, fire barriers, fire detection and suppressi on, or a combination of these and/or alternative shutdown capabilit

y. Alternative shutdown capability is provided for Attachment L-15-150 Page 32 a fire in the instrumentation and rela y room (CB-1), cable spreading room (CB-2), main control room (CB-3), west communication room (emergency shutdown panel station) (CB-6), and cable tunnel (CT-1) because these areas contain more than one division of safe shutdown cabling in close proximity to each other and in-place protection from fire cannot be provided.

For hot shutdown and for cooldown to cold shutdown conditions, at least one

train of the following safe shutdown system s would be available: reactor coolant system (RCS), auxiliary feedwater syst em, main steam system (atmospheric dump valves) and chemical and volume control system (CVCS). For cold shutdown conditions, at least one train of the residual heat removal (RHR) system would be available for long-term decay heat removal. A single train provides the capability to achieve cold shutdown conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with or without offsite power after a fire. The availability of these systems includes the components, cabling, electrical distribution panels, and support systems necessary to achieve cold shutdown. The support systems include the service water system; reactor plant component cooling water system; emergency diesel generator and its support systems; stati on service air system; filter water system; necessary heating, ventilat ion, and air conditioning systems; emergency ac and dc power systems; and necessary instrumentation to monitor plant parameters for safe s hutdown. The above systems are used to achieve safe shutdown through various success paths, depending on the

location of the fire. Reactivity control is accomplished through control rod insertion followed by boration provi ded by a charging pump (CVCS) drawing suction from borated water supplies from the refueli ng water storage tank or from the boric acid tanks through a boric acid transfer pump. RCS makeup/inventory control is provided by a charging pump combined with letdown. RCS pressure control is also accomplished by a charging pump combined with letdown, t he power-operated relief valves, or the pressurizer heaters if available. RCS dec ay heat removal is accomp lished initially using the steam generator safety relief valves and by the power-operated relief valves (atmospheric dump valves) during cool down, and the auxiliary feedwater system, down to a temperature of 350 degree F, at which time the heat-removal function is transferred to the RHR system.

For certain fires outside the control room , cold leg temperature (T-cold) wide range indication may be lost because all T-cold indication in the control room is powered from train B. This is acceptabl e since alternate means for determining T-cold is available by use of steam generator pressure indication and other normal train A primary system instrumentation. Similarly for certain other fires outside the control room, the use of core exit thermocouples for T-hot indication and use of T-cold as an alternate to st eam generator pressure indication are acceptable. The applicant's fire protection safe shut down analysis demonstrates that except for the instrument and relay room (CB-1), cable spreading room (CB-2), main Attachment L-15-150 Page 33 control room (CB-3), west communica tion room (CB-6), and cable tunnel (CT-1), redundant systems and cabling needed for safe shutdown following a fire are separated in accordance with BTP CMEB 9.5-1, Po sitions C.5.b.1 and C.5.b.2 with some noted deviations that are evaluated elsewhere in Section 9.5.1 of the SER and its supplements. For Fire Areas CB-1, CB-2, CB-3, CB-6, and CT-1, the applicant has provided alternate shutdown capability independent of these areas in accordance with Position C.5.c of BTP CMEB 9.5-1. NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-10, states: Safe Shutdown Components Section C.5.b of BTP CM EB 9.5-1 identifies the s eparation criteria for redundant safe shutdown components. The applicant had originally intended to install new barriers for areas that do not meet these guidelines. By letter dated March 27, 1985, the applicant stated that installation of these barriers would not be possible and that an alternative m eans of separation would be required, which would necessitate deviations from the SRP. Amendment 14 to the FSAR identified 11 areas in which deviations from the separation crit eria exist. One of these areas, the charging pump room, was approved in SSER 3. The remaining deviations have been evaluated through Amendment 14 and during a site audit

of January 27-30, 1987. The 10 deviations were found to be acceptable as identified in the fo llowing evaluations.

Component Cooling Water Pumps The component cooling water pumps (2CCP*P21A, B, and C) are located in the auxiliary building at elevation 735 fee t, 6 inches. Pumps A and B are separated by 24 feet; however, the C swing pump is located between pumps A and B and is an intervening combustible. Each pump contains 1/2 gallon of lube oil and has combustible motor insulation. The combustible loading in the immediate area of the pumps is neglig ible and there is dete ction and automatic water suppression over each pump. There is reasonable assurance that a single fire could not jeopardize the operation of bot h pumps A and B. If a fire were to occur, the plant fire brigade would respond and control it. The automatic suppression would also limit the size and intensity of a fire.

Therefore, the lack of at least 20 feet of separation of the component cooling pumps with no intervening combustibles is an acceptable deviation from Section C.5.b of BTP CMEB 9.5-1.

Attachment L-15-150 Page 34 Boric Acid Transfer Pumps and Storage Tanks Each of the boric acid pumps and tanks is located in a separate cubicle with 2-foot-thick reinforced concrete walls.

The pumps and tanks do not meet the separation criteria because they are located within 20 feet of their redundant components and the cubicles are not totally enclosed. Each of the cubicles has a labyrinth-type opening for missile and radi ation protection. Each cubicle will be provided with detection and the combustible loading is low. It is expected that a fire would be detected in its incipient stage and that the plant fire brigade would respond and control it. It is not probable that a fi re in any cubicle could travel through the labyrinth opening and into the adjacent cubicle of the redundant component. Therefore, the arr angement of the boric acid transfer pumps and boric acid storage tanks is an acceptable deviation from BTP CMEB 9.5-1 Section C.5.b.

Charging System Suction Valves

There are four valves that can provi de suction paths for the charging pumps during shutdown. All four valves are located in the same area; however, only one valve is necessary for safe shutdown.

There is approximately 15 feet of separation between the farthes t valves. The combustibl e loading in the area is negligible. Access to the area will be stri ctly controlled for radiation purposes and therefore, it is unlikely that transient combustibles would accumulate. The area is provided with detection and it is expected that a fire would be detected in its incipient stage and that the plant fire brigade would respond and extinguish it. There is reasonable assur ance that a fire w ould not prevent the operation of at least one of the four va lves. Therefore, th e lack of charging system suction valve separation is an acceptable deviation from BTP CMEB 9.5-1, Section C.5.b. Emergency Switchgear Room Supply and Exhaust Fans and Emergency Switchgear Room Supply Dampers The emergency switchgear room s upply and exhaust fans and emergency switchgear room supply dampers do not m eet the criteria of the SRP because the redundant components are not separat ed from each other by a 3-hour barrier. The two supply fans and the two ex haust fans are located in Fire Area CV-4. All of the motors are totally enclosed and are lo cated in separate ductwork. The control cable for supply fan A and exhaust fan A has been protected with 1-hour fire-wrap material in the fire area outside of the ductwork.

The combustible loading in the fire ar ea is negligible and detection has been provided. It is anticipated that if a fire were to occur, it would be detected in the incipient stage and the plant fire brigade wo uld respond to extinguish it, using adjacent hose racks. There is reasonable assurance that a fire would not jeopardize both trains of supply fans and exhaust fans. The supply dampers are located in a plenum adjacent to the suppl y fans. The combustible loading in the Attachment L-15-150 Page 35 plenum is negligible and t here is limited access by pl ant personnel. The damper motors are totally enclosed, which would prevent the burnout of one motor from affecting the operation of t he other. There is reasonable assurance that a fire would not affect the operation of bot h dampers. Therefor e, the lack of separation between the em ergency switchgear room supply fans and exhaust fans and the emergency switchgear room supply dampers is an acceptable deviation from Section C.5.b of BTP CMEB 9.5-1.

Charging Pump Emergency Exhaust Fans

The charging pump emergency exhaust fans are not in compliance with the SRP because they are not separated by a 3-hour barrier. The fans are located in Fire Area PA-4 and are in a conf iguration similar to the emergency switchgear supply and exhaust fans. Both fans and motors are totally contained within the ductwork. The combustible loading near the fans is low and detection is provided. Therefore, the lack of separation between the charging pump emergency exhaust fans is an acceptable de viations from Section C.5.b of BTP CMEB 9.5-1.

Auxiliary Feedwater Control Valves

The six auxiliary feedwater control valves are all located in Fire Area SG-1S, which deviates from the separation guidelines of the SRP. However, these valves are hydroelectrically operated, normally open valves, which fail "as is" on loss of electrical control. On loss of hydraulic oil, the auxiliary feedwater flow will open the valves. The applic ant stated that auxiliary feedwater flow can be controlled manually throttling the discharge valve at the auxiliary feedwater pump. The combustible loading in fire area SG-1S is less than 1/2 hour and detection is provided. It is anticipated t hat a fire would be detected early and the plant fire brigade would respond and control it. Even if a fire were to disable all six valves, the plant could still be able to safely shut down. Therefore, the lack of separation between redundant auxilia ry feedwater control valves is an acceptable deviation from Section C.5.b. of BTP CMEB 9.5-1. Atmospheric Steam Dump Valves and Main Steam Isolation Valves Atmospheric steam dump valves 2SVS*

PCV 101 A, B, and C and main steam isolation valves (MSIVs) 2MSS*HYC 101 A, B, and C are located in the main

steam valve house and are not separated in compliance with the SRP guidelines. The combustible loading in the valve house is less than 1/2 hour and the detection is provided. The steam dump valves are partially separated by concrete walls, which extend at leas t 2 feet beyond the valves. The MSIVs are spring-loaded valves, which are latched open during plant operation. Only

one of the three solenoid-operated valves for each MSIV is required to operate to close the MSIV. Two of the solenoi ds are designed to de-energize and the third is designed to energize. There is reasonable assurance that a fire would Attachment L-15-150 Page 36 not prevent the operation of the requir ed steam dump valves or main steam isolation valves. By letter dated Dece mber 4, 1986, the staff granted an exemption for the Beaver Valley Unit 1 main st eam valve room equipment separation. The configuration of the Unit 2 main steam valve room is equivalent to that of Unit 1. Theref ore, the lack of separation between valves in the main steam valve room is an acceptable devia tion from Section C.

5.b of BTP CMEB 9.5-1. Reactor Containment

Equipment inside containment is not in compliance with Section C.5.b of BTP CMEB 9.5-1 because redundant trains of safe shutdown components and circuitry are not separated by 3-hour walls or are not separated by 20 feet with no intervening combustibles. Generally, redundant cables inside the containment are run on opposite sides of the interior wall. Although this does not provide 3-hour separation, the wall is a significant barri er to fire and heat.

Cables inside the containment are either qualified to IEEE Standard 383 or are run inside conduit. The only significant co mbustible loading ot her than cable is the oil inside the reactor coolant pum ps, RHR pumps, and the charcoal filters.

The reactor coolant pumps are provi ded with an oil collection system in compliance with the SRP, which reduc es the potential for spread of combustible oil. Both the RHR pumps and the charcoal filters are provided with detection and suppression systems. The penetration area, where redundant divisions are separated by at least 18 feet, is provided with detection and automatic suppression. Because of the low in situ combustibles and the containment's large volume, it is expected that any fire would develop slowly with the heat dissipated to the large air space. In addition, because access to the area is tightly controlle d, it is not expected that transient combustibles would contribute to the fire loading. T herefore, there is reasonable assurance that a fire inside the containment woul d not jeopardize both trains of redundant safe shutdown equipment, and lack of complete separation of redundant trains of safe shutdown components inside cont ainment is an acceptable deviation from Section C.5.b of BTP CMEB 9.5-1. Safe Shutdown Circuitry In Amendment 14 to the FSAR, the applicant identified six fire areas where safe shutdown circuitry is not in compliance with Section C.5.b of BTP CMEB 9.5-1. The fire areas include cable vaults (CV-4 and CV-5), primary auxiliary building (PA-4), pipe tunnel (PT-1), south safeguards building (S G-1S), and the service building normal switchgear (SB-4). Thes e fire areas deviate from the SRP because they do not contain automatic suppression in addition to detection and 1-hour separation. All six areas have a combustible loading of less than 1/2 hour and detection is provided. One train of circuitry is wrapped with 1-hour

material in each of the six areas. It is expected that a fire would be detected in its incipient stage and the plant fire bri gade would respond. All of the areas are Attachment L-15-150 Page 37 provided with hose racks for fire brigade use. Providing autom atic suppression in these areas would not significantly in crease the level of fire protection.

Therefore, the lack of area suppression for Fire Areas CV-4, CV-5, PA-4, PT-1, SG-1S, and SB-4 is an acceptable deviati on from Section C.

5.b of BTP CMEB 9.5-1. Electrical Cable Construction, Cable Trays, and Cable Penetrations

In the SER, the staff identified three fire areas where cable tray separation did not meet the guidelines of Section C.5.e(2) of BTP CMEB 9.5-1. They include the containment (RC-1) and the primary auxiliary build ing (PA-3 and PA-4). In Amendment 14 to the FSAR, the applicant provided clarification of this deviation and stated that continuous line-type detection was not provided in any safety-related cable trays; however, all areas containing safety-related cables had general area detection and all areas wit h concentrated cables, except for RC-1, PA-3, and PA-4, were provided with automatic suppression. As identified

previously in the SER, the addition of automatic suppression in these three

areas would not significantly enhance fi re safety. Also, the general area detection provides adequate assurance that a fire in any safety-related cable will be detected in its incipient stage, making line-type heat detection

unnecessary. Therefore, the lack of autom atic suppression in fire areas RC-1, PA-3, and PA-4 and the lack of continuous-li ne type of heat detection in safety-

related cable trays are acceptable deviati ons from Section C.

5.b of BTP CMEB 9.5-1. The explicit prior approval from Lic ensing Action 31, "Access Hatch - Unrated Containment Hatch - BTP C.5.a(5)" is fo r usage of an unrated Containment hatch. The following licensing excerpt below the as sociated fire compartment attribute list applies: Fire Compartment 2-RC-1 Attribute 3.11.3 - Fire Barrier Penetrations NUREG-1057, Supplement No. 5 titled "Saf ety Evaluation Report related to the operation of Beaver Valley Power Station, Unit 2,"

dated May 1987, page 9-4, states: During the audit, the applicant also stat ed that the containment access hatch did not contain a UL label or certificati on of fire testing. The hatch was observed to be similar to air locks used at other facilities and was designed to meet multiple accident criteria. The combus tible loading near the hatch is low; therefore, there is reasonable assurance that a fire of significant magnitude or duration will not occur near the air lock. If a fire does occur, it is probable that the substantial construction of the air lock will prevent fire propagation through the containment boundary. T herefore, an unrated contai nment access hatch is an acceptable deviation from Section C.5.a(5) of BTP CMEB 9.5-1.

Attachment L-15-150 Page 38

This item addresses the lack of 50' separation from t he outdoor station transformers TR-2A, TR-2C, TR-2D, and TR-MT-2 and the wall separating 2-TB-1, which is less than a three hour barrier. The correlation between transformer

location identifications and fire compar tments can be found in Attachment I, Definition of Power Block, Table I BVPS-2 Power Block Definitions. 2-TR-1 is the compartment for the Main Transformer (TR-MT-2). 2-TR-2 is the compartment for Unit Station Service Transformer (TR-2C

). 2-TR-3 is the compartment for Unit Station Service Transformer (TR-2D). This discussion applies to the following attributes and was evaluated through the variance from deterministic requirements (VFDR) through Action Item BV2-0793.

The action item resolved this VFDR by determining through performance-based analysis that the non-rated portion of the fire barriers is adequate to withstand the fire effects of the potential hazard: Fire Compartment 2-TR-1 A ttribute 3.11.2 - Fire Barriers Fire Compartment 2-TR-2 A ttribute 3.11.2 - Fire Barriers Fire Compartment 2-TR-3 A ttribute 3.11.2 - Fire Barriers The records for Fire Compartment 2-TR-1 Attribute 3.11.2 - Fire Barriers, Fire Compartment 2-TR-2 Attribute 3.11.2 - Fire Barriers and Fire Compartment 2-TR-3 Attribute 3.11.2 - Fire Barriers are revised to credit the performance based analysis.

The explicit prior approval from Licensi ng Action 18, "Fire Hydr ant - Deviation in Spacing - BTP C.6.b (7)" is for spacing between hydrants 15 and 16. The following licensing excerpt below the associated fire compartment attribute list applies: NFPA 805 Section 3.5.15, Hydrants and Hose Houses Section 9.5.1.5, "Fire Detection and Suppression," of NUREG-1057, Supplement No. 5 titled "Safety Evaluation Report rela ted to the operation of Beaver Valley Power Station, Unit 2," dated May 1987 states: Fire Protection Water Supply System

During the site audit, the applicant stated t hat fire hydrant 16, located at the southwest corner of the turbine building, was reloca ted because it interfered with the installation of the auxiliary boile r and the security perimeter fence, thus providing a 370-foot spacing indicated in Section C.6.

b(7) of BTP CMEB 9.5-1.

The area was observed during the audi t and coverage for nearby hazards appeared adequate. Therefore, the spacing between hydrants 15 and 16 is an acceptable deviation from the SRP.

The explicit prior approval from Licens ing Action 26, "Fire Detection System Secondary Power Supplies - Use of Plant Emergency Power Supply - BTP Attachment L-15-150 Page 39 C.6.a(6)" is for fire detec tion power supply system. The following licensing excerpt below the associated fire compartment attribute list applies: NFPA 805 Section 3.8.1, Fire Detection Power Supply System Section 9.5.1.5, "Fire Detection and Suppression," of NUREG-1057, Supplement No. 6 titled "Safety Evaluation Report rela ted to the operation of Beaver Valley Power Station, Unit 2," dated August 1987 states:

Fire Detection A fire detection system is provided for all areas containing safety-related equipment and for all areas that present a fire exposure to safety-related equipment.

The system complies with NFPA [Standard] 72D for a Class A system, with detectors installed in accordance with NFPA [Standard] 72E.

By letter dated May 23, 1984, the applic ant committed to provide a reliable power supply for the fire detection system as follows:

(1) The primary supply for the fire detection system and suppression systems is the normal offsite power supply system.

(2) The secondary supply for the fire detection systems is a non-safety diesel generator. The switchover capability is an automatic function. The diesel generator supplies the 120-V ac [Volts alternating current] uninterruptible power supply system required for the detection system and the 125-V dc [Volts direct current] panels for the fire detection and suppression systems.

(3) A battery backup system with a 2-hour rated capability is provided as a backup to the 125-V dc systems.

A battery backup system with a 30-minute capability is provided as a backup to the 120-V ac systems. This is to provide electrical pow er continuity for the 10 seconds required to start the diesel and achieve rated voltage and frequency.

The staff finds this an acceptable primary and secondary source of power.

On the basis of its evaluati on, the staff concludes that the fire detection system will meet Section C.6.a of BTP CMEB 9.5-1 and is, therefore, acceptable. The explicit prior approval from Licensi ng Action 29, "Standpipe and Hose Systems - Class II versus Class III Requirement - BTP C.6.c" is for t he hose station system designed similar to a Class II type standpi pe and hose system, in that it has 1.5"-

size hose valves only, and does not have 2.5"-size hose valves as required for Class III systems. The following licensing excerpts below the associated fire compartment attribute list apply:

Attachment L-15-150 Page 40 NFPA 805 Section 3.6.1, Standpipe and Hose Systems - Class II versus Class III Requirement The BVPS-2 "Updated Final Safety Analysis Report," BVPS-2 UFSAR, Section 9.5.1.7.3, states that: Compliance with hose rack spacing is me

t. The hose stations are designed for flow of at least 100 gpm through a 1.5" hose. The system is more similar to a Class II type standpipe and hose system in that it has 1.5"-size hose valves only, and does not have 2.5"-size hose valves as required for Class III

systems." Section 9.5.1.5, "Fire Detection and Suppression," of NUREG-1057, Supplement No. 6 titled "Safety Evaluation Report rela ted to the operation of Beaver Valley Power Station, Unit 2," dated August 1987 states: Sprinkler and Standpipe Systems

The wet pipe sprinkler syst ems, deluge systems, and pre-action systems meet the provisions of NFPA [Standard]

13 and NFPA [Standard] 15. The areas equipped with water suppression system s are listed in Table 1 of the applicant's fire protection evaluation report. Each automatic sprinkler system and interior hose standpipe is supplied through separate connections from the yard main or from the internal cross-connections through buildings to ensure that no single failure in the water supply system will impair both the primary and backup fire protection in building

areas. Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve so that groups of sprinkler systems and/or manual hose stations can be isol ated without interrupt ing the supply to other sprinkler systems and manual hose stations connected to the same header. On the basis of its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordanc e with Section C.6.

c of BTP CMEB 9.5-1, and are, ther efore, acceptable. Manual hose stations are located th roughout the plant in accordance with NFPA [Standard] 14. Standpi pe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The staff concludes that the design of the standpipe system piping meets Section C.6.c of BTP CMEB-9.5-1, and is, therefore, acceptable.

Attachment L-15-150 Page 41

Where fire doors are not code compliant, su ch as a door in a fire barrier that

separates a fire compartment from a st airwell, or doors t hat have been modified from the tested configuration, a performance based analysis of VFDR BV1-3120 and VFDR BV2-1633 resolves the fire door rating. This applies to the below fire compartment attributes: Fire Compartment 1-CV-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-CV-2 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-MS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-NS-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-PA-1E Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-PA-1G Attribute 3.11.3 - Fire Barrier Penetrations Fire Compartment 1-TB-1 Attribut e 3.11.3 - Fire Barrier Penetrations Fire Compartment 2-S-1 Attribute 3.11.3 - Fire Barrier Penetrations

A revision to the LAR for items changed in this response will be provided in a future

submittal.

Response:

The response to NFPA 805 Section 3.4.2 compliance basis discussion of "Will Comply with the Use of Commitment" will be revised to clarify that the updates to the pre-fire plans will comply with the requirement in NFPA 805 Section 3.4.2.

The phrase "meet the intent of this" will be removed in Section 3.4.2 and replaced with "comply with." Additionally, a reference to LAR Attachment S, Table S-3 Action Item BV1-2371 for changes to pre-fire plans at both units will be added to the Compliance Basis. A revision to the LAR Attachment A, Table B-1, A1 record 3.4.2 for this changed item will be provided in a future transmittal.

Attachment L-15-150 Page 42

Response:

A review was performed of the BVPS LAR Atta chment S, Table S-3, "Implementation Items." Within the table below, the implementa tion item is listed, the applicable unit as submitted in the LAR, and the description to clarify which item is being reviewed.

Where the unit as listed in t he submitted LAR does not require revision, the "Change to Unit" column is listed as "None." W here changes are recommended, a clarifying explanation is provided.

Updates to LAR Attachment S, Tables S-2 and S-3 will be provided in a future submittal.

LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV1-0714 1 Complete Penetration Seal Database None BV1-1624 1 Update Calculation 8700-DEC-3574, Circuit Failure

Task 9 None BV1-1633 1 Update Uncertainty & Sensitivity Analysis None There is a separate item

for BVPS-2 (BV2-1580) BV1-2358 1 Develop the BVPS-1 Fire Safety Analysis (FSA)

None Attachment L-15-150 Page 43 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV1-2360 1 Update [fire protection plan, or] FPP procedures to reflect power block areas listed in

Attachment I 1 & 2 Procedures are common to both

units BV1-2371 1 Update fire brigade pre-fire plans and training materials 1 & 2 Procedures are common to both

units BV1-2706 1 Track NRC Correspondence on the open CT secondary

issue and evaluate their

conclusions as they pertain

to BVPS-1 and BVPS-2 and Update 2701.620-000-025, Revision A, "Current

Transformer Investigation for

Beaver Valley Power Station" None There is a separate item

for BVPS-2 (BV2-1020) BV1-2823 1 Update administrative process/engineering controls

to address future installation

of wiring above a suspended

ceiling in accordance with NFPA 805 1 & 2 Wiring above suspended

ceilings is

common to both

units. BV1-2825 1 Beaver Valley [non-power operation, or] NPO

Implementation Plan 1 & 2 NPO implementation

procedures are

common to both

units BV1-2826 1 Document results of walk down that was performed

inside BVPS-1 reactor

containment to evaluate fire

detector spacing None BV1-2828 1 Revise procedure 1OST-33.13B, Deluge Valve Fire

Protection System

Instrument Test, to define

actuation criterion None Attachment L-15-150 Page 44 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV1-2833 1 Update the Fire Protection Program Change Evaluation

associated with the hydraulic

calculation for fire protection

system water supply 1 & 2 Fire protection system water

supply is

common to both

units. BV1-2902 1 Procedure update 1/2-ADM-1901 to add reference to NFPA 805 1 & 2 The procedure is common to

both units. BV1-2903 1 Procedure update 1/2-ADM-1902 to meet requirements

of NFPA 805 1 & 2 The procedure is common to

both units. BV1-2904 1 Procedure update 1/2-ADM-1903 to add reference to NFPA 805 1 & 2 The procedure is common to

both units. BV1-2905 1 Procedure update 1/2-ADM-1904 to enhance

combustible controls

program 1 & 2 The procedure is common to

both units. BV1-2906 1 Procedure update 1/2-ADM-1905 to enhance

combustible controls

program 1 & 2 The procedure is common to

both units. BV1-2907 1 Procedure update 1/2-ADM-1906, PIPS-M16 to meet

requirements of NFPA 805 1 & 2 The procedure is common to

both units. BV1-2908 1 Procedure update 1/2-ADM-1900 to enhance controls of

flammable gas 1 & 2 The procedure is common to

both units. BV1-2909 1 Procedure update 1/2OM-56B.4A.A to enhance

controls of combustible liquids 1 & 2 The procedure is common to

both units. BV1-2974 1 Verify the Reported Change-in-Risk Upon Completion of

probabilistic risk

assessment, or PRA-

Credited Implementation Items 1 & 2 This verification must be done

for both units.

Attachment L-15-150 Page 45 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV1-2975 1 Fire Protection Safe Shutdown Response Procedures must be updated

for NFPA 805

implementation None There is a separate item

for BVPS-2 (BV2-1365). BV1-2989 1 Beaver Valley will implement a Fire Protection Monitoring

Program in accordance with the NRC approved version of

[frequently asked question, or] FAQ 10-0059 1 & 2 The monitoring program will be

common to both

units. BV1-3018 1 Procedure updates associated with NFPA

Standard 30 requirements 1 & 2 The affected procedures are

on both units. BV1-3019 1 Establish a minimum set of qualification criteria for

proficiency associated with

fire brigade qualifications 1 & 2 Brigade qualifications

are common to

both units. BV1-3020 1 Fire Brigade Procedure changes related to NFPA

Standard 600 requirements 1 & 2 Affected procedure is

common to both

units. BV1-3026 1 Procedure update related to NFPA Standard 20

requirements. 1 & 2 Affected procedure is

common to both

units. BV1-3027 1 BVPS-1 and BVPS-2 LAR Attachment G implementation activities 1 & 2 Applicable to both units. BV1-3041 1 Update fire barrier surveillance procedures to

include newly defined fire compartments None BV1-3060 1 Review and Update [human reliability analysis, or] HRA

once Final Fire Procedures

are written 1 & 2 HRA review is applicable to

both units.

Attachment L-15-150 Page 46 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV1-3065 1 New NFPA 805 Control Procedures and Processes 1 & 2 Fire protection program procedures are

common to both

units. BV1-3066 1 Maintaining appropriate compensatory measures 1 & 2 Compensatory measures affect

both units. BV2-0362 2 Update procedures to enhance guidance on

containment and monitoring

of potentially contaminated

fire suppression water None BV2-0487 2 Update the CO2 flow and time criteria for 2-CV-6 None BV2-0619 2 Develop the BVPS-2 Fire Safety Analysis (FSA)

None BV2-1020 2 Track NRC Correspondence on the open [current transformer, or] CT

secondary issue and

evaluate their conclusions as

they pertain to BVPS-1 and

BVPS-2 and Update

2701.620-000-025, Revision

A, "Current Transformer

Investigation for Beaver

Valley Power Station" None There is a separate item

for BVPS-1 (BV1-2706) BV2-1022 2 Perform Procedural Enhancements to Pre-fire Plans for 2-DG-1, 2-DG-2 Control Circuits Vent Fans None BV2-1157 2 Plant Boundary Definition and Partitioning Document

will be enhanced to provide

additional detail 1 & 2 The plant boundary definition and

partitioning

document is

common to both

units.

Attachment L-15-150 Page 47 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV2-1166 2 Minor documentation updates to BVPS-1 and

BVPS-2 Control Room Fire

Model Analyses 1 & 2 Applicable to both units. BV2-1169 2 Minor Documentation Updates to BVPS-1 and

BVPS-2 Structural Steel Reviews 1 & 2 Applicable to both units. BV2-1182 2 Minor Documentation Update to Task 13, Seismic Fire Interaction Reviews 1 & 2 Documents for both units are

affected. BV2-1294 2 Updates to Task 9 Calculation (10080-DEC-

3575) None BV2-1314 2 BVPS-2 procedure update 2OST-33.13I to include heat

detection activation time None BV2-1345 2 Procedure revision to include fire door OS52-21 inspection

verification 1 & 2 Affected procedure is

common to both

units. BV2-1365 2 Fire Protection Safe Shutdown Response Procedures must be updated

for NFPA 805 implementation None There is a separate item

for BVPS-1 (BV1-2975)

BV2-1369 2 Hydraulic calculations need reconstituted for the water-spray systems in 2-PA-3, 2-RC-1, 2-SG-1N, and 2-SG-

1S 1 & 2 Hydraulic Calculation is applicable to

both units. BV2-1372 2 BVPS-2 procedure update 2OST-33.21 to include heat

detector activation time None BV2-1566 2 Add caution statement to Pre-Fire Plan for fire hose in

2-SB-4 None BV2-1570 2 Hydrogen signage update needed for NFPA Standard

55 requirements None Attachment L-15-150 Page 48 LAR Table S-3 Implementation Items: Item Unit (as submitted in LAR) Description Change to Unit Explanation BV2-1576 2 Update fire barrier surveillance procedures to include newly defined fire compartments None BV2-1580 2 Update Uncertainty and Sensitivity Analysis Task 15 None There is a separate item

for BVPS-1 (BV1-1633)

Response:

The lack of a lube oil collection system in mi sting areas satisfies the nuclear safety performance goals, performance objective s, and performance criteria because redundant reactor coolant pumps exist that are separated from each other by reinforced concrete walls. The reactor coolant pumps are not required for post-fire safe shutdown.

Therefore, the lack of a lube oil collection system in misting areas will not adversely impact the ability to achieve and main tain a safe and stable condition.

LAR Attachment L, Approval Request 2 will be revised to describe how the lack of a lube oil collection system in misting areas satisfies the nuclear safety performance Attachment L-15-150 Page 49 goals, performance objectives, and perfo rmance criteria of NFPA 805 and how the configuration maintains safety margins and each element of fire protection defense-in-depth (DID).

The following explanation will be added to the nuclear safety and radiological release performance criteria section:

The nuclear safety performance criter ia are met because redundant reactor coolant pumps (RCPs) are available as necessary and the RCPs are not

required to achieve or maintain post-fire safe shutdown.

The following explanation will be added to t he safety margin and defense-in-depth section:

The three echelons of DID are:

(1) Prevent fires from starting (c ombustible/hot work controls);

(2) Rapidly detect, control and extingu ish fires that do occur, thereby limiting damage (fire det ection systems, automatic fire suppression, manual fire suppression, pre-fire plans);

(3) Provide adequate level of fire protection for systems and structures so that a fire will not prev ent essential safety functions from being performed (fire barriers, fire rated cable, su ccess path remains free of fire damage, recovery actions).

Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided.

Echelon 1 is maintained by the o il collection system and by the reactor coolant pump design, and is not affe cted by this configuration. The introduction of small amounts of oil misting does not affect Echelons 2 and

3. The oil misting does not result in compromising fire detection, automatic or manual fire suppression functions, or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved.

An update to LAR Attachment L for this approval request will be provided in a future

submittal.

Attachment L-15-150 Page 50

Response:

The lack of sectional isolation valves between the sprinkler system and hose station

connections satisfies the nuclear safety performance goals, performance objectives, and performance criteria because existing co mpensatory measures ensure there is no impact on the ability to detect and suppress fire s if sections of fire protection water supply piping are isolated.

LAR Attachment L, Approval Request 3 will be revised to describe how the lack of sectional isolation valves between the sprinkler system and hose station connections satisfies the nuclear safety perform ance goals, performance objectives, and performance criteria of NFPA 805 and how the configuration maintains each element of fire protection DID.

The following explanation will be added to the nuclear safety and radiological release performance criteria: Compensatory measures, such as equivalent capacity backup fire hose

protection to restore suppression c apabilities, and establishment of fire surveillance within the related area, ens ure that there is no impact on the ability to detect and suppress fires.

Addition of sectionalizing valves to separate the hose stations from the sprinkler systems in an area would not significantly improve the radiological release performance criteria or the nuclear safety performance criteria.

The following explanation will be added to the defense in depth discussion:

The three echelons of DID are:

(1) To prevent fires from starti ng (combustible/hot work controls)

(2) Rapidly detect, control and extingu ish fires that do occur, thereby limiting damage (fire det ection systems, automatic fire suppression, manual fire suppressi on, pre-fire plans)

(3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, su ccess path remains free of fire damage, recovery actions).

Attachment L-15-150 Page 51 Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided.

Echelon 1 is met throu gh plant fire prevention procedures and is not affected by this configuration. Ec helons 2 and 3 are met in performance evaluations through appropriate com pensatory measures, such as the

readiness of additional fire hose to reach the affected areas, and fire surveillances. The fire brigade is trained to rapidly respond to and extinguish fires with the tools provi ded to them, which include a standpipe and hose system. The lack of sectional is olation valves does not result in compromising fire suppression functi ons or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved. An update to LAR Attachment L for this approval request will be provided in a future

submittal.

Response:

LAR Attachment L, Approval Request 4 will be revised to describe how the lack of electrical supervision for fire hydrant cu rb box type control valves will satisfy the radiological release performance goals, performance objectives, and performance criteria of NFPA 805.

For the nuclear safety and radiological release performance criteria section, BVPS has implemented administrative control for periodic surveillance of the box curb valves. The inaccessibility of the curb box valves, the required usage of a special T-wrench, and periodic surveillance by trained and authorized personnel ensures that the nuclear safety and radiological release perfo rmance goals, performance objectives, and

performance criteria ar e not affected.

For the safety margin and defense-in-depth section, additional details will be provided to clarify how safety margin has been preserved.

Echelon 1 is not affected since it entails plant procedures. Echelons 2 and 3 are met si nce the curb box valves do not adversely affect the system pressure or flow nor compromise fire suppression functions, manual

fire suppression functions, or post-fire safe shutdown capability.

Attachment L-15-150 Page 52 An update to LAR Attachment L for this approval request will be provided in a future

submittal.

Response: e) The credit taken for the VEWFDS is in accordance with the simplified event tree as described in FAQ 08-0046.

f) In the letter dated April 27, 2015 (ADAMS Accession No. ML15118A484), the response to FPE RAI 15a stated that t he VEWFDS will be connected to interface with the Control Room annunciation system, and that LAR Attachment S, Table S-2 will be revised to add this modification for both BVPS-1 and BVPS-2. Code compliance reports will be completed throughout the modification process, however, compliance of the VEWFDS with respect to NFPA 805 section 3.8

cannot be described until the detailed design is complete.

As the modification design is not complete at this time, t here are no changes to LAR Attachment A.

Attachment L-15-150 Page 53

Response:

An engineering evaluation compared the BVPS ERFBS configuration to actual fire endurance tests performed in accordance wit h GL 86-10 Supplement 1 and determined the BVPS configuration to be equivalent to a 1-hour fire rating. The fire severity in 1-PA-1E and 1-PA-1G is less than the 1-hour fire endurance rating applied to the ERFBS.

The LAR Attachment A Table B-1 Section 3.11.

5 records for fire compartments 1-PA-1E and 1-PA-1G will be updated with the above info rmation to clarify how the ERFBS meets the requirements of NFPA 805 section 3.11.5.

An update to LAR Attachment A, Table B-1 will be provided in a future submittal.

Attachment L-15-150 Page 54

Response:

Fire protection on ductwork is not considered an ERFBS, as ERFBS is referring to fire protection of electrical raceways. Fire pr otection on ductwork is considered fire barrier protection and is covered under the 3.

11.2 "Fire Barrier" records.

An EEEE analyzed the use of the 3M Intera m E-50 series blanket materials as fire barriers to protect ductwork and dampers and concluded that the installed

configurations are equivalent to a 1-hour fire rating re sistance for the ductwork and a 2-hour fire rating resistance for the specific fire dampers.

LAR Attachment A, Table B-1, Section 3.11.5 records for fire compartments 2-CB-1, 2-CV-1, 2-CV-3, 2-PA-3, 2-PA-4, 2-SB-3, and 2-SB-4 will be revised to delete references to fire barriers for ductwork.

LAR Attachment A, Tabl e B-1, Section 3.11.2 records for fire compartment 2-CB-1 will be revised to include the results of the engineering evaluation regarding fire barriers for ductwor

k. The Table B-1, Section 3.11.2 records for fire compartments 2-CV

-1, 2-CV-3, 2-PA-3, 2-PA-4, 2-SB-3, and 2-SB-4 already include the engineering evalua tion regarding fire ba rriers for ductwork.

An update to LAR Attachment A, Table B-1 will be provided in a future submittal.

Response:

ERFBS installed on conduits at BVPS-2 originally consisted of Thermo-Lag 330-1 pre-shaped conduit sections having 0.50 inch nominal thickness with buttered joint

construction. Following Generic Letter (G L) 92-08, "Thermo-Lag 330-1 Fire Barriers,"

and GL 86-10 Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier Attachment L-15-150 Page 55 Systems Used to Separate Safe Shutdown Trains Within t he Same Fire Area," fire endurance testing results were used to establish the fire endurance rating of Thermo-Lag 330-1 installation configurations. The fire endurance tests were conducted in accordance with GL 86-10 Suppl ement 1. The Thermo-Lag ERFBS(s) at BVPS-2 were modified, consistent with the i ndustry test program results, in order to achieve a 1-hour fire rating. The modificati ons included the addition of 3/8 in ch thick pre-formed conduit sections, stress skin, and The rmo-Lag trowel grade material over the existing conduit sections for conduits 1-1/2 inch to 2 inch in diameter, and the additi on of stress skin with Thermo-Lag trowel grade material for condui ts 3 inch to 6 inch in diameter.

An engineering evaluation performed an analysis of each section of protected conduit in comparison with the fire endurance test results and determined that the installed ERFBS meets the acceptance criteria of Section 3.11.5 of NFPA 805 (NRC GL 86-10 Supplement 1).

Response:

The BVPS ERFBS uses several configurat ions in fire area 2-PA-4. Some configurations "Comply" by meeting an act ual fire endurance test and some "Comply with the Use of EEEE," engineering evaluations for specific configurations determined that the ERFBS in 2-PA-4 is equivalent to a 1-hour fire rating.

Previous NRC approval does not apply.

LAR Attachment A, Table B-1 Section 3.11.5 record for fi re compartment 2-PA-4 will be corrected to delete the "Complies by previous NRC approval" statement. An update will

be provided in a future submittal.

Attachment L-15-150 Page 56

Response:

A review of the Alignment Statements in LAR Attachment B, Table B-2 was performed to determine that the a lignment statement s that included "Not in Alignment, but Prior NRC approval" or "Not in Alignment with no adverse consequences" have been addressed. The re view concluded that the following attributes utilize these compliance statements:

3.1.1.9 -72 hour Coping Period, 3.1.2.4 - Decay Heat Removal, 3.1.2.5 - Process Monitoring, and 3.2.2.1 - Identify the System Flow Path for Each Shutdown Path LAR Section 4.2.1.1 will be revised to include the following information:

3.1.1.9 - 7 2 h o ur C o ping P e ri o d The 72-hour coping period, as defined in NEI 00-01 section 3, is not applicable to plants transitioning to NFPA 805. As described in FAQ 07-0039, NFPA 805 does not require Attachment L-15-150 Page 57 cooldown to cold shutdown. The assessment of accomplishment of performance goals should document the equipment required to achieve a safe and stable plant condition in accordance with NFPA 805 Section 1.3.

Safe and stable conditions for BVPS-1 and BVPS-2 are to maintain the plant in hot standby up to the point at which the residual heat removal (RHR) loop is placed into service as discussed in LAR section 4.2.

1.2. NFPA 805 analysis determined that the plant no longer is required to reach cold shutdown as noted in NEI 00-01, section

3.1.1.9. Cold shutdown was previously required by 10 CFR 50, Appendix R. Based on this NFPA 805 analysis, there ar e no adverse consequences.

3.1.2.4 - D ec ay H e at R e m o val Decay heat is removed by use of a natural circulation cooldown and steam release via the main steam safety valves and manual op eration of atmospheric dump valves or residual heat removal. Auxiliary feed water (AFW) is credited to supply cooling water to the steam generators.

As described in FAQ 07-0039, NFPA 805 does not require cooldown to cold shutdown. The assessment of accomplishment of performance goals should document the equipment required to achieve 'a safe and st able' plant condition in accordance with NFPA 805 section 1.5. Through 'safe and st able' plant operation per the requirements of NFPA 805, decay heat will be removed using systems analyzed and procedures developed to support this transition. Alt hough the requirements of NEI 00-01 section 3.1.2.4 for cold shutdown are not met, the new requirem ent associated with NFPA 805 is satisfied so there are no adverse consequences.

3.1.2.5 - Pr ocess M o ni tor in g Process monitoring instrumentation required to achieve and maintain a safe and stable plant condition post-fire is identified in LA R Attachment C, NEI 04-02 Table B-3, "Fire Area Transition." This instrumentation is consistent with minimum process monitoring instrumentation expectations identified in NRC Information Notice (IN) 84-09, "Lessons Learned from NRC Inspections of Fire Protec tion Safe Shutdown Systems (10 CFR 50, Appendix R)" and as described in the licensing bases for BVPS-1 and BVPS-2. The process monitoring instrumentation described below either a ligns with IN 84-09, or has prior NRC approval. This instrumentation includes:

Pressurizer pressure and level: In support of the inventory and pressure control nuclear safety per formance criteria (NSPC) for pressurizer pressure, both units evaluate pressurizer level. BVPS-1 has exemption 11.24 to permit the use of Reactor Coolant System (RCS) pressure as an acceptable substitute. BVPS-2 evaluates the availability of pressurizer pressure.

Attachment L-15-150 Page 58 Reactor coolant temperature (T-hot /

T-cold): In suppor t of the decay heat removal NSPC for both units, T-hot is evaluated for the availability of either hot leg temperature indicators or incore thermocouples. T-cold is evaluated for the availability of T-cold temperat ure elements and the T-cold temperature recorder.

Steam generator (SG) level and pre ssure: In support of the decay heat removal NSPC, BVPS-1 has exemption 11.24 to permit the use of narrow range steam generator level instrumentation. SG wide range pressure instruments are evaluated for availabili ty after a fire. BVPS-2 evaluates availability of wide range SG pressure and wide range SG level, as well as narrow range SG level.

Neutron flux monitoring (source range): In support of the reactivity control NPSC, BVPS-1 has exemption 11.24 to have a source range monitor

operational within 80 minutes af ter the reactor is tripped in the event of a fire.

BVPS-2 evaluates the availability of the source range detectors after a fire.

Water level indication for the refue ling water storage tank (RWST) and the primary plant demineralized water t ank are not provided at the backup indicating panel (BIP) for BVPS-1 or at the alternate shutdown panel (ASP) for BVPS-2. This does not meet the requirements of Section 3.1.2.5 of NEI 00-01. However, each tank is of suffici ent capacity that level monitoring is not critical to safe shutdown functions. This configuration was previously approved for BVPS-1 by letter dated January 5, 1983 from the NRC, and previously approved for BVPS-2 in section 9.5.1.4 General Plant Guidelines" of NUREG-1057 Supplement 5.

3.2.2.1 - Id e nt i fy t h e Sy s t e m Fl o w Pa t h fo r Ea c h Shu tdown Path The BVPS-1 and BVPS-2 NFPA 805 safe shutdown analysis interim transition report, Attachment 1, "Safe Shutdown Perf ormance Goal and System Logic Model Description" describe the systems that are required for post-fire safe shutdown.

The "Post-Fire SSD and PRA and Component Selection" procedure describes the methodology and documentation requirements a ssociated with selection of post-fire safe shutdown systems and components which utilize process and instrumentation

diagrams (P&IDs) to aid in creating the safe shutdown equipment lists for safe shutdown systems and associ ated support systems.

As part of the NFPA 805 transition, the post-fire safe shut down analysis has been incorporated into a computerized safe shutdown analysis tool, SAF E, which maintains success path models of performance goals, systems, equipment, and cables. The markup and annotation of P&IDs are not required to support the SAFE analysis tool which does not meet the requirements of NEI 00-01 Section 3.2.2.1. Since SAFE Attachment L-15-150 Page 59 software performs the function of the ma rked up P&ID, there are no adverse

consequences.

Changes to the LAR Section 4.2.1.1, "Compliance with NFPA 805 Section 2.4.2" will be provided in a future submittal.

Response:

1) BVPS procedures direct the use of three electrical fans for BVPS-1 emergency switchgear room temporary ventilation, placed within the emergency switchgear rooms. The fans are powered by a gasoline engine-driven portable generator, which is placed in the yard with adequat e separation and isolation from all identified NSCA systems, structures, and components (SSCs).

2) BVPS procedures direct the use of two gasoline engine-driven fans and two electrical fans for BVPS-1 diesel generat or room temporary ventilation. The

electrical fans are powered by a gaso line-driven portable generator. The two electrical fans are placed in the entranc e to the diesel generator number 2 room, while the generator and the gasoline engine-driven fans are placed in the yard outside the diesel building with adequate separation and isolation from all identified NSCA SSCs.

Attachment L-15-150 Page 60

3) Control room temporary ventilation procedures will be developed to direct the placement of one or more electric fans in the doorway from the outside, blowing into the common BVPS-1 and BVPS-2 cont rol rooms, powered from local receptacles. LAR Attachment G will be re vised to specify that the control room portable ventilation will be supplied by electrical fans, and to eliminate the notation of fan capacity. The required capacity will be determined as part of preparing the plant procedures. Revision to LAR Attach ment G, Table G-1 for this changed item will be provided in a future submittal.

Response:

1) Fifteen (15) gallons of gasoline is kept ready for immediate use by the gasoline engine-driven portable generator, which is used to power the electric fans for either the BVPS-1 emergency switchgear rooms or the BVPS-1 diesel generator rooms. This gasoline is stored in the flammable storage cabinet at the BVPS-1 turbine deck and is inventoried periodicall

y. The generator fuel tank has a 4 gallon capacity, which will run the generator for about 4.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, the available gasoline is enough to keep the gener ator running for about 15.75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months . Additional fuel can be readily obtai ned from off-site before it is needed.

2) Five (5) additional gallons of gasoline/oil mixture is kept ready for immediate use by the two gasoline engine-driven fans used to ventilate the BVPS-1 diesel generator rooms. This gasoline is stored in the flammable storage cabinet at the BVPS-1 turbine deck and is inventoried per iodically. Each fan has a one-quart

capacity, which will run the fan for about an hour. Therefore, the available gasoline/oil mixture is enough to keep bot h fans running for about 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . Additional fuel can be readily obtained from off-site before it is needed.

3) No fuel is required for the portable el ectric fans used to ventilate the control room.

Attachment L-15-150 Page 61 Response:

1) The generator powering t he BVPS-1 emergency switchgear fans is located in the yard near the chemical addition buildi ng and is not in close proximity to any NSCA SSCs. Therefore, refueling does not present a fire exposure hazard to adjacent NSCA SSCs.

2) BVPS procedures direct a continuous fi re watch for the gasoline engine-driven portable generator and fans for the BVPS-1 diesel generator room temporary ventilation. Furthermore, the portable generator and the fans are located in the yard outside the door to the diesel generator room number 2, and they are not in proximity to any NSCA SSCs. Therefore, refueling does not present a fire exposure hazard to adjacent NSCA SSCs.

3) Refueling is not required for the portable electric fans used to ventilate the control room.

Response: 1) Per BVPS procedures, t he BVPS-1 emergency switchg ear room temporary ventilation flow path is provided by blocking open doors. One fan is placed in each of the two rooms, directing the hot air towards the third fan placed in the doorway to the normal switchgear room.

The third fan exhausts through an outlet duct hose routed through the norma l switchgear room to establish sufficient exhaust flow up the stairwell in to the clean shop. Service building roof dampers are opened to allow the hot air to escape the building. Cool air from outside flows into the emergency switc hgear rooms through doors blocked open for the electrical cords.

2) Per BVPS procedures, the BVPS-1 diesel g enerator room temporary ventilation flow path is provided by blocking open t he security access doors to both rooms and the two doors between the rooms. The four fans are arranged in or just outside the security door for the operating diesel generator room door. Each fan is equipped with an "elephant trunk" led insi de the room. Cool air from outside flows across the operating diesel generator, through t he connecting doors, across the idle diesel generator and out the open security access door for the idle diesel generator room.

Implementation item BV1-2975 in LAR Attachment S, Table S-3 will develop a temporary vent ilation procedure for diesel generator number 1 when it is operating, similar to the existing procedures for diesel Attachment L-15-150 Page 62 generator number 2.

3) Implementation items BV1-2975 and BV2-1365 in LAR A ttachment S, Table S-3 will develop control room temporary vent ilation procedures to specify the required flow path, with supporting calculations as necessary. It is anticipated that this will require opening two exterior doors to the ya rd such that cool air is blown in through one door, flows across the control rooms for both units, and hot air

exhausts out the other door.

Response:

LAR Attachment G describes a number of recovery actions that involve implementing repair procedures on valves that have been im pacted by a combination of fire-induced

and random failures.

Attachment L-15-150 Page 63 The repair recovery actions listed in Attachment G were reviewed. Recovery actions associated with repairs are DID recovery acti ons and are not credited in the fire PRA.

As such, these repairs are not required to be documented in Attachment G and will be removed. A revision to LAR Attachment G, Table G-1, and Attach ment C, Table B-3, for these deleted and changed items will be provided in a future submittal.

Response:

As specified in part a) above, recovery acti ons associated with repairs are DID recovery actions and are not credited in the fire PRA. As such, these repairs are not required to be documented in Attachment G and will be remo ved. A revision to LAR Attachment G, Table G-1, and Attachment C, Table B-3, for these deleted and changed items will be provided in a future submittal.

Attachment L-15-150 Page 64

Response:

LAR Attachment C, Table B-3 wa s incorrect, and VFDR BV2-0411 will be removed from this table in a future submittal.

Attachment L-15-150 Page 65

Response:

BVPS has a procedure in place for fires in radiological controlled areas (RCAs). The procedure specifies corrective and protective measures to minimize the radiological consequences of the fire or t he fire-fighting efforts. In order to minimize creation of large quantities of contaminated water and potent ial contamination of adjacent areas by runoff, use of carbon dioxide, dry chemical, or similar non-water extinguishing agents are instructed to be used. A radiation protection technician will also accompany the fire brigade to continuously monitor the radi ation dose rate and make exposure and contamination control recommendations.

LAR Attachment S, Table S-3 item BV1-2371 will update the yard pre-fire plans to specify procedural controls such as the use of carbon dioxid e or dry chemical extinguishing agents, which is consistent with current procedures, and to consider the use of engineering controls such as tem porary damming to contain potentially-contaminated fire suppression water runoff if water is needed for fire suppression.

Attachment L-15-150 Page 66 Response:

The screening of radiological areas was initia lly performed by the radioactive release report preparer and reviewer. The report pr eparer was an engineer with more than 30 years of experience at BVPS, which included increasing responsibilities for engineering and oversight of the BVPS fire protection program. The report reviewer had more than 30 years of experience as a pr ofessional grade member of the Society of Fire Protection Engineers, and 29 years nuclear power plant experience as a fleet lead fire protection

engineer and fire protec tion program owner.

Subsequent report updates were produced and reviewed by individuals whose qualifications include senior reactor operators, and electr ical and licensing engineers.

Attachment L-15-150 Page 67

Response: A review of installed cable insulation and jacket materials was performed at BVPS to determine the type (that is, thermoset or thermoplastic) in order to estimate the appropriate cable time to ignition, HRRPUA, and flame spread rate. When information

regarding the insulation or jacket material was not readily available, the cable was conservatively considered thermoplastic.

Attachment L-15-150 Page 68 In all cases, where the cable material revi ew indicated any thermoplastic cables were present, the cable raceway (cable tray) was conservatively assumed to be thermoplastic when determining the time to ignition, HRRPU A and/or spread rate. No mass-weighted average approach was used for cable trays.

The ignition criteria for thermoset and thermoplastic cables provided in NUREG/CR-6850, Appendix H, Table H-1, were used for estimating ignition time for the first tray in the stack. S ubsequent ignition timing of additiona l cable trays in the stack or adjacent stacks is consistent with or more co nservative than the timing rules in section R.4.2.2 of NUREG/CR-6850 and section 9.

2.1 of NUREG/CR-7010.

NUREG/CR-6850, Appendix R prov ides cable tray properties and guidance on determining the HRRPUA and spread rate for both thermoset and thermoplastic cable

trays. For most areas, BVPS fire modeling analyses use the NUREG/CR-6850 spread rates and the most conservative NUREG/CR-6850 Table R-1 bench scale HRRPUAs (adjusted using the Lee correlation, shown in the table below) for each cable type in the fire growth analysis for cable trays.

For some risk-significant fire scenarios, subsequent fire modeling refinements utilize the refined HRRPUAs recommended by NUREG/CR-7010, "Cable Heat Release, Ignition, and Spread in Tray Installations During Fire (CHRISTIFIRE) - Phase 1: Horizontal Trays" (as shown in the table below).

Table FM RAI 01d: Cable Tray HRRPUA Thermoset Thermoplastic/Unknown NUREG/CR-6850 214 kW/m 2 270 kW/m 2 NUREG/CR-7010 150 kW/m 2 250 kW/m 2 The recommendations of NUREG/CR-7010 allow for the flame spread rate of the predominant cable type to be used for trays with a mixture of thermoplastic and thermoset cables. However, for BVPS, FE NOC conservatively treated trays containing any thermoplastic cable as thermoplasti c raceways for the purpose of flame spread rate.

Attachment L-15-150 Page 69

Response:

Transient fires were evaluated based on the 98 th percentile HRR specified in NUREG/CR-6850, "EPRI/NRC-RES Fire PR A Methodology for Nuclear Power Facilities," Table G-1, except in fire compartments 1-CR

-4, 1-CS-1, 2-CB-1, 2-CB-6, 2-CV-1, 2-CV-3, and 2-SB-3 which ut ilized reduced transient HRRs.

The 98 th percentile HRR for transient fires listed in NUREG/CR-6850, Table G-1 is based on tested fuel package configurations identified in NUREG/

CR-6850, Table G-7.

The configurations tested are various solid fuel packages such as cardboard, paper, plastics, cotton rags, and acetone. The m odel assumptions regarding location and HRR of transient combustibles in a fire ar ea or zone will not be violated due to BVPS procedure requirements that paper, cardboar d, scrap wood, rags and other trash combustibles shall not be allowed to accumula te in any critical building or location except in metal containers with approved fire suppressive lids.

The guidance provided in the June 21, 2012 me mo from Joseph Giitter to Biff Bradley

("Recent Fire PRA Methods review Panel De cisions and EPRI 1022993, 'Evaluation of Peak Heat Release Rates in Electrical Cabinets Fires'," ADAMS Accession No.

ML12171A583) allows the user to choose a lower screening HRR for transient fires in a fire compartment based on "the specific attri butes and considerations applicable to that location." The guidance indicates that "p lant administrative controls should be considered in the appropriate HRR for a postulated transient fire" and that "a lower screening HRR can be used for individual plant spec ific locations if the 317 kW value is judged to be unrealistic given the specific a ttributes and considerations applicable to

that location."

Walkdowns were performed and the room usage and contents were considered when prescribing the transient HRR. This provided assurance that the HRRs used for the transient scenarios, modeled in the fire PR A, would be an appropriate representation of any potential transient fire in the area. All areas w here a reduced transient HRR is utilized are safety related areas and are therefore regulated by the BVPS transient control program. The combi nation of transient controls and expected room usage and

contents allow for an appropriate reduced tr ansient HRR to be selected as follows.

In fire compartments 1-CR-4, 2-CB-1, 2-CV-1, and 2-CV-3, t he 75th percentile transient HRR (142 kW) was used for the majority of transient fire scenarios. The HRR is reduced in these fire compartments for fire scenarios based on the following criteria:

Attachment L-15-150 Page 70 Large combustible liquid fires are not expected in the areas represented by the reduced HRR transient fire scenarios, si nce activities in these areas do not include maintenance of oil containing equipment. Any portion of a fire

compartment where oil containing equipment is present (for example, 2-CV-3) will continue to utilize a 317 kW transient fire.

The materials composing the fuel packages included in Table G-7 of NUREG/CR-6850 are not represent ative of the typical materials expected to be located in these areas. Untreated wood (typically prohibited at nuclear power plants), airline trash bags with over 2 kg of paper products or over 4 kg of straw, grass, or eucalyptus duff are unlikely to be present in 1-CR-4, 2-CB-1, 2-CV-1, or 2-CV-3. Since fires that are not bounded by the tests are not expected to occur in fire compartments 1-CR-4, 2-CB-1 , 2-CV-1, or 2-CV-3, the 75th HRR was deemed appropriate for use.

In fire compartments 1-CS-1 , 2-CB-6, and 2-SB-3, a 69 kW transient HRR was used for all transient fires. In addition to the justification provided above, a transient HRR may be further refined to 69 kW for select fire compartments based on t he following criteria:

A transient fire in an area of strict combustible controls, where only small amounts of contained trash are consider ed possible, is judged to be no larger than the 75 th percentile fire in an electrical cabinet with one bund le of qualified cable.

A review of the transient ignition source tests in Table G-7 of NUREG/CR-6850 indicates that of the type of transient fi res that can be expected in these rooms (polyethylene trash can or bucket cont aining rags and paper) were measured at peak heat release rates of 50 kW or below.

Administrative controls were enhanced in fire compartments 1-CR-4, 1-CS-1, 2-CB-1, 2-CV-1, and 2-SB-3 to limit combustible transi ent material within the fire compartment by designating these compartments as "Tr ansient Combustible Exclusion Areas." Exclusion areas have localized visual warnings such as red painted floor areas or other signage such as marked floor ma ts at room entrances and ex its, indicating transient combustibles are not permitted.

Fire compartments 2-CB-6 and 2-CV-3 will be designated as "Transient Combustible Exclusion Areas" as part of LAR Attachm ent S, Table S-3, Implementation Item BV1-2907 in a future submittal.

Additionally, condition reports dated bet ween May 30, 2014 and April 10, 2015 identifying violations of transient combus tible and flammable materials controls were reviewed. The condition reports initiated co rrective actions for these violations, which have been completed. BVPS has escalated the level of concern with the control of transient combustibles, including the requirements of NFPA 805. This includes the Attachment L-15-150 Page 71 added discussion of transient combustibles, transient combustible exclusion areas, NFPA 805, and the importance of fire protection for all site personnel into general access training or plant access training.

Therefore, based on the expected room usage and contents, administrative controls and procedures, transient combustible control program, and training emphasis for all site personnel, it is expected that the HRR selected for transient fire scenarios in the subject fire compartments will not be violated during and post-transition.

Response:

The Consolidated Model of Fire and Smok e Transport (CFAST) was used at BVPS in lieu of the MQH method to provide a better repr esentation of the post-fire conditions in fire compartments with complex or unique geometries and/or ventilation aspects, and to provide additional information not readily available from MQH, such as lower layer gas temperatures and hot gas layer (HGL) heights. The specific uses of CFAST at BVPS are provided below:

CFAST was used for various fire com partments in the tem perature sensitive equipment HGL study to calculate upper and lower gas layer temperatures, and the gas layer heights.

CFAST was used in support of the mult i-compartment analysis to calculate the HGL temperature and layer height in t he exposed fire co mpartments.

CFAST was used to calculate the HGL temperature fo r the bounding fire scenario (that is, fire scenario with the largest HRR) in 1-NS-1. CFAST was utilized because of its ability to calculate upper and lower gas layer temperatures as well as its ability to model unique geometrical configurations and ventilation aspects, such as modeling vents opening at a specific time (for example, door opening at 10 minutes).

Attachment L-15-150 Page 72 The main control room analysis utilized CFAST to calculate the HGL temperature, layer height, and smoke conc entration, in order to determine when the habitability criteria would be reached and thus when abandonment would occur.

Response:

The sprinkler activation correlation was not us ed for transient fires and a transient fire growth profile was not necessary in the sprinkler activation correlation.

Detection timing, for both smoke and heat detectors, was determined using

NUREG-1805 FDT 10 . Using the physical parameters (radial distance from fire source to detector, height of ceiling above the fire source, and ambient temperature) required for each fire scenar io, the minimum fire size required to activate the detector was determined.

If the minimum HRR required to activate the detector was less than the critical HRR evaluated for target damage, then detection may have been credited. In these cases, the time to detection was determined by us ing a standard t² fire growth profile, calculated for each detailed fire scenario.

When utilizing the t² fire growth profile for detection in transient scenarios, the guidance contained in NUREG/CR-6850, Supplement 1, Chapter 17, was used to determine the time to peak HRR of a transient fire. C hapter 17 states that a time-dependent fire growth model is appropriate for any sit uation where the basis of its use can be established. Three categories of transi ent growth profiles ar e provided with their respective times to peak heat release rate:

Attachment L-15-150 Page 73 Common trash can fire (8 minutes).

Common trash bag fire (2 minutes).

Spilled solvents or combusti ble liquids (0 minutes).

The profile that was selected for each transient ignition source was based on administrative controls and the expected c ontents within the compartment. Detection was assumed to occur when the minimum required HRR for detection was reached in the t² fire growth profile.

The delay to detector activation, as calculated by FDT10, was omitted for t² fire growth profiles. The FDT10 activation time assumes exposure to a steady HRR from time zero, with no regard for fire growth. Using a t² fire growth profile, the thermal response of the detector activation is considered to be accounted for, as the fire grows due to heat/smoke exposure. Therefore, no additi onal delay is considered necessary.

Response:

Small vent dimensions are conservative for HGL estimates when using the method of MQH. Plant walkdowns were conducted for eac h fire compartment to confirm that there was a door opening with dimensions of at least 0.

9 meter (m) by 2.1 m.

An exception is fire compartment 1-CV-3 which was modeled with its non-standard-si zed door of 0.9 m by 1.5 m.

Once the fire is detected, fire brigade per sonnel will be dispatc hed to the room and are expected to open a door and perform suppression activities, which would provide the Attachment L-15-150 Page 74 door opening assumed in the fire modeling analys is. Prior to this action, and in the early stages of the fire sc enarios, a single door opening is considered an appropriate representation of the various natural ventilation openings withi n the room (for example, door gaps, HVAC ventilation openings, and so on). This single door opening is representative of the plant conditions and is conservative since most compartments have more than one door and have other natural and mechanical ventilation openings.

Response:

When the algebraic models were implemented for HGL calculations using the MQH method, all vents in the floor or ceiling, or in a wall at or near the ceiling of the compartment were disregarded and instead repr esented by a single door opening. This is considered conservative because the in clusion of these vents would result in additional room cooling and ther efore lower predicted HGL temperatures. Even in fire compartments where the only vent in the fire compartment is at the ceiling (for example, 1-CV-3), the use of a single ve rtical vent is considered acceptable since in reality, the air entrainment from outside the compartment would be considerably reduced and would limit the oxygen supply available for combustion, and reduce the HGL temperature.

The single door opening was assumed open for t he entire duration of the fire, providing an inlet for air, which is considered an appr opriate representation of various natural ventilation openings in the room (for example, door gaps, and HVAC ventilation

openings) in the early stages of t he fire scenarios. It also re flects the actual ventilation area when the fire brigade opens a door to perform suppression activities in the latter stages of the fire scenarios.

Attachment L-15-150 Page 75 Therefore, the method described above is a conservative approach for HGL calculations in compartments with vents in the floor or ceiling, or in a wall at or near the ceiling of the compartment.

Response:

The copier, boxes with paper, and plastic tr ash can have been removed from behind the BVPS-2 vertical main control board (MC B) and placed against the wall near the alternate north MCR entrance. The copier , boxes of paper, and plastic trash can are examples of transient combustibles and the transient fires considered in the MCR abandonment calculations, based on the recommended NUREG/CR-6850 Table E-9 transient fire, would bound fires involving t hese transient combustibles. Further, the abandonment calculation showed a 98 th percentile transient fire (317 kW) would still not lead to abandonment conditions. With the exc eption of the specific issue related to consideration of loose trash fires in the MCR being addressed in FM RAI 01(j)(ix) (response to be submitted at a later date), the transient fires considered in the MCR abandonment calculations are consider ed appropriate and representative.

The kitchen is a very small enclosed room, with access from the MCR via a single fire-rated door. The entire kitchen bou ndary, including door and walls, is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire rated.

The ignition sources in this room are typical small kitchen appliances. There are no fire PRA targets in the kitchen area and it is well separated from PRA targets found in the MCR. Due to the minimal combustible loading and ignition sources, a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated fire barrier, and effective spatial and physical s eparation from MCR targets and secondary Attachment L-15-150 Page 76 combustibles, the risk from ki tchen fires is considered to be bounded by other fixed and transient combustible sources in the MCR.

Therefore, it has not been explicitly considered in the MCR abandonment calculations.

All unscreened ignition sources identified in the BVPS-1 comput er room have been included in the MCR component counts and considered in the MCR abandonment calculations.

The BVPS-2 computer room is not part of the MCR fire compartment. It is a separate fire compartment (2-CB-4), and consequently, computer room fires are not considered as part of the MCR abandonment calculations.

No significant fixed ignition sources abov e and beyond typical office equipment were identified in the office. Transient combustible sources t hat may be present in the office are considered to be captur ed and bounded by the transient fire modeling applied within the MCR.

Response:

It has been confirmed that all cabinets in t he MCR with multiple bundles of unqualified cable have closed doors.

Attachment L-15-150 Page 77

Response:

The MQH HGL calculation was used to det ermine the maximum HGL temperature in the exposing compartment and conservatively no inte r-compartment openings between the exposing and exposed were considered at th is stage of the MCA. To allow for natural ventilation, the MQH HGL calculation assumes an external ventilation opening represented by a single open door. If the HGL temperature in the exposing compartment did not exceed the critical temperature for damage to occur, then regardless of the openings in the barrier, it would not be possible for a damaging HGL to form in any exposed compartments. Fo r cases where a damaging HGL could form in the exposing compartment, furt her detailed MCA CFAST fire modeling was performed, including consideration of openings between the exposed and exposing compartments. The openings in the CFAST HGL calculation between the exposing and exposed

compartments were determined following a re view of opening details gathered from drawings, walkdown information, and a propagation pathway credibility assessment. If a barrier contained any permanent opening, that opening size was used in the HGL calculation. For cases with no permanent openings, the worst-case remaining opening

type (that is, fire doors, fire dampers, or pe netrations) was applied.

Generally, fire doors were assumed to be 0.9 m x 2.1 m opening s, fire dampers to be 1 m x 1 m openings, and penetration seals to be 0.1 m x 0.1 m openi ngs. However, larger areas may have been used as applicable. In all cases, the vent sizes modeled boun d the existing plant conditions for a given fire compartment.

Attachment L-15-150 Page 78

Response:

An investigation was perform ed to classify each of the various cable types used at BVPS as either thermoset (TS) or thermoplastic (T P) based upon cable jacket or insulation material. This information was combined with that in Appendix H of

NUREG/CR-6850 to determine thermal damage cr iteria for TP targets (including raceways containing mixed or unknown cable types) as follows:

Critical Temperature:

205 degrees Celsius (ºC), or 400 degrees Fahrenheit (ºF) Critical Heat Flux: 6 kW/,square-meter (m²), or 0.5 British Thermal Unit per square-foot second (Btu/ft²s)

Similarly, the thermal damage criteria for TS targets are as follows:

Critical Temperat ure: 330 ºC (625 ºF) Critical Heat Flux: 11 kW/m² (1.0 Btu/ft²s)

Attachment L-15-150 Page 79

Response:

The Heskestad and Delichatsios smoke detecti on actuation correlation (the temperature to smoke density correlation) is based upon the ceiling jet temper ature predicted by Alpert's ceiling jet temperature correlation; th erefore, the normalized parameters for the ceiling jet temperature correlation are applicable. The normaliz ed parameter that applies to the Alpert's ceiling jet temperature correlation is the ceiling jet distance ratio, and the validation range is 1.

2-1.7, as provided in N UREG-1824. The Heskestad and Delichatsios smoke detection actuation corre lation using Alpert's ceiling jet temperature correlation was either applied within t he validated range or has been reviewed and justified as acceptable based on NUREG-1824. The justific ations are documented in the BVPS fire modeling verification and validation documentation. Furthermore, all of the models fall within the acceptable validat ion range provided by Table 3-3 of the Supplement 1 Draft to NUREG-1824.

In addition, the smoke detection actuation correlation was applied to fuels, configurations, and environmental conditions consistent with those described in Chapter 4-1 of the Society of Fi re Protection Engineers (S FPE) Handbook and NUREG-1805, "Fire Dynamics Tools (FDTs): Quantitative Fire Hazard Analysis Methods for the U.S.

Nuclear Regulatory Commission Fire Protecti on Program." The correlation was also applied within the limitations described in these publications.

Heskestad and Delichatsios correlated a sm oke temperature change of 10°C (18°F) based upon typical fire fuels. The ma terials tested to develop the Heskestad and Delichatsios smoke detection actuation co rrelation are represent ative of the fuels modeled for smoke detector activation. The tested materials include various plastics, foams, and paper, possessing smoke properties similar to the fires modeled at BVPS. Additionally, when implementing the He skestad and Delichatsios smoke detection actuation correlation (that is, FDT10), the 10°C (18°F) ceiling jet te mperature rise from ambient temperature is preserved by adjusti ng the activation temper ature of the smoke detector accordingly.

Attachment L-15-150 Page 80

Response: Fire modeling calculations have been, and will be, performed by engineers who meet the qualification requirements of Section 2.7.3.4 of NFPA 805 (2001).

Fire modeling to support the LAR and fire PRA development was performed by FENOC and contract personnel using their respec tive companies' procedures and Quality Assurance programs. These procedures require that pr oject personnel assigned to each task have the proper experience and training to perform the work.

This is verified by FENOC and contractor company management. All contractor engineering procedures and quality assurance manuals have been reviewed for compliance with the

FENOC Quality Assu rance Program.

These FENOC and contractor personnel were chosen based on their experience and expertise in fire modeling. The qualific ations needed to perform fire modeling related tasks depend, in part, on the specific role of the personnel. Appropriate qualifications for FENOC and contractor personnel using, applying, and approving fire modeling tools

include required reading on fire modeling project instructions, relevant industry methodology and/or guidance documents such as NUREG/CR-6850, NUREG-1934, NUREG-1805, and applicable fire modeling so ftware user's guide documents. Other requirements include training and/

or mentoring in fire growth analysis, zone of influence (ZOI) calculations, and fire modeling tools.

The qualification r equirements to perform other fire modeling related tasks depend in part on the personnel's specific assigned role. Some sub-tasks of fire modeling ma y be assigned to other staff with experience Attachment L-15-150 Page 81 and skill set commensurate with the task.

Example tasks include walkdown data collection, raceway drawi ng reviews, and data entry.

In addition, as stated in LAR section 4.

7.3, FENOC will devel op qualification requirements for FENOC personnel to perform fire modeling. These qualification guides will be developed per applicabl e FENOC training program procedures and in accordance with the FENOC Q uality Assurance Program.

Implementation item BV1-3117 has been created to develop position specific guides meeting the requirements of NFPA 805 Se ction 2.7.3.4, regarding personnel qualifications. A revision to the LAR Attachment S, Table S-3 for this added implementation item will be provi ded in a future submittal.

Response:

Fire modeling to support the LAR and fire PRA development was performed by FENOC and contractor personnel using their res pective companies' procedures and Quality Assurance programs. Thes e procedures require that FENOC and any contractor management be responsible for the overall pr oject performance of fire modeling tasks and for ensuring that project personnel assigned to each task have the proper experience and training to perform the work. Engineers performing fire modeling are required to perform their duties in accordance with the fire modeling procedure and Quality Assurance program. This process was followed to ensure the personnel performing fire modeling were qualified. All contractor engineering procedures and quality assurance manuals have been reviewed fo r compliance with the FENOC Quality Assurance Program.

During the transition, FENOC will continue to utilize qualified personnel to perform fire modeling and will continue to use the pr ocess described above. Additionally, qualification requirements and tr aining will be created to prov ide a means of qualifying FENOC engineers to perform fire modeling. This requirement will be included as implementation item BV1-3117 in LAR Attach ment S, Table S-3. To address this implementation item, qualif ication guides will be developed and implemented per applicable FENOC training program proc edures and in accordance with the FENOC Quality Assurance Program.

Attachment L-15-150 Page 82 When FENOC personnel perform fire modeli ng post transition, the FENOC processes for developing qualifications will be followed to ensure that assigned personnel are qualified. FENOC training procedures requi re that personnel be qualified to perform

assigned tasks and managers and supervisors are responsible for ensuring that personnel are qualified. Once the fire modeling qualificat ion guides are developed, the new guidance, in conjunction with existing FENOC training procedures will ensure personnel performing fire model ing are qualified and that their qualifications are adequately maintained.

Implementation item BV1-3117 has been created to develop position specific guides meeting the requirements of NFPA 805 Se ction 2.7.3.4, regarding personnel qualifications. A revision to the LAR Attachment S, Table S-3 for this added implementation item will be prov ided in a future submittal.

Response:

Throughout the BVPS FPRA process, the fire modeling personnel and the FPRA personnel maintained frequent communications. Periodic meetings with the entire FPRA and fire modeling teams were held, as necessary to ensure proper communication. The fire modeling anal yses were developed into approved vendor documents which were then used as input to the Fire PRA. These analyses are controlled under the vendor technical info rmation review processes which require appropriate cross-disciplinary reviews ar e performed and impacted departments (such as the PRA group) are notified of the change.

Attachment L-15-150 Page 83 Response:

For consistency, each major fire modeling task (for example, scoping fire modeling, detailed fire modeling, multi-compartment analysis, and ma in control room analysis) was assigned to a single supporting consultan

t. Therefore, a single vendor procedure and a consistent methodology were utilized for all analyses within each major task. All

applicable contractor engin eering procedures and quality assurance manuals have been reviewed for compliance with the FENOC Quality Assurance Program to ensure consistency.

Response:

Fire modeling was performed in support of the BVPS fire PRA, utilizing codes and standards developed by industry and NRC and that were verified and validated in authoritative publications such as NUREG-1824, "Verificati on and Validation of Selected Fire Models for Nuclear Power Plant Applicat ions." In general, t he fire modeling was performed using conservative methods and input parameters that were based upon NUREG/CR-6850, "Fire PRA Methodology for Nuclear Power Facilities." This approach was used based upon the current state of knowledge regarding the uncertainties related

to the application of the fire modeling tools and associated input parameters for specific plant configurations.

The detailed fire modeling task develops a probabilistic output in t he form of target failure probabilities and are subject to both aleatory (statistical) and epistemic (systematic) uncertainty.

Appendix V of NUREG/CR-6850 recommends that to the extent possible, modeling parameters should be expre ssed as probability distribut ions and propagated through the analysis to arrive at target failure probability distributions. These distributions should be based on the variation of experim ental results as well as the analyst's judgment. To the Attachment L-15-150 Page 84 extent possible, more than one fire model can be applied and probabilities assigned to the outcome which describes the degree of belief that each model is the correct one.

Due to the uncertainty with each of thes e parameters, the fire modeling task has selected conservative values for some of key input parameters while utilizing the mean values for the rest to provi de safety margin as described below. Per NEI 04-02, there is no clear definition of an adequate safety margin; however, the safety margin should be sufficient to bound the uncertainty within a particular calculation or application. The

BVPS fire modeling documentation for each fire compartment provides a list of items that were modeled conservati vely and that provide safety margin. Some examples include the following items:

The majority of the BVPS fire PRA's scenarios involving electrical equipment (including the electrical split fraction of pump fires) utilize the 98th percentile HRR for the zone of influence. This is considered conservative.

The HRR value for some cabinets was based upon non-qualified internal cable.

This results in a conservative HRR as these cabinets likely contain some amount of qualified cable.

The fire elevation in most cases is at the top of the cabinet or pump body. This is considered conservative, since the com bustion process will occur where the fuel

mixes with oxygen, which is not alwa ys at the top of the ignition source. Additionally, the guidance of FAQ 08-0043 recommends fire be modeled 1 foot

below the top of the electrical cabinets t hat are sealed at the top, and reinforces that this method is conservative.

The radiant fraction utilized is 0.4. Th is represents a 33 percent safety margin over the normally recommended value of 0.3. In addition, the convective heat release rate fraction utilized is 0.7. The normally recommended value is between

0.6 and 0.65, and thus the use of 0.7 is conservative.

For transient fire impacts, a large bounding transient zone assumes all targets within its ZOI are affected by a fire. Time to damage is usually calculated based on the most severe (closest) target. Th is is considered conservative, since a transient fire would actually have a much smaller ZOI and varying damage times for the various HRR bins which make up the total HRR probability distribution.

This approach is implemented to minimize the multitude of transient scenarios to be analyzed.

In some fire compartments, transient fires assume dam age to all targets from the floor to the ceiling. This is conserva tive since most tran sient fires are not expected to have a ZOI that would reach the ceiling.

Attachment L-15-150 Page 85 The fire elevation for transient fires wa s assumed to be 2 feet to account for any transient fires not occurring at floor leve

l. This is conservative since most transient fires are expected to be below this height (that is, at floor level).

For HGL calculations using the MQH correlation, no equipment or structural steel is credited as a heat sink, because the closed-form correlations used do not account for heat loss to these items.

For the non-fire dynamics simulator (FDS) analyses, as the fire propagates to secondary combustibles, the fire is c onservatively modeled as one single fire using the fire modeling closed-form co rrelations. The resulting plume temperature estimates used are therefor e conservative, since the fire would actually be distributed over a large surface area, and would be less severe at the target location.

For most scenarios, target damage is assumed to occur when the exposure environment meets or exceeds the damage threshold. No additional time delay due to thermal response is given.

Oil fires are analyzed as both unconfined and confined spills with 20-minute durations. Unconfined spills result in large heat release rates, but usually burn for seconds. The oil fires in this compartment have been conservatively

analyzed for 20 minutes to account for t he uncertainty in the oil spill size.

For many scenarios, automatic or manual detection and suppression are not credited which leads to conservative results.

Scenarios that identify the time to automatic detection and suppression do not utilize the approach of adding the HGL temperature to the ceiling jet temperature.

Including the effects of a HGL would result in shorter detection and suppression times; therefore, the use of the ceiling jet correlation is considered conservative.

All fires modeled using FDS assume that the fire does not experience the effects of oxygen deprivation. This is a conserva tive assumption that enables the fire to continuously burn in environments with ox ygen levels below that required to sustain the prescribed HRR.

The fire dynamics tools (FDTs) generally over-predict hot gas layer temperatures and this over-prediction is expected to lead to conservative results.

Not every cable tray is filled to capacity. In many cases, cable trays that are partially full have been assumed to be filled to capacity, which provided a conservative estimate of the surf ace area and corresponding fire severity.

Attachment L-15-150 Page 86 For some scenarios fire propagation to the first cable tray has been estimated to be one minute. In most cases, propagation to the first cable tray would be greater than one minute; therefore, this is considered conservative.

Many cable trays have metal top or bottom covers which are mostly solid with the exception of infrequent small gaps (for exam ple, less than 1 inch). A solid metal bottom cover would normally delay igni tion and damage by 20 minutes. Metal top or bottom covers with small and in frequent gaps are not credited to delay damage of target cables, which is conservative. Additionally, based on FM RAI 2b, the fire modeling analysis for cable trays with perforated and corrugated tray covers is being updated to remo ve credit for a delay time to damage or ignition.

In actuality, these covers would provide some delay to both damage and ignition.

Therefore, assuming no delay is conservative.

In most cases, credit was not given to cable tray covers for damage and fire spread to cable trays containing any thermoplastic or unknown cables. Not crediting the covers is considered conservative as the percentage of thermoplastic cables in these trays is oft en very low. In addition, the much more conservative thermoplastic fire growth c haracteristics were used for the majority of mixed thermoplastic and thermoset cable trays.

Cable trays with any amount of thermoplastic cable, regardless of percentage were treated as thermoplastic for fi re spread rate, even though NUREG/CR-7010 would allow the predomi nant type to be used.

High energy arcing fault scenarios were c onservatively assumed to be at peak fire intensity for 20 minutes from time zero (igniti on), even though the initial arcing fault is expected to consume the co ntents of the cabinet and burn for only a few minutes.

For many non-risk-significant scenarios, conduit elevations were assumed to be within the flame height su ch that they were s ubjected to damaging plume temperatures and a potential damaging radiant heat flux.

Attachment L-15-150 Page 87 Response:

In the area of the fire modeling, "model" uncertainties and associated assumptions can be introduced through two separate phases of the fire modeling; first from selection of fire modeling tools such as FDTs and CF AST, and secondly through their applications to the development of fire scenarios.

NUREG-1934 states that "model" uncertainties can be estimated using the processes of verification and validation.

Model uncertainty is based pr imarily on comparisons of model predictions with experimental m easurements as docum ented in NUREG-1824 "Verification and Validation of Selected Fire Models for Nu clear Power Plant Applications," final report, dated May 2007 and other model validation studies.

All of the fire models used and listed in Attachment J of the BVPS NFPA 805 LAR were within or very near the experimental uncertainty, as determined by NUREG-1824.

Where applicable, all fire m odels listed below were applied within the validation ranges

or the use was justified as acceptable wi th a subsequent analysis. Each model is discussed below.

Hot Gas Layer Temperature using FDTs

The predictive capability of the hot gas la yer temperature paramet er using FDTs is characterized as YELLOW+ according to NUREG-1824, Volume 1, Table 3-1.

As stated in NUREG-1824, Volume 1, secti on 2.6.2, a YELLOW+/- characterization is assigned "If the first criterion is satisfi ed and the calculated relative differences are outside the experimental uncertainty but indica te a consistent pattern of model over-prediction or under-prediction, then the model predictive capability is characterized as YELLOW+ for over-prediction, and YELLO W- for under-prediction. The model prediction for the specific attribute may be useful within the ranges of experiments in this study, and as described in Tables 2-4 and 2-5, but the users should use caution when interpreting the results of the m odel. A complete understanding of model assumptions and scenario applicability to these V&V results is necessary. The model

may be used if the grade is YELLOW+ when the user ensures that model over-prediction reflects conservatism. The user must exercise caution when using models with capabilities de scribed as YELLOW+/-."

NUREG 1824, Volume 3, se ction 6.1 states that: "The FDTs models for HGL temperature capture the appropriate physi cs and are based on appropriate empirical data. FDTs generally over-pr edict HGL temperature, outside of uncertainty." The over prediction is expected to lead to conserva tive results and increased safety margin.

Attachment L-15-150 Page 88 Hot Gas Layer Height and Temperature using FDS

The predictive capability of the hot gas layer height and temperatur e parameters in FDS is characterized as GREEN according to Table 3-1 of NUREG-1824.

A GREEN characterization is given "If both cr iteria are satisfied (that is, the model physics are appropriate for the calculation being made and the calculated relative differences are within or very near experimental uncertainty), then the V&V team concluded that the fire model prediction is accurate for the ranges of experiments in this study, and as described in Tables 2-4 and 2-5.

A grade of GREEN indicates the model can be used with confidence to calculate the specific attribute. The user should recognize, however, that the accuracy of the model prediction is still somewhat uncertain and for some attributes, such as smoke concentration and room pressure, these uncertainties may be rather large. It is important to note t hat a grade of GREEN indicates validation only in t he parameter space defined by t he test series used in this study; that is, when the model is used withi n the ranges of the parameters defined by the experiments, it is validated."

NUREG-1824, Volume 7, secti on 6.1, summary states: "FDS is suitable for predicting HGL temperature and height, with no specific caveats, in bot h the room of origin and adjacent rooms. In terms of the ranking system adopted in this report, FDS merits a Green for this category, based on- The FDS predictions of the HGL temperature and height are, with a few exceptions, within experimental uncertainty."

Hot Gas Layer Temperature and Height using the Consolidated Model of Fire and Smoke Transport (CFAST)

The predictive capability of the hot gas layer height and temper ature parameters in CFAST was characterized as GREEN according to NUREG-1824, Volume 1, Table 3-1.

The GREEN designation is discussed above under the "Hot Gas Layer Height and Temperature using FDS" heading. Specifically, the GR EEN designation was assigned to the CFAST HGL temperature parameter calculated in the fire compartment of origin.

Compartments remote from the fire we re assigned a YELLOW designation which "suggests that one exercise caution when using the model to evaluate this quantity -

consider carefully the assumptions made by the model, how t he model has been applied, and the accura cy of the results."

As stated in NUREG-1824, Volume 1, secti on 2.6.2, a YELLOW characterization is assigned "If the first criterion is satisfi ed and the calculated relative differences are outside experimental uncertainty with no consis tent pattern of over- or under-prediction, then the model predictive capability is characterized as YELLOW. A YELLOW classification is also used despite a consiste nt pattern of under or over-prediction if the experimental data set is limit ed. Caution should be exerci sed when using a fire model

for predicting these attributes. In this case, the user is refe rred to the details related to the experimental conditions and validation results documented in Volumes 2 through 6.

Attachment L-15-150 Page 89 The user is advised to review and understand the model assumptions and inputs, as well as the conditions and results to det ermine and justify the appropriateness of the model prediction to the fire scenario for which it is being used."

NUREG-1824, Volume 5, secti on 6.1 summary states: "The CFAST predictions of the HGL temperature and height are, with a few exceptions, wit hin or close to experimental uncertainty. The CFAST predictions are typi cal of those found in other studies where the HGL temperature is typically somewhat over-predicted and HGL height somewhat

lower than experimental meas urements. These differences are likely attributable to simplifications in the model dealing with mixi ng between the layers, entrainment in the fire plume, and flow through vents. Still, predictions are mostly within 10 % [percent] to 20 % of experimental measurements."

Ceiling Jet Temperature using the Alpert Correlation

The predictive capability of the ceiling jet temperature parameter using the Alpert correlation in the fire-induced vulnerability eval uation (FIVE) fire model is characterized as YELLOW+ according to NUREG-1824, Vo lume 1, Table 3-1. The YELLOW+ designation is discussed above under the "Hot Gas Layer Temperature using FDTs" heading. Specifically, NUR EG-1824, Volume 4, sect ion 6.2 summary states:

The Alpert correlation under-predicts ceili ng jet temperatures in compartment fires with an established hot gas layer.

This result is expected because the correlation was developed without considering HGL effects. The original version of FIVE accounted for HGL effects by adding the ceiling jet and HGL

temperature. This practice results in consistent over-predictions of the ceiling jet temperature. The approach of adding ceili ng jet temperatures to the calculated hot gas layer continues to be the re commended method for FIVE-Rev 1 users.

Based on the above discussion, a classifi cation of Yellow+ is recommended if HGL effects on the ceiling jet temperature are considered using the approach described in the above bullet. The Alpert correlation by itself is not intended to

be used in rooms with an established hot gas layer.

The approach of adding the hot gas layer temperature to the ceiling jet temperature was not used in the BVPS fire modeling analysis. The primary application of the ceiling jet correlation at BVPS was the determination of detection and suppression timing, in which the ceiling jet velocity is a sub-model in the analysis. Including the effects of a hot gas

layer would have resulted in shorter detecti on and suppression times, and therefore the BVPS approach is conservative. The use of the ceiling jet correlation for target damage was bounded by the use of the point sour ce radiation model and is justified and discussed in the BVPS fire m odeling V&V documentation.

Attachment L-15-150 Page 90 Plume Temperature using FDTs

The predictive capability of the plume temperature parameter using FDTs is characterized as YELLOW- according to NUREG-1824, Volume 1, Table 3-1. The

YELLOW- designation is discussed above under the "Hot Gas Layer Temperature using FDTs" heading.

NUREG-1824, Volume 3, sect ion 6.2 summary states "T he FDTs model for plume temperature is based on appropriate empirical dat a and is physically appropriate. FDTs generally under-predicts plume temperature, outsi de of uncertainty, because of the effects of the hot gas layer on test measurements of plume temper ature. The FDTs model is not appropriate for predicting the plume temperatures at elevations within a hot gas layer."

The FDTs plume correlation for fire modeling applications was used within the limitations provided in NUREG-1824. The effects of the plume and hot gas layer interaction were analyzed and documented in the BVPS fire modeling verification and

validation documentation.

Plume Temperature using FDS

The predictive capability of the plume temperature parameter using FDS is characterized as YELLOW according to NUREG-1824, Table 3-1. The YELLOW designation is discussed above under the "Hot Gas Layer Temperature and Height using the Consolidated Model of Fire and Smoke Transport (CFAST)" heading.

NUREG-1824, Volume 7, secti on 6.3 summary states: "The FDS hydrodynamic solver is well-suited for this application. FDS over-predicts the lower plume temperature in BE [benchmark exercise] #2 because it over-predicts the flame height. FDS predicts the

FM/SNL [Factory Mutual and Sandia National Laboratories] plume temperature to within experimental uncertainty. The simulations of BE #2 and the FM/SNL series are the most time-consuming of all six test series, mainly because of the need for a fairly fine numerical grid near the plume.

It is important that a us er understand that considerable computation time may be necessary to well-reso lve temperatures within the fire plume.

Even with a relatively fine grid, it is still challenging to accurately predict plume temperatures, especially in the fire itself or just above the flame tip. There are only nine plume temperature measurements in the data set. A more definitive conclusion about the accuracy of FDS in predicting plume tem perature would require more experimental data."

In accordance with the guidance provided in NUREG-1934, a dimensionless D*/ dx ratio

between 5 to 10 produces favorable FDS results at moderate computational cost, where D* represents the fire's characteristic diameter, and dx represents the size of a grid cell.

This guidance was applied in the BVP S FDS applications that analyzed plume temperatures. The meshes used in BVPS fire modeling were considered to be Attachment L-15-150 Page 91 sufficiently fine to analyze plume temperatur es in each case. In addition, the plume temperatures within the flaming region ar e not the focal point of either study.

Flame Height using FDTs

The predictive capability of t he flame height parameter using FDTs is characterized as GREEN according to NUREG-1824, Table 3-

1. The GREEN designation is discussed above under the "Hot Gas Layer Height and Temperat ure using FDS" heading.

NUREG-1824, Volume 3, secti on 6.3 summary states "The FDTs model predicted flame heights consistent with vis ual test observations."

Smoke Concentration using CFAST

The predictive capability of the smoke concentration parameter in CFAST is

characterized as YELLOW according to NU REG-1824, Volume 1, Table 3-1. The YELLOW designation is discussed above under the "Hot Gas Layer Temperature and

Height using the Consolid ated Model of Fire and Smok e Transport (CFAST)" heading.

NUREG-1824, Volume 5, se ction 6.6 summary states

"CFAST is capable of transporting smoke throughout a compartment, assuming that the production rate is known and that its transport properties are comparable to gaseous exhaust products.

CFAST typically over-predicts the smoke concentration in all of the BE #3 tests, with the exception of Test 17.

Predicted concentrations fo r open-door tests are within experimental uncertainties, but those for closed-door tests are far higher. No firm conclusions can be drawn from this single data set. The measurements in the closed-door experiments are inconsistent with basic conservation of mass arguments, or there is a fundamental change in the combustion process as the fire becomes oxygen-starved."

The smoke concentration was analyzed and was used as one criterion to determine the probability of MCR abandonment at BVPS following a fire scenario in the MCR.

Because the smoke concentration was over-predicted for both the open-door and closed-door test configurations as indi cated in NUREG-1824, the BVPS CFAST results were considered conservative.

The smoke production rates used in the mode l were conservatively selected from Table

3-4.16 of the SFPE Handbook of Fi re Protection Engineering, 4 th Edition. Because transport properties of the smoke are expected to be comparable to gaseous exhaust products, the use of the model is within the lim itations and the experimental uncertainty.

Radiant Heat using FDTs

The predictive capability of t he radiant heat parameter of t he FDTs is characterized as YELLOW according to NUREG-1824, Volume 1, Table 3-1. The YELLOW designation Attachment L-15-150 Page 92 is discussed above under the "Hot Gas Lay er Temperature and Height using the Consolidated Model of Fire and Smoke Transport (CFAST)" heading.

NUREG-1824, Volume 3, secti on 6.4 summary states: "The FD Ts point source radiation and solid flame radiation model in general are based on appropriate empirical data and is physically appropriate with c onsideration of the simplifyi ng assumptions. The FDTs point source radiation and soli d flame radiation model are not valid for elevations within a hot gas layer. FDTs predictions had no clear trend. The model under- and over-predicted, outside uncertainty. The point source radiation model is intended for predicting radiation from flames in an unobstructed and smoke-clear path between

flames and targets."

Only the FDTs point source radiation m odel was used in the BVPS fire modeling. NUREG-1824 states that there is no clear trend in under- or over-prediction for the point

source model. The model over-predicted heat flux for locations immersed in a hot gas layer, which is likely due to smoke and the HGL preventing radiation from reaching the gauges. This over-prediction is expected to lead to conservative results and increased safety margin. In a smaller number of ca ses, the model under-pr edicted heat flux due to contribution of radiation fr om the HGL. In or der to account for this potential under prediction, conservatism was built into the use of the radiation model at BVPS, including the use of a radiant heat release rate fr action of 0.4, as opposed to the normally recommended value of 0.3.

In addition, NUREG-1824 states that the point source model is not intended to be used for locations relatively close to the fire. In the BVPS fire modeling analysis, targets located close to the fire were conservatively failed within the early stages of fire growth.

Radiant Heat using FDS

The predictive capability of the radiant heat parameter in FDS is characterized as YELLOW according to NUREG-1824, Table 3-1. The YELLOW designation is discussed above under the "Hot Gas Layer Temperature and He ight using the Consolidated Model of Fire and Smoke Transport (CFAST)" heading.

Even though the FDS radiant heat model was designated as Yellow, NUREG 1824, Volume 7, section 6.8 states that: "FDS has the appropriate radi ation and solid phase models for predicting the radiative and convective heat flux to targets, assuming the

targets are relatively simple in shape.

FDS is capable of pr edicting the surface temperature of a target, assumi ng that its shape is relatively simple and its composition fairly uniform. FDS predictions of heat flux and surface temperatur e are generally within experimental uncertainty, but there are numerous exceptions attributable to a variety of

reasons. The accuracy of the predictions generally decreases as the targets move closer to, or go inside of t he fire. There is not enough near-f ield data to challenge the model in this regard."

Attachment L-15-150 Page 93 FDS was used to calculate radiant heat exposure to determine the radiant heat

exposure to an electrical cabinet from a tr ansient fire. The lim itations outlined in NUREG-1824 were not of concern based upon the following:

1) Heat flux was not calculated for any targets inside of the fire. For the FDS analyses performed, all potential radiant heat targets were located a minimum of 3 feet horizontally away from the fire.

2) All targets were simple in shape and not complex in nature. The targets analyzed were a flat sheet metal panel and heat flux monitoring devices located independent of obstructions. In both in stances, the targets were of simple geometry and uniform composition.

Since the model was not used outside of the limitations identified, BVPS concluded that the FDS predictions of heat flux we re within experimental uncertainty.

Completeness Uncertainties

Potential model uncertainties introduced as par t of the use of the fire modeling tools in fire scenario selection and analysis are listed below. BVPS performed the characterization of such fire modeling mode l uncertainties and evaluated their impacts on the fire PRA model. The fire modeling at BVPS follows the guidance and requirements provided in NUREG/CR-6850 and other NRC accepted guidance

documents and positions, which are generally pre scriptive and conservative in nature. Since some of these uncertainties were characterized as conservatively biased or are judged to have insignificant impacts on the fi re PRA model, or the approaches used by BVPS were the sole acceptable analysis method available to evaluate impacts in the fire modeling analyses, no further consider ation was given to this type of model uncertainties.

Heat release rates (peak HRR, time to reach peak, steady burning time, decay time) Number of cabinet cable bundles Ignition source fire diameter Room ventilation conditions Fire growth assumptions (cable tray empirical rule set, barrier delay, fire duration) Cable fire spread characteristics for horizontal and vertical trays Transient fires (peak HRR, time to reach peak, location factor, detection time) Oil fires (spill assumptions)

Assumed target location Target damage threshold criteria Manual detection time Mean prompt suppression rate Attachment L-15-150 Page 94 Manual suppression rate Welding and cutting target damage set Transient target impacts Superposition of damaging sources (for example, plume, radiant heat, and others) Crediting or not crediting conduit in time-to-damage Model Completeness

Regarding "completeness" uncertainties, these re fer to the fact that a model may not be a complete description of the phenomena it is designed to predict. Completeness uncertainty was addressed by the same process used to address the model uncertainty.

Model and completeness uncertainty are closely related, and it would be impractical to evaluate them separately. Therefore, the discussion above for "model" uncertainties, as well as the conservative approaches discuss ed in the response to FM RAI 6a address "completeness" uncertainty.

For uncertainties specifically involved wit h ignoring the content s of a compartment, there were several areas of conservatism th at mitigate the reduction in volume in HGL calculations. The following assumptions were utilized within the fire modeling which lead to conservatism or reduced the impact of ignoring the contents of a compartment in the fire modeling analysis:

If equipment was included in HGL calc ulations, a large heat sink was provided in the fire compartment, wh ich would have generated lower HGL temperatures.

No heat passage through fire doors or dampers was considered in the HGL temperature calculations. The material properties of concrete were applied to all exterior boundaries of the fire com partment. Realistically, the heat from the HGL would be transferred to adjacent spaces more easily by a door or fire damper, which have a higher thermal conduc tivity than concrete. Including these passages to adjacent compartments would have generated lower HGL temperatures.

Although obstructions within the room could reduce the effective volume when analyzing HGL temperatures, many of these obstructions (such as electrical cabinets and transformers) are not totally solid obstructions.

Electrical cabinets are generally not full of electrical components on the inside (for example, they have large empty spaces within the cabinets). These empty spaces within the electrical cabi nets reduce the impact of including obstructions for HGL temperature calculations.

The volume of some fire compar tments was reduced in the BVPS fire modeling analysis to meet the validati on range for compartment aspect ratio.

Attachment L-15-150 Page 95 For fire compartments having an aspect ratio outside the validated range where detailed fire modeling was perfo rmed and whole room damage was not postulated, the height, length, or wid th of the fire compartment was "shortened" to values that fall within the validation range. Shortening the dimensions of the fire compartment decreases the overall volume of the compartment and creates a more severe condition. The reduction in volume in these compartments bounds the obstruc tions that were not considered.

Attachment L-15-150 Page 96

Response: The unavailability of any fire protection syst em is documented as par t of the BVPS fire protection program and fire protection impairment process. BVPS plant-specific system unavailability data collected by the BVPS fire pr otection program will be incorporated into the fire PRA as follows:

1. Assume an unavailability probability of 0.01 for those system s with a historical unavailability of less than 0.

01. This probability represents an unavailability of Attachment L-15-150 Page 97 approximately 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months per year, which is intended to capture any unplanned potential fire protection system impairments in the future.

2. For all systems with a historical unavailability ex ceeding 0.01, the actual unavailability probability will be used as an input to the FPRA analysis.

These plant-specific system unavailabilities will be factored into fire scenario frequency evaluations in detailed fire modeling, where fire protection systems are credited. These updates will be reflected in the updated fi re risk results for both BVPS-1 and BVPS-2 that will be provided to the NRC as part of the integrated analysis performed in response to PRA RAI 03. To ensure these unavailability probabilities are adequately addressed, the unavailability of credited fire protection systems will be tracked as part of the BVPS monitoring program, as documented in LAR, Table S-3, Items BV1-2974 and BV1-2989.

Attachment L-15-150 Page 98

Response: F&O HRA-E1-01 addresses concerns over the lack of formality, rigor and defensibility of the HRA dependency analysis that was c onducted, and inadequa cy of the approach used for the consistency review. All i ssues associated with this F&O have been resolved and documented. The updated HRA dependency analysis for the BV2REV5F fire PRA model is documented in BVPS-2 PRA assessment PRA-BV2-12-002. This PRA assessment, as well as the consistency review, are referenced in the updated BVPS-2 fire HRA notebook, BV2REV5F Fire Human Reliability Analysis. The notebook was updated to address peer review F&Os and to reflect the final model for the NFPA 805 LAR.

The BVPS-2 PRA assessment PRA-BV2-12-002 was prepared to formally document

the methodology, analysis, and results of potential HFE dependency issues among internal event, internal flooding, and fire operator actions in the BV2REV5A PRA model and the BV2REV5F fire PRA model. The BV PS PRA team used a systematic approach that investigated a comprehensive set of human action combinations to merit

confidence that the impacts of all dependencies have been thoroughly assessed and adequately represented in the PRA models. It includes a systematic and comprehensive search for and evaluation of dependent human intera ctions that may play a significant role in the accident sequence frequency. The methods applied to evaluate the dependence and the probabilities of these dependent human actions are consistent with the state of the art as it is practiced in the domestic nuclear industry, and consistent with that descr ibed in NUREG-1921, EPRI/NRC-RE S Fire Human Reliability Analysis Guidelines.

All operator action HEP values were in creased to 0.8 probability, and the model quantified to address the concern of recognizing dependent HFEs in combination of multiple events in lower core damage frequency (CDF) and large early release

frequency (LERF) sequences. The resulting sequences (in terms of the concurrent, failed split fractions) and the cutsets obtained fo r the individual top event split fractions (which account for all of the cutsets contri buting more than 1.0E-3 percent to the split fraction values) were logically combined in a Microsoft Access database to identify the multiple HFEs in these accident sequences.

These operator action combinations were initially evaluated for level of dependenc e through the use of a generic dependence evaluation tree logic addressing the similarities and differences in the following factors:

crew, cognition, cues, locations, timing, and resources. Five qualitative dependency levels (zero, low, moder ate, high, and complete depend ence) were adopted for the Attachment L-15-150 Page 99 treatment of human action dependence as dev eloped in the technique for human error rate prediction (THERP). A review of the results of the initial dependence determination using the dependence tree logic was performed for every combination identified as described above. Those operator action co mbinations determined initially dependent were subsequently reviewed by an expert panel , and, where it was felt that adjustments were needed to the decisions made for select ed attributes in the dependence tree logic, the reasons were documented and the dependency level between the affected operator actions were adjusted appropriately.

To further address this F&O, section 3.5 Consistency Review was added to the BVPS-2

fire HRA notebook, BV2REV5F Fire Human Reliability Analysis. This review provided the F&O-requested comparison of failure rates between different versions of the same operator action, and provided complete justif ication for any deviations from expected results and trends, in order to ensure that all HEPs were evaluated with appropriate consistency.

Beyond the scope of this F&O, a similar HRA dependency analysis and consistency review were conducted for BVPS-1. The HRA dependency analysis for the BV1REV5F fire PRA model is documented in BVPS PRA assessment PRA-BV1-13-025. The consistency review is documented in Section 3.5 of the BVPS-1 fire HRA notebook, BV1REV5F Fire Human Reliability Analysis.

Attachment L-15-150 Page 100

Response:In most cases, the structure of t he BVPS RISKMAN fire PRA models preclude dependency concerns. Many operator action s are evaluated under multiple conditions in order to account for differ ent potential plant states re sulting from the success or failure of logically preceding actions or systems. The BVPS PRA models are built to specifically avoid issues with operator action dependencies. Hence, although extensive evaluations of potential HEP dependency issues were performed for the BV2REV5F and BV1REV5F fire PRA models in PRA as sessments PRA-BV2 002 (BVPS-2 HRA dependency analysis) and PRA-BV1-13-025 (BVPS-1 HRA dependency analysis) in response to this F&O, the independence amongst most human actions is fundamentally already constructed into the BVPS RISKMAN fire PRA model logic and structures.

For the BVPS-2 fire PRA, 460 operator action pairings were identified as potentially dependent and 86 percent (395 pairs) had a joint HEP probability greater than 1.0E-05. The range of joint HEP probabilities spanned 3.0E

-01 to 1.6E-07.

Of the remaining 14 percent (65 pairs) that had a joint HEP probability less than 1.0E-05, 64 pairs were assessed as zero dependence based on the use of generic dependence evaluation logic tree, as described in the response to part (i) of this RAI, as well as individual review by the BVPS PRA team members (including a former BVPS-2 senior reactor

operator, or SRO) to verify t hat they appropriately reflect the nature of the relationships among the HFEs in the context of the a ccident sequences in which they appear.

Independence between actions was established via team review using such

considerations as well-trained, rapid-re sponse operator actions and long-time-window operator actions that afford significant recovery time if performed incorrectly, intervening successful operator actions that would break dependency, and an assessment of the time separation of subsequent actions from pr ior failed operator actions and when the consequences of the preceding faile d operator actions are realized.

Attachment L-15-150 Page 101 The remaining BVPS-2 operator action pairing with a joint HEP of 5.7E-06 (less than 1.0E-05) and complete dependence is OP RHH3F1-OPRHC1F1. Operator action OPRHH3F1 (in top event HH) is Operator Locally Align and Manual Start Backup HHSI

[high head safety injection] Pump, and operator action OPRHC1F1 (in top event HC) is Operator Aligns The Alternate Cold Leg SI [safety injection] Path; SLOCA. The dependence between the two actions is accounted for within the BVPS-2 fire PRA

model through the use of the no melt condition from injection phase (NMF) logic rule in the GTRECIRC event tree. This NMF split fraction rule guarantees early core melt in the model based on the failed state of either Top Event HH or Top Event HC in the GENTRANS event tree, given that a small LOCA, RCP seal LOCA, PORV LOCA, or a

feed and bleed condition exists.

As another example of a BVPS-2 operator action pairing with a joint HEP less than 1.0E-05, the joint HEP operator action pairing OPRCD1F1 - OPRMU2F1 has a value of 2.5E-07. Operator action OPRCD1F1 is the action for operators co ol down the primary system to less than 400 psig and to depressurize the secondary system, given a small LOCA before the RWST empties.

Operator action OPRMU2F1 (in top event MU) is the action for operators to provide makeup to RWST, given a small LOCA and failure to successfully transfer to safety injection (SI) recirculation. Ba sed on the use of the generic dependence evaluation l ogic tree, this pairing was deemed zero dependence based on the significant time windows to comp lete either action. The system time window of OPRCD1F1 is 519 minutes and OPRMU2F1 is 579 minutes. Additionally, in the scenario development for OP RCD1F1, it is already assumed that top event MU has failed, otherwise the RWST would not be emptied.

Note, for the BVPS-1 fire PRA, 295 operator action pairings were identified as potentially dependent and 84 percent (249 pairs) had a joint HEP probability greater

than 1.0E-05. The range of jo int HEP probabilities spanned 2.6E-02 to 5.4E-08. Of the remaining 16 percent (46 pairs) that had a joint HEP probability less than 1.0E-05, all 46

pairs were assessed as zero dependence based on the use of generic dependence

evaluation logic tree, as well as individual review by the BVPS PRA team members (including a former BVPS-1 SRO) to verify that they appropriately reflect the nature of the relationships among the HFEs in the c ontext of the accident sequences in which they appear. This was consistent with the approach discussed above for BVPS-2.

In addition to the evaluation of HF E pairs, for both BVPS-1 and BVPS-2 HRA dependency analyses, the quantified accident sequences for core damage and large

early release were also used to generate a list of the HFE combinations involving more than 2 HFEs. These HFE combinations we re derived based on t he consideration of those confirmed, dependent HFE pairs. All of the HFE combinations that involve only independent HFE pairs were excluded. Those HFE combinations involving more than two HFEs were then evaluated to determine and identify the possibility of longer strings

of dependent HFE combinations (t hat is, more than two HFEs). All such identified joint HFE combinations less than 1E-05 were evaluated as having their dependency properly Attachment L-15-150 Page 102 accounted for, having their dependency broken by intervening successful actions, and so on, per the process described above.

Finally, the implementation of a joint HEP probability "floor" value of 1.0E-05 is not practical in the RISKMAN m odeling environment as there are no means to incorporate it. When the BVPS PRA models were first developed, the fault trees and event trees were developed with great care to specifically preclude any potential operator action dependencies. Operator acti ons were developed to address very specific boundary conditions in the model, corresponding to very specific plant damage states in a given accident scenario. Operator actions contribute to the success or failure of their respective top event. Successive operator actions in the sequence are created to specifically address the success or failure of preceding top events, in all relevant combinations, including any appropriate adjustments to the success criteria or timing

used in the evaluation of the HEP or any other pertinent factors.

Many top events contain multiple versions of what is essentially the same operator action, to account for

the ways in which different plant damage states may affect performance of the action.

Hence, as first stated above and proved via the dependency analyses discussed herein, the structure of the BVPS RISKMAN fire PRA models were developed to preclude dependency concerns.

Attachment L-15-150 Page 103 Response:

The LAR Attachment G describes a number of recovery actions that involve implementing repair procedures on valves that have been impacted by fire-induced cable failures and fireArepair is a recovery action performed on a component that is impacted by a combination of fire-induced and random failures, to ensure that the nuclear safety performance criteria are main tained. A repair is performed using a pre-approved step-by-step procedure to restore functionality of the component. The term "repair" was used instead of maintenance for the recovery actions since it is similarly used in section 4.2.4.1.6 of NFPA 805 in conjunction with credited success path(s) and recovery actions.

Recovery actions associated with repairs are DID recovery actions and are not credited in the fire PRA. The response to PRA RAI 18(b) specifies which actions in LAR

Attachment G are risk-reduction (PRA-credited) actions and which are DID actions.

Attachment L-15-150 Page 104 Response:

Reduced heat release rates fo r transient fires are credi ted in the following fire compartments:

1-CR-4: Process Instrument Room

- Elevation (El.) 713' (142 kW) 1-CS-1: Cable Spreading Room 1 - El. 725'-6" (69 kW) 2-CB-1: Instrumentatio n and Relay Area (142 kW) 2-CB-6: West Communications Room - El. 707'-6" (69 kW) 2-CV-1: West Cable Vault - El. 735'-6" (142 kW) 2-CV-3: Cable Vault & Rod C ontrol Area - El. 755'-6" (142 kW) 2-SB-3: Cable Spreading Room 1 - El. 745'-6" (69 kW)

Attachment L-15-150 Page 105

Response:

The additional risk of recovery actions (including previously-approved actions) has been

evaluated in accordance with RG 1.205 and FAQ 07-0030.

For each fire compartment, the additional risk of recovery actions was calculated by summing the individual delta risk for those VFDRs where the fire PRA credits a recovery action as a means of compensating for the potential for fire damage to the credited success path. This value represents a fraction of the total delta risk for the compartment and was recorded in the conc lusion of each compartment FRE as the compartment's "additional risk of recovery actions."

Recovery actions credited in the fire PRA for each compartment are listed in the first section (VFDR Recovery Actions (Local)) of Table 6-1 of each compartment FRE report. The VFDR(s) associated with the recovery action is also listed in this section.

The calculated additional risk of recovery acti ons for each compartment is not explicitly presented in Attachment W of the LAR.

As discussed above, the additional risk of recovery actions are recorded in the indivi dual FRE reports for each fire compartment.

These values are provided in Tables 1 and 2 below.

Attachment W of the LAR does, howev er, include the foll owing statement:

The development of the Fire Risk Evaluat ions and data for Tables W-2a and W-2b treated all previously approved recove ry actions as new. Thus, the CDF (change in core damage frequency) and LERF (change in large early release frequency) for all recovery actions are included in the Fire Risk Evaluation results presented in

Tables W-2a and W-2b.

Attachment L-15-150 Page 106 Thus, the fire risk evaluation delta risk pr esented in Tables W-2a and W-2b of the LAR bounds the additional risk of recovery actions.

Attachment W of the LAR will be updated as part of the response to PRA RAI 03, and columns will be added to Tables W-2a and W-2b presenting the additional risk of

recovery actions.

The additional risk of recovery actions is presented below in Table 1 for BVPS-1 and Table 2 for BVPS-2. The values have been ta ken directly from the fire compartment FRE reports.

The total additional risk from recovery actions for BVPS-1 is 2.34E-04 per year and 8.66E-06 per year for CDF and LERF respectively, and for BVPS-2 the values are 3.38E-04 per year and 4.41E-06 per year for CDF and LERF, respectively. While these

values are above the RG 1.174 guidelines for acceptable increases in risk (less than 1E-05 per year for CDF and 1E-06 per year for LERF), it should be noted these additional risk of recovery action values do no t credit the risk offset or any risk reduction achieved through the plant modifications to install Westinghouse reactor coolant pump shutdown seals and the very early warn ing fire detection system.

RG 1.205 states that,

The total increase or decrease in risk associated with the impl ementation of NFPA 805 for the overall plant should be calcul ated by summing the risk increases and decreases for each fire area (including any risk increases resulting from previously

approved recovery actions). The total risk increase should be consistent with the acceptance guidelines in Regulatory Gui de 1.174. Note that the acceptance guidelines of Regulatory Guide 1.174 may re quire the total CDF, LERF, or both, to evaluate changes where the risk impac t exceeds specific guidelines.

Application of this guidance to recovery ac tions means that the proposed additional risk of recovery actions is acceptable if the net change in risk is risk-neutral or represents a

risk decrease. Based on the negative net change in risk values (overall risk decrease) reported in Attachment W of the LAR, t he additional risk of recovery actions, while independently exceeding the acceptance guidelines, is acceptable as part of the overall transition to NFPA 805 due to the offsetti ng risk decreases also associated with the transition.

Attachment L-15-150 Page 107 Table 1 - Additional Risk of Recovery Actions for BVPS-1

1-CR-2 Control Room Heating, Ventilation, and Air Conditioning (HVAC) Equipment Room Y 7.31E-09 7.31E-10 1-CR-3 Communications Equipment and Relay

Room Y 9.49E-08 5.71E-10 1-CR-4 Process Instrumentation Room Y 1.99E-04 8.35E-06 1-CS-1 Cable Spreading Room Y 1.57E-07 7.29E-08 1-CV-1 West Cable Vault Y 7.22E-07 2.43E-09 1-CV-2 East Cable Vault Y 2.87E-08 8.28E-11 1-DG-2 Diesel Generator Room Train B Y 2.50E-08 6.64E-11 1-ES-1 Emergency Switchgear Train A Y 8.52E-08 2.30E-10 1-ES-2 Emergency Switchgear Room Train B Y 4.47E-06 2.61E-08 1-MG-1 Motor Generator Room Y 1.59E-08 8.59E-10 1-NS-1 Normal Switchgear Room Y 2.48E-05 1.55E-07 1-PA-1E Primary Auxiliary Building 735' - 6" Y 2.15E-07 3.45E-09 1-PA-1G Primary Auxiliary Building 722'-6" Y 5.63E-07 2.20E-09 1-PT-1 Pipe Tunnel Y 5.40E-07 2.87E-09 1-QP-1 Quench Spray / AFW Pump Room Y 8.23E-07 3.07E-09 1-RC-1 Reactor Containment Building Y 2.24E-07 7.00E-10 1-TB-1 Turbine Building Y 8.67E-08 2.11E-10 3-CR-1 Control Room Y 1.96E-06 3.82E-08 3-YARD-1 Manholes and Ductlines in the Yard Y 6.20E-09 3.07E-11 1-CTP-1 Cooling Tower Pump House and Cooling Tower Y 4.20E-09 Epsilon 1-DG-1 Diesel Generator Cubicle A Y 4.55E-Epsilon Attachment L-15-150 Page 108 Table 1 - Additional Risk of Recovery Actions for BVPS-1

09 1-PA-1A Primary Auxiliary Building (768'-7") Y 5.51E-10 Epsilon 1-PA-1C Primary Auxiliary Building (752'-6") Y 4.80E-10 Epsilon 1-SB-GEN Service Building and Pipe Chase Y 1.24E-09 Epsilon 1-TO-1 Turbine Oil Storage Room Y 2.41E-10 Epsilon 1-TR-1 Unit 1 - Main Transformer (TR-MT1) Y 6.57E-10 Epsilon 1-TR-2 Unit 1 - Unit Station Service Transformer 1D Y 5.65E-10 Epsilon 1-TR-3 Unit 1 - Unit Station Service Transformer 1C Y 5.65E-10 Epsilon 1-TR-4 Unit 1 - System Station Service Transformer

1A Y 1.56E-09 Epsilon 1-TR-5 Unit 1 - System Station Service Transformer

1B Y 6.60E-10 Epsilon 1-WH-1 Unit 1 Warehouse and Shop Area Y 5.70E-10 Epsilon 3-AIS-1 Alternate Intake Structure Y 4.90E-10 Epsilon 3-ER-1 Emergency Response Facility (ERF)

Substation Y 2.60E-09 Epsilon 3-ER-2 ERF Diesel Generator Building Y 5.23E-10 Epsilon 3-IS-1 Intake Structure Cubicle 1 Y 8.00E-10 Epsilon 3-IS-2 Intake Structure Cubicle 2 Y Epsilon Epsilon 3-IS-6 Intake Structure (all ar eas except 3-IS-1, 2, 3, 4) Y 7.00E-10 Epsilon 3-RH-1 Switchyard Relay House Y 4.20E-09 Epsilon 3-SY-1 Main Switch Yard Y Epsilon Epsilon 1-CO-2 CO2 Storage and PG Water Pump Room N N/A N/A 1-CV-3 Cable Tunnel N N/A N/A 1-FB-1 Fuel Handling / Decon Buildings N N/A N/A 1-H-1 Bulk Hydrogen Storage Tanks in BV1 Yard Area N N/A N/A Attachment L-15-150 Page 109 Table 1 - Additional Risk of Recovery Actions for BVPS-1

1-MS-1 Main Steam Valve Room N N/A N/A 1-PA-1GA Charging Pump Cubicle 1A N N/A N/A 1-PA-1GB Charging Pump Cubicle 1B N N/A N/A 1-PA-1GC Charging Pump Cubicle 1C N N/A N/A 1-SGPD-1 Steam Generator Blowdown Area (752'-6") N N/A N/A 1-VP-1 River Water Valve Pit Train A N N/A N/A 1-VP-2 River Water Valve Pit Train B N N/A N/A 1-WT-1 Refueling Water Storage Tank Area (1QS-TK-1) N N/A N/A 1-WT-10 Primary Plant Demineralized Water Storage Tank (1WT-TK-10) N N/A N/A 1-WT-11 Turbine Plant Demineralized Water Storage Tank (1WT-TK-11) N N/A N/A 1-WT-26 Auxiliary Demineralized Water Storage Tank (1WT-TK-26) N N/A N/A 3-ER-3 Emergency Response Facility N N/A N/A 3-IS-3 Intake Structure Cubicle 3 N N/A N/A 3-IS-4 Intake Structure Cubicle 4 N N/A N/A 3-TR-6 ERF Offsite Power Transformer (TRF-ERFS-3B) N N/A N/A 3-TR-7 ERF Offsite Power Transformer (TRF-ERFS-3A) N N/A N/A Total 2.34E-04 8.66E-06 Epsilon is used to represent the calculat ed delta risk for report ed delta CDFs of less than 1E-10, and similarly for report ed delta LERFs of less than 1E-11. N/A used for compartments with no credited recovery actions.

Attachment L-15-150 Page 110 Table 2 - Additional Risk of Recovery Actions for BVPS-2

2-ASP Alternate Shutdown Panel Room Y 3.39E-08 3.83E-10 2-CB-1 Control Building (Instrument and Relay

Room, Cable Spreading Room, Cable Tunnel) Y 2.85E-04 3.72E-06 2-CB-6 West Communications Room Y 1.42E-05 1.44E-07 2-CV-1 West Cable Vault & Rod Control Room Y 9.38E-06 8.69E-08 2-CV-2 East Cable Vault & Rod Control Area Y 1.14E-07 7.88E-10 2-CV-3 Cable Vault & Rod Control Area Y 1.63E-06 7.29E-09 2-CV-6 Cable Vault & Rod Control Relay Room (755' - 6") Y 2.11E-08 1.52E-10 2-DG-2 Diesel Generator Cubicle Train B Y 2.48E-08 4.31E-10 2-MS-1 Main Steam Valve Area Y 1.70E-10 Epsilon 2-PA-3 Auxiliary Building General Area (710'-6", 718'-6", 735'-6") Y 2.24E-08 4.81E-10 2-RC-1 Reactor Containment Building Y 4.53E-08 5.84E-10 2-SB-1 Service Building Emergency Switchgear Train A Y 1.10E-07 3.53E-08 2-SB-2 Service Building Emergency Switchgear Train B Y 7.06E-08 1.25E-09 2-SB-3 Service Building Cable Spreading Area Y 4.93E-07 3.45E-09 2-SB-4 Service Building Normal Switchgear Y 9.32E-08 1.87E-09 2-SB-8 Service Building Battery Room 2-2 Y 4.63E-10 9.57E-12 2-SG-1S South Safeguards Area Y 2.21E-10 1.96E-12 3-CR-1 Main Control Room Y 2.62E-05 4.05E-07 2-DG-1 Diesel Generator Cubicle A Y 9.35E-09 2.13E-10 2-TB-1 Turbine Building General Area Y 6.81E-07 5.86E-09 Attachment L-15-150 Page 111 Table 2 - Additional Risk of Recovery Actions for BVPS-2

2-TR-4 System Station Service Transformer 2B Y 1.70E-08 2.53E-10 2-TR-5 System Station Service Transformer 2A Y 1.70E-08 2.53E-10 3-IS-2 Intake Structure Cubicle 2 Y 2.97E-09 6.42E-11 3-RH-1 Switchyard Relay House Y 2.76E-08 4.14E-10 3-SY-1 Main Switch Yard Y 8.00E-10 1.05E-11 2-CB-5 Control Building Fan Room (735'-6") Y 2.13E-08 2.13E-09 2-CB-4 Control Building Computer Room (735'-6") N N/A N/A 2-CP-1 Condensate Polishing Building N N/A N/A 2-CTP-1 Cooling Tower Pump House and Cooling Tower N N/A N/A 2-FB-1 Fuel Handling & Decontamination Building N N/A N/A 2-H-1 Bulk Hydrogen Storage Tanks in BV2 Yard Area N N/A N/A 2-PA-5 Auxiliary Building General Area N N/A N/A 2-SB-5 Service Building MFRV Room N N/A N/A 2-SB-7 Service Building Battery Room 2-3 N N/A N/A 2-SB-9 Service Building Battery Room 2-4 N N/A N/A 2-TB-2 Turbine Building Battery Room 2-6 N N/A N/A 2-TR-1 Unit 2 Main Transformer (TR-MT-2) N N/A N/A 2-TR-2 Unit 2 - Unit Station Service Transformer 2C N N/A N/A 2-TR-3 Unit 2 - Unit Station Service Transformer 2D N N/A N/A 2-VP-1 Service Water Valve Pit East Train A N N/A N/A 2-VP-2 Service Water Valve Pit West Train B N N/A N/A 2-WH-1 Unit 2 Waste Handling Building (All Levels) N N/A N/A 2-WT-21 Refueling Water Storage Tank Area (2QSS-TK21) N N/A N/A 2-WT-210 Primary Plant Demineralized Water Storage Tank N N/A N/A 2-WT-211 Turbine Plant Demineralized Water Storage Tank (2WTD-TK211) N N/A N/A 2-WT-23 Demineralized Water Storage Tank (2WTD-TK23) N N/A N/A 3-AIS-1 Alternate Intake Structure N N/A N/A 3-ER-1 ERF Substation N N/A N/A Attachment L-15-150 Page 112 Table 2 - Additional Risk of Recovery Actions for BVPS-2

3-ER-2 ERF Diesel Generator Building N N/A N/A 3-ER-3 Emergency Response Facility N N/A N/A 3-IS-1 Intake Structure Cubicle 1 N N/A N/A 3-IS-4 Intake Structure Cubicle 4 N N/A N/A 3-IS-6 Intake Structure (All ar eas except 3-IS-1, 2, 3, 4) N N/A N/A 3-TR-6 ERF Offsite Power Transformer (TRF-ERFS-3B) N N/A N/A 3-TR-7 ERF Offsite Power Transformer (TRF-ERFS-3A) N N/A N/A 2-CV-4 South Cable Vault and Rod Control Area (773'-6") N N/A N/A 2-CV-5 North Cable Vault and Rod Control Area (773'-6") N N/A N/A 2-PA-3A Charging Pump Cubicle A (735'-6") N N/A N/A 2-PA-3B Charging Pump Cubicle B (735'-6") N N/A N/A 2-PA-3C Charging Pump Cubicle C (735'-6") N N/A N/A 2-PA-4 Auxiliary Building General Area (755'-6") N N/A N/A 2-PA-6 Auxiliary Building MCC Room Train A (755'-6") N N/A N/A 2-PA-7 Auxiliary Building MCC Room Train B (755'-6") N N/A N/A 2-PT-1 Pipe Tunnel Area N N/A N/A 2-SB-10 Service Building Non-Safety Related Battery Room 2-5 (760'-6") N N/A N/A 2-SB-6 Service Building Battery Room 2-1 (730'-6") N N/A N/A 2-SG-1N North Safeguards Area N N/A N/A 3-IS-3 Intake Structure Cubicle 3 N N/A N/A 3-YARD-1 Manholes and Ductlines in the Yard N N/A N/A Total 3.38E-04 4.41E-06 Epsilon is used to represent the calculat ed delta risk for report ed delta CDFs of less than 1E-10, and similarly for report ed delta LERFs of less than 1E-11. N/A used for compartments with no credited recovery actions.

Attachment L-15-150 Page 113

Response:

As part of the LAR Attachment G feasibility assessment, the recovery actions (RA) were reviewed and classified based on whether they are credited for purposes of DID and/or

risk reduction.

Tables 3 and 4 below list the RAs and prim ary control station (PCS) actions from Attachment G of the LAR for BVPS-1 and BV PS-2, respectively. The final column indicates whether the action is a PCS action (contains entry "PCS"), an RA credited for purposes of DID only (contains entry "DID"), credited for risk reduction only (contains entry "RR"), or credited for both DID and risk reduction (contai ns entry "RR and DID").

Note that Tables 3 and 4 below include a column specifying the affected components resulting in VFDRs, which is not strictly required for this response. However, Tables 3

and 4 will be referenced in the response to another RAI (SSD RAI 04(a), to be submitted at a later date) which requests the same differentiation between risk reduction actions and DID actions from LAR Attachment G that is supplied in this response. The response to SSD RAI 04(b) (to be submitted at a later date) will require the information in this additional column in order to ex pand on the details of certain actions.

Attachment G of the LAR will be updated as part of the res ponse to PRA RAI 03, and as part of that update, a column will be added to Tables G-1 a nd G-2 to show whether the action is a PCS action, or an RA cr edited for RR, DID, or RR and DID.

Attachment L-15-150 Page 114 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-2 LI-1FW-475BP LI-1RC-460BP PI-1RC-403BP TI-1RC-410BP BIP Power Use supplementary controls and monitoring from the BIP. BV1-2144 DID 1-CR-2 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B, & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2163 RR 1-CR-2 1VS-AC-1A 1VS-C-1A 1VS-E-4A 1VS-F-40A 1VS-P-3A Install a 5000 CFM [cubic feet per minute] portable fan in the Control Room doorway to supply temporary ventilation. BV1-2476 RR 1-CR-2 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2792 RR 1-CR-3 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B, & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2090 DID 1-CR-3 4KVS-1DF 4KVS-1D-1D10

4KVS-1F-1F7 1-EE-EG-2 PNL-DG-SEQ-2 Align AE and DF bus loads as required. BV1-2094 RR 1-CR-3 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2785 RR 1-CR-4 4KVS-1A-1A1 4KVS-1B-1B1 4KVS-1C-1C1 4KVS-1D-1D1 HYV-1FW-100A HYV-1FW-100B HYV-1FW-100C De-energize 1FW-P-1A at 4KVS-1A & 1B and de-energize 1FW-P-1B at 4KVS-1C & 1D to stop main feedwater flow to the steam generators. BV1-2497 DID Attachment L-15-150 Page 115 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-4 1CH-E-1MOV-1CH-378 De-energize MOV-1CH-381 at 480VUS-1-1P and manually close it OR Manually close 1CH-214 OR manually close 1CH-216 to isolate seal return. BV1-2499 RR 1-CR-4 Spurious SI 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1DF-1F11-P 4KVS-1DF-1F15-P De-energize 1CH-P-1A(C) at 4KVS-1AE OR De-energize 1CH-P-1B(C) at 4KVS-1DF to control charging/HHSI flow. BV1-2500 DID 1-CR-4 4KVS-1AE 4KVS-1AE-1E7 4KVS-1AE-1E9 4KVS-1AE-1E12 4KVS-1AE-1E14-OCT 1EEEG1 PNL-DG-SEQ-1 Align AE and DF bus loads as required. BV1-2501 RR 1-CR-4 4KVS-1AE-1E16 MOV-1FW-151B MOV-1FW-151D MOV-1FW-151F Start 1FW-P-3A at 4KVS-1AE to provide train A AFW flow. De-energize MOV-1FW-151B, D & F at 480VUS-1-1N. Manually throttle MOV-1FW-151F to control SG A AFW flow. Manually throttle MOV-1FW-151D to control SG B AFW flow. Manually throttle MOV-1FW-151B to control SG C AFW flow. BV1-2504 DID 1-CR-4 4KVS-1AE-1E16 MOV-1MS-105 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151B MOV-1FW-151C MOV-1FW-151D MOV-1FW-151E MOV-1FW-151F De-energize 1FW-P-3B at 4KVS-1DF to stop train B AFW flow. De-energize MOV-1FW-151B, D & F at 480VUS-1-1N. Manually throttle MOV-1FW-151F to control SG A AFW flow. Manually throttle MOV-1FW-151D to control SG B AFW flow. Manually throttle MOV-1FW-151B to control SG C AFW flow. BV1-2505 RR 1-CR-4 LT-1QS-100A LT-1QS-100B LT-1QS-100C LT-1QS-100D 1-MTR-SIGNAL De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction.

De-energize 1SI-P-1A at 4KVS-1AE and De-energize 1SI-P-1B at 4KVS-1DF to stop flow from the containment sump. De-energize MOV-1CH-115B at 480VUS-1-1N and open it to align suction to the charging pumps. Manually start 1CH-P-1A or 1CH-P-1C at 4KVS-1AE to provide RCS makeup flow. BV1-2506 DID Attachment L-15-150 Page 116 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-4 4KVS-1AE-1E2 4KVS-1AE-1E10 4KVS-1AE-1E14 Trip the #1 diesel to prevent damage. Align 4KVS-1AE for diesel start. Restart the #1 diesel. Manually start 1WR-P-1A or 1C at 4KVS-1AE. Start other AE bus loads as required. BV1-2507 DID 1-CR-4 480VUS-1-8N12480VUS-1-9P12480VUS-1-1B7480VUS-1-8N13480VUS-1-9P13 De-energize the A and D group heaters at 480VUS18-N, de-energize the control group heater at 480VUS11B and de-energize the B and E group heaters at 480VUS19-P to prevent RCS overpressure. BV1-2508 DID 1-CR-4 480VUS-1-8N4 480VUS-1-9P5

1-CIB-SPUR De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2510 RR 1-CR-4 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 PCV-1RC-455A PCV-1RC-455B De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2511 RR 1-CR-4 PCV-1MS-101A-P PCV-1MS-101B-P PCV-1MS-101C-P HCV-1MS-104-P Manually close PCV-1MS-101A to stop SG A steam flow.

Manually close PCV-1MS-101B to stop SG B steam flow. Manually close PCV-1MS-101C to stop SG C steam flow. Manually close HCV-1MS-104 to stop SG A B & C steam flow. BV1-2515 RR 1-CR-4 SOV-1RC-102B SOV-1RC-103B SOV-1RC-105 LI-1FW-475BP LI-1RC-460BP NI-1NI-32A PI-1RC-403BP TI-1RC-410BP TI-1RC-29BP BIP Power Use supplementary controls and monitoring from the BIP. BV1-2517 DID 1-CR-4 MOV-1CH-289 De-energize MOV-1CH-289 at 480VUS-1-1n and manually close it, OR Close manual valve 1CH-30 to stop excessive RCS makeup. BV1-2518 RR Attachment L-15-150 Page 117 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-4 MOV-1RW-103AMOV-1RW-103BMOV-1RW-103CMOV-1RW-103DMOV-1RW-106AMOV-1RW-106BMOV-1RW-114AMOV-1RW-114BMOV-1RW-104AMOV-1RW-104BMOV-1RW-104CMOV-1RW-104DMOV-1RW-1041-CIB-SPUR De-energize MOV-1RW-103A at 480VUS-1-1N, de-energize MOV-1RW-103B at 480VUS-1-1P and close both valves. BV1-2520 RR 1-CR-4 MOV-1RW-102A2 MOV-1RW-106A MOV-1RW-114A MOV-1RW-103A 1-CIB-SPUR Trip the #1 diesel to prevent damage.

Deenergize MOV-1RW-106A at 480VUS-1-1P, de-energize MOV-1RW-114A at 480VUS-1-1N and open both valves. Align 4KVS-1AE for diesel start.

Restart the #1 diesel. De-energize MOV-1RW-102C1 at MCC1-E2 and manually close it. Manually start 1WR-P-1C at 4KVS-1AE to provide River Water flow, OR De-energize MOV-1RW-102A2 at MCC1-E1 and manually throttle it 10% open THEN manually start 1WR-P-1A at 4KVS-1AE and manually open MOV-1RW-102A2 to provide River Water flow.

Start other AE bus loads as required. BV1-2521 RR 1-CR-4 MOV-1RW-113A MOV-1RW-113B Deenergize MOV-1RW-113A at MCC1-E7 and open it. BV1-2522 RR 1-CR-4 MOV-1SI-836-P MOV-1SI-869A-P MOV-1SI-869B-P MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D Spurious SI De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to stop excessive RCS makeup flow.

De-energize MOV-1SI-836, 867A and 869A at 480VUS-1-1N, de-energize MOV-1SI-867B and 869B at 480VUS-1-1P and manually close the valves to isolate the SI flow paths. Manually start 1CH-P-1A or 1CH-P-1C at 4KVS-1AE to provide RCS makeup flow.

BV1-2523 BV1-2528 DID Attachment L-15-150 Page 118 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-4 MOV-1SI-869B De-energize MOV-1SI-869B at 480VUS-1-1P and manually throttle to provide an alternate makeup flow path. BV1-2524 DID 1-CR-4 1WT-TK-10 Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valves. BV1-2530 DID 1-CR-4 PCV-1RC-455C-P PCV-1RC-455D-P PCV-1RC-456-P PT-1RC-444 PT-1RC-445 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2534 RR 1-CR-4 1VS-AC-1A 1VS-C-1A 1VS-E-4A 1VS-F-40A 1VS-P-3A Close PCV-1RC-455C, PCV-1RC-455D and PCV-1RC-456 at the keylock switches to stop RCS depressurization. BV1-2535 RR 1-CR-4 MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1AE-1E11 4KVS-1AE-1E15 Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV1-2569 RR 1-CR-4 LCV-1CH-460A SW-ISO-CH460A De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction. De-energize MOV-1CH-115B at 480VUS-1-1N and open it to align suction to the charging pumps. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2571 RR 1-CR-4 LCV-1CH-460A SW-ISO-CH460A Close LCV-1CH-460 at the keylock switch to isolate letdown. BV1-2711 RR 1-CR-4 4KVS-1B-1B2 4KVS-1D-1D2 De-energize 1CN-P-1A at 4KVS-1B and de-energize 1CN-P-1A at 4KVS-1B to stop condensate flow to the steam generators. BV1-2765 DID 1-CR-4 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2859 RR Attachment L-15-150 Page 119 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CR-4 PCV-1RC-455DPCV-1RC-456 Transfer control of reactor head vent valves SOV-RC102B, 103B and 105 to the BIP and open the valves as necessary for RCS depressurization. To align Containment Sump recirculation to maintain long-term cooling, perform the following. De-energize MOV-1SI-860A and 863A at 480VUS-1-1N and open them, de-energize MOV-1SI-885A and 885C at 480VUS-1-1N and close them, de-energize MOV-1CH-115B at 480VUS-1-1N and close it and de-energize MOV-1SI-862A at 480VUS-1-1N and close it. BV1-2886 DID 1-CR-4 MOV-1CH-115C De-energize MOV-1CH-115C at 480VUS-1-1N and close it or De-energize MOV-1CH-115E at 480VUS-1-1P and close it to prevent hydrogen intrusion into the suction of the charging pumps. BV1-2912 RR 1-CS-1 1VS-AC-1B 1VS-C-1B 1VS-E-4B 1VS-F-40B 1VS-P-3B Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV1-2478 RR 1-CS-1 1CH-E-1 MOV-1CH-381 De-energize MOV-1CH-381 at 480VUS-1-P and manually close it OR Manually close 1CH-214 OR manually close 1CH-216 to isolate seal return. BV1-2537 RR 1-CS-1 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151C MOV-1FW-151E Manually start 1FW-P-3B at 4KVS-1DF. De-energize MOV-1FW-151A, C & E at 480VUS-1-P . Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2540 DID 1-CS-1 LT-1QS-100A LT-1QS-100B LT-1QS-100C LT-1QS-100D 1-MTR-SIGNAL De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction.

De-energize 1SI-P-1A at 4KVS-1AE and De-energize 1SI-P-1B at 4KVS-1DF to stop flow from the containment sump. De-energize MOV-1CH-115D at 480VUS-1-P and open it to align suction to the charging pumps. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2541 DID 1-CS-1 4KVS-1DF-1F2 4KVS-1DF-1F10 4KVS-1DF-1F14 Trip the #2 diesel to prevent damage. Align 4KVS-1DF for diesel start.

Restart the #2 diesel. Manually start 1WR-P-1B or 1C at 4KVS-1DF. Start other DF bus loads as required. BV1-2542 DID Attachment L-15-150 Page 120 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CS-1 480VUS-1-8N12 480VUS-1-9P12 480VUS-1-1B7 480VUS-1-8N13 480VUS-1-9P13 De-energize the A and D group heaters at 480VUS18-N, de-energize the control group heater at 480VUS11B and de-energize the B and E group heaters at 480VUS19-P to prevent RCS overpressure. BV1-2543 DID 1-CS-1 480VUS-1-8N4 480VUS-1-9P5 1-CIB-SPUR De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2544 RR 1-CS-1 Spurious SI 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1DF-1F11-P 4KVS-1DF-1F15-P De-energize 1CH-P-1A(C) at 4KVS-1AE OR De-energize 1CH-P-1B(C) at 4KVS-1DF to control charging/HHSI flow. BV1-2545 DID 1-CS-1 4KVS-1DF 4KVS-1DF-1F1-OCT 4KVS-1DF-1F2-OCT 4KVS-1DF-1F5 4KVS-1DF-1F7 4KVS-1DF-1F8-OCT 4KVS-1DF-1F9 4KVS-1DF-1F13-OCT 4KVS-1DF-1F15-OCT 1EE-EG-2 4KVS-1DF-F12 PNL-DG-SEQ-2 Align AE and DF bus loads as required. BV1-2546 RR 1-CS-1 FCV-1FW-103B Isolate and vent the instrument air to fail FCV-1FW-103B closed to ensure adequate AFW flow. BV1-2550 DID 1-CS-1 LCV-1CH-460A SW-ISO-CH460A Close LCV-1CH-460 at the keylock switch to isolate letdown. BV1-2552 RR Attachment L-15-150 Page 121 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CS-1 MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1AE-1E11 De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction De-energize MOV-1CH-115D at 480VUS-1-P and open it to align suction to the charging pumps. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2553 RR 1-CS-1 MOV-1CH-289 De-energize MOV-1CH-289 at 480VUS-1-N and manually close it, OR Close manual valve 1CH-30 to stop excessive RCS makeup. BV1-2554 DID 1-CS-1 4KVS-1AE-1E16 MOV-1MS-105 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151B MOV-1FW-151C MOV-1FW-151D MOV-1FW-151E MOV-1FW-151F MOV-1MS-105 De-energize 1FW-P-3A at 4KVS-1AE and manually trip 1FW-P-2 to stop train A AFW flow. De-energize MOV-1FW-151A, C & E at 480VUS-1-P. Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2555 DID 1-CS-1 MOV-1RW-103A MOV-1RW-103B MOV-1RW-103C MOV-1RW-103D MOV-1RW-106A MOV-1RW-106B MOV-1RW-114A MOV-1RW-114B MOV-1RW-104A MOV-1RW-104B MOV-1RW-104C MOV-1RW-104D MOV-1RW-104 MOV-1RW-116A MOV-1RW-116B 1-CIB-SPUR De-energize MOV-1RW-103C at 480VUS-1-N, de-energize MOV-1RW-103D at 480VUS-1-P and close both valves. BV1-2557 DID Attachment L-15-150 Page 122 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CS-1 MOV-1RW-102B1 MOV-1RW-106B MOV-1RW-114B MOV-1RW-103A 1-CIB-SPUR Trip the #2 diesel to prevent damage. Deenergize MOV-1RW-106B at 480VUS-1-P, de-energize MOV-1RW-114B at 480VUS-1-N and open both valves. Align 4KVS-1DF for diesel start. Restart the #2 diesel. De-energize MOV-1RW-102B2 at MCC1-E1 and manually close it. De-energize MOV-1RW-102B1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1B at 4KVS-1DF and manually open MOV-1RW-102B1 to provide River Water flow, OR De-energize MOV-1RW-102C2 at MCC1-E1 and manually close it. De-energize MOV-1RW-102C1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1C at 4KVS-1DF and manually open MOV-1RW-102C1 to provide River Water flow. Start other DF bus loads as required. BV1-2558 DID 1-CS-1 MOV-1SI-836-P MOV-1SI-869A-P MOV-1SI-869B-P MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D Spurious SI De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to stop excessive RCS makeup flow. De-energize MOV-1SI-836, 867A and 869A at 480VUS-1-N, de-energize MOV-1SI-867B and 869B at 480VUS-1-P and manually close the valves to isolate the SI flow paths. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2559 BV1-2578 DID 1-CS-1 PCV-1MS-101A-P PCV-1MS-101B-P PCV-1MS-101C-P HCV-1MS-104-P Manually close PCV-1MS-101A to stop SG A steam flow.

Manually close PCV-1MS-101B to stop SG B steam flow. Manually close PCV-1MS-101C to stop SG C steam flow. Manually close HCV-1MS-104 to stop SG A B & C steam flow. BV1-2560 DID 1-CS-1 PCV-1RC-455C-PPCV-1RC-455D-PPCV-1RC-456-P PT-1RC-444PT-1RC-445 Close PCV-1RC-455C, PCV-1RC-455D and PCV-1RC-456 at the keylock switches to stop RCS depressurization. BV1-2561 RR Attachment L-15-150 Page 123 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CS-1 TV-1BD-100A TV-1BD-100B TV-1BD-100C TV-1BD-101A1 TV-1BD-101A2 TV-1BD-101B1 TV-1BD-101B2 TV-1BD-101C1 TV-1BD-101C2 TV-1BD-107A TV-1BD-107B TV-1BD-107C De-energize TV-1BD-100A, B & C at PNL-DC-3, de-energize TV-1BD-101A1, B1 & C1 at PNL-VITBUS-1 and de-energize TV-1BD-101A2, B2 & C2 at PNL-VITBUS-2 to stop blowdown flow. BV1-2565 DID 1-CS-1 TV-1MS-101A TV-1MS-101B TV-1MS-101C Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valves. BV1-2566 DID 1-CS-1 4KVS-1A-1A1 4KVS-1B-1B1 4KVS-1C-1C1 4KVS-1D-1D1 HYV-1FW-100A HYV-1FW-100B HYV-1FW-100C De-energize 1FW-P-1A at 4KVS-1A & 1B and de-energize 1FW-P-1B at 4KVS-1C & 1D to stop main feedwater flow to the steam generators. BV1-2576 DID 1-CS-1 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 PCV-1RC-455A PCV-1RC-455B De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2579 RR 1-CS-1 MOV-1RW-113C MOV-1RW-113D1 Deenergize MOV-1RW-113B at MCC1-E8 and open it. BV1-2586 DID 1-CS-1 MOV-1SI-869B De-energize MOV-1SI-869B at 480VUS-1-P and manually throttle it to provide an alternate makeup flow path. BV1-2587 DID 1-CS-1 4KVS-1B-1B2 4KVS-1D-1D2 De-energize 1CN-P-1A at 4KVS-1B and de-energize 1CN-P-1A at 4KVS-1B to stop condensate flow to the steam generators. BV1-2764 DID Attachment L-15-150 Page 124 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CS-1 PCV-1MS-101APCV-1MS-101BPCV-1MS-101CHCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2860 DID 1-CS-1 PCV-1RC-455C MOV-1RC-535-P Transfer control of reactor head vent valves SOV-RC102B, 103B and 105 to the BIP and open the valves as necessary for RCS depressurization. To align Containment Sump recirculation to maintain long-term cooling, perform the following. De-energize MOV-1SI-860B and 863B at 480VUS-1-P and open them, de-energize MOV-1SI-885B and 885D at 480VUS-1-P and close them, de-energize MOV-1CH-115D at 480VUS-1-P and close it and de-energize MOV-1SI-862B at 480VUS-1-P and close it. BV1-2887 DID 1-CS-1 MOV-1CH-115C De-energize MOV-1CH-115C at 480VUS-1-N and close it or De-energize MOV-1CH-115E at 480VUS-1-P and close it to prevent hydrogen intrusion into the suction of the charging pumps. BV1-2920 RR 1-CV-1 PCV-1MS-101A-P PCV-1MS-101B-P

PCV-1MS-101C-P Manually close PCV-1MS-101A to stop SG A steam flow. Manually close PCV-1MS-101B to stop SG B steam flow. Manually close PCV-1MS-101C to stop SG C steam flow. BV1-2128 DID 1-CV-1 MOV1CH115CP De-energize MOV-1CH-115D at 480VUS-1-1P and open it to align suction to the charging pumps. BV1-2129 DID 1-CV-1 MOV-1MS-105 4KVS-1AE-1E16 MOV-1FW-151A MOV-1FW-151B MOV-1FW-151C MOV-1FW-151D MOV-1FW-151E MOV-1FW-151F De-energize 1FW-P-3A at 4KVS-1AE and manually trip 1FW-P-2 to stop train A AFW flow. De-energize MOV-1FW-151A, C & E at 480VUS-1-1P. Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2133 RR 1-CV-1 MOV-1SI-836-P MOV-1SI-869A-P MOV-1SI-867A MOV-1SI-867C Spurious SI De-energize MOV-1SI-836, 867A and 869A at 480VUS-1-1N and manually close them to isolate the SI flow paths.

BV1-2135 BV1-2757 DID Attachment L-15-150 Page 125 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CV-1 4KVS-1A-1A54KVS-1B-1B54KVS-1C-1C5PCV-1RC-455APCV-1RC-455B De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2138 RR 1-CV-1 480VUS-1-8N4 480VUS-1-9P5 1-CIB-SPUR De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2139 DID 1-CV-1 TV-1MS-101C Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valve. BV1-2140 DID 1-CV-1 MOV-1CH-289 De-energize MOV-1CH-289 at 480VUS-1-1N and manually close it, OR Close manual valve 1CH-30 to stop excessive RCS makeup. BV1-2156 RR 1-CV-1 FCV-1FW-103B Isolate and vent the instrument air to fail FCV-1FW-103B closed to ensure adequate AFW flow. BV1-2158 DID 1-CV-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2739 RR 1-CV-1 PCV-1MS-101A PCV-1MS-101B PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2861 RR 1-CV-1 MOV-1RW-103AMOV-1RW-103BMOV-1RW-103CMOV-1RW-103DMOV-1RW-104AMOV-1RW-104BMOV-1RW-104CMOV-1RW-104DMOV-1RW-1041-CIB-SPUR De-energize MOV-1RW-103C at 480VUS-1-1N and close it. De-energize MOV-1RW-103D at MCC1-E4 and close it. BV1-2874 DID 1-CV-1 MOV-1RW-114B 1-CIB-SPUR Deenergize MOV-1RW-114B at 480VUS-1-1N and open it. Align 4KVS-1DF for diesel start.

Manually start 1WR-P-1B or 1C at 4KVS-1DF to provide River Water flow. Start other DF bus loads as required. BV1-2876 DID Attachment L-15-150 Page 126 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CV-1 MOV-1FW-151A MOV-1FW-151C MOV-1FW-151E De-energize MOV-1FW-151A, C & E at 480VUS-1-1P. Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2929 DID 1-CV-2 MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B De-energize MOV-1CH-115B at MCC1-E3 and open it to align suction to the charging pumps. BV1-2111 RR 1-CV-2 PCV-1MS-101B-PPCV-1MS-101C-P Manually close PCV-1MS-101B to stop SG B steam flow.

Manually close PCV-1MS-101C to stop SG C steam flow. BV1-2114 DID 1-CV-2 480VUS-1-8N4 480VUS-1-9P5 1-CIB-SPUR De-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2119 RR 1-CV-2 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2740 RR 1-CV-2 MOV-1SI-869B-P MOV-1SI-867A MOV-1SI-867B MOV-1SI-867D De-energize MOV-1SI-867D and 869B at 480VUS-1-1P and manually close them to isolate the SI flow paths.

BV1-2120 BV1-2755 DID 1-CV-2 MOV-1SI-869B De-energize MOV-1SI-869B at 480VUS-1-9P and manually throttle it to provide RCS makeup flow. BV1-2756 DID 1-CV-2 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2862 RR 1-CV-2 MOV-1RW-103A MOV-1RW-103B MOV-1RW-103C MOV-1RW-103D MOV-1RW-104B MOV-1RW-104D MOV-1RW-104 MOV-1RW-106A MOV-1RW-114A MOV-1RW-106B MOV-1RW-114B 1-CIB-SPUR De-energize MOV-1RW-103A at MCC1-E3, de-energize MOV-1RW-103B at MCC1-E4 and close both valves.

BV1-2877 RR Attachment L-15-150 Page 127 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-CV-2 MOV-1RW-106AMOV-1RW-114AMOV-1RW-103AMOV-1RW-103B1-CIB-SPUR Deenergize MOV-1RW-106A at MCC1-E4, de-energize MOV-1RW-114A at MCC1-E3 and open both valves. Align 4KVS-1AE for diesel start. De-energize MOV-1RW-102C1 at MCC1-E2 and manually close it. Manually start 1WR-P-1C at 4KVS-1AE to provide River Water flow, OR De-energize MOV-1RW-102A2 at MCC1-E1 and manually throttle it 10% open THEN manually start 1WR-P-1A at 4KVS-1AE and manually open MOV-1RW-102A2 to provide River Water flow. Start other AE bus loads as required. BV1-2878 RR 1-CV-2 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2973 DID 1-CV-3 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2308 DID 1-CV-3 1VS-D-22-1B 1VS-D-22-2C 1VS-D-22-2D 1VS-F-22B Install temporary ventilation for the running diesel. BV1-2311 DID 1-CV-3 MOV-1MS-105 MOV-1FW-151B MOV-1FW-151D MOV-1FW-151F Manually trip the Turbine Driven Auxiliary Feedwater Pump to prevent SG overfill. BV1-2927 DID 1-DG-2 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2071 RR 1-DG-2 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2741 RR 1-ES-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-1810 RR 1-ES-1 480VUS-1-8N12 480VUS-1-8N13 480VUS-1-9P13 De-energize the A and D group heaters by manually stopping the #1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-1A AND de-energize the E group heater at 480VUS19-P to prevent RCS overpressure. BV1-2052 DID Attachment L-15-150 Page 128 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-ES-1 4KVS-1A-1A1 HYV-1FW-100A HYV-1FW-100B HYV-1FW-100C De-energize 1FW-P-1A at 4KVS-1A to stop main feedwater flow to the steam generators. BV1-2054 DID 1-ES-1 4KVS-1A-1A5 De-energize 1RC-P-1A at 4KVS-1A to prevent an RCP seal LOCA. BV1-2055 DID 1-ES-1 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P De-energize 1CH-P1A and 1CH-P1C by manually stopping the #1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-1A to stop excessive RCS makeup. BV1-2131 DID 1-ES-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2742 RR 1-ES-1 MOV-1SI-867A MOV-1SI-867C Spurious SI De-energize MOV-1SI-867A by manually stopping the #1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-1A, then manually close MOV-1SI-867A to isolate the SI flow path. BV1-3000 DID 1-ES-2 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2060 RR 1-ES-2 1VS-AC-1A 1VS-C-1A 1VS-E-4A 1VS-F-40A 1VS-P-3A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV1-2061 RR 1-ES-2 480VUS-1-9P12 480VUS-1-9P13 De-energize the B and E group heaters by manually stopping the #2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-1D to prevent RCS overpressure. BV1-2063 DID 1-ES-2 4KVS-1B-1B5 De-energize 1RC-P-1B at 4KVS-1B to prevent an RCP seal LOCA. BV1-2066 RR 1-ES-2 4KVS-1DF-1F11-P 4KVS-1DF-1F15-P De-energize 1CH-P1B and 1CH-P1C by manually stopping the #2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-1D to stop excessive RCS makeup. BV1-2108 DID 1-ES-2 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151C MOV-1FW-151E MOV-1MS-105 De-energize 1FW-P-3B at 4KVS-1DF to stop train B AFW flow. BV1-2415 RR 1-ES-2 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2481 RR Attachment L-15-150 Page 129 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-ES-2 4KVS-1AE 4KVS-1AE-1E7 4KVS-1AE-1E9 1EEEG1 PNL-DG-SEQ-1 4KVS-1AE-1E12 Align AE and DF bus loads as required. BV1-2815 RR 1-ES-2 MOV-1SI-867B MOV-1SI-867D Spurious SI De-energize MOV-1SI-867A by manually stopping the #1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-1A, then manually close MOV-1SI-867A to isolate the SI flow path. BV1-3001 DID 1-MG-1 1VS-AC-1A1VS-C-1A1VS-E-4A1VS-F-40A1VS-P-3A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV1-2479 RR 1-MG-1 PNL-DG- SEQ-1 Align AE and DF bus loads as required. BV1-2597 RR 1-MG-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2743 RR 1-MG-1 PCV-1MS-101A PCV-1MS-101B PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2900 RR 1-MS-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Initially, decay heat removal will be via the main steam code safeties. In the event that a main steam code safety sticks open, provide RCS makeup from the RWST to compensate from the reactivity change and RCS shrink. Actions to be performed in the Control Room.

BV1-2193 PCS 1-MS-1 TV-1MS-101A TV-1MS-101B TV-1MS-101C Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valve. BV1-2194 DID 1-MS-1 PCV-1MS-101A-P PCV-1MS-101B-P

PCV-1MS-101C-P HCV-1MS-104-P Provide RCS makeup from the RWST to compensate for reactivity change and RCS shrink. Actions to be performed in Control Room.

BV1-2965 PCS 1-MS-1 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2971 DID Attachment L-15-150 Page 130 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-NS-1 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 De-energize 1RC-P-1A, 1B and 1C by tripping OCB 83, OCB 92, PCB 331 AND PCB 341 at the Switchyard Relay Building to prevent an RCP seal LOCA. BV1-2603 RR 1-NS-1 4KVS-1DF 4KVS-1DF-1F7 4KVS-1DF-1F9 PNL-DG-SEQ-2 Align AE and DF bus loads as required. BV1-2606 RR 1-NS-1 4KVS-1AE-1E16 4KVS-1DF-1F16 MOV1FW151A MOV1FW151B MOV1FW151C MOV1FW151D M OV1FW151E MOV1FW151F De-energize 1FW-P-3B at 4KVS-1DF to stop train B AFW flow. De-energize MOV-1FW-151B, D & F at MCC1-E5. Manually throttle MOV-1FW-151F to control SG A AFW flow. Manually throttle MOV-1FW-151D to control SG B AFW flow. Manually throttle MOV-1FW-151B to control SG C AFW flow. BV1-2608 RR 1-NS-1 480VUS-1-8N12 480VUS-1-9P12 480VUS-1-1B7 480VUS-1-8N13 480VUS-1-9P13 De-energize the A and D group heaters at 480VUS18-N, de-energize the control group heater by tripping OCB 83, OCB 92, PCB 331 AND PCB 341 at the Switchyard Relay Building and de-energize the B and E group heaters at 480VUS19-P to prevent RCS overpressure. BV1-2610 DID 1-NS-1 LI-1RC-460BP TI-1RC-410BP BIP Power Energize the BIP and monitor the primary parameters remotely from the BIP. BV1-2613 DID 1-NS-1 4KVS-1DF-1F11-P 4KVS-1DF-1F15-P De-energize 1CH-P-1B and 1C at 4KVS-1DF to stop excessive RCS makeup flow. BV1-2615 DID 1-NS-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2616 RR 1-NS-1 PCV-1MS-101A PCV-1MS-101B PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2704 RR 1-NS-1 4KVS-1DF-1F10 Swap River Water pump breakers at 4KVS-1DF. Manually start 1WR-P-1C at 4KVS-1DF. BV1-2708 DID Attachment L-15-150 Page 131 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-NS-1 MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D Spurious SI De-energize 1CH-P-1B(C) at 4KVS-1DF to stop excessive RCS makeup flow. De-energize MOV-1SI-867A at MCC1-E5, de-energize MOV-1SI-867B at MCC1-E6 and manually close the valves to isolate the SI flow path. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2872 DID 1-NS-1 4KVS-1DF-1F11 4KVS-1DF-1F15 Manually start 1CH-P-1B and 1C at 4KVS-1DF to provide RCS makeup flow. BV1-2994 DID 1-PA-1E PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2009 RR 1-PA-1E MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B De-energize MOV-1CH-115D at MCC1-E4 and open it to align suction to the charging pumps. BV1-2012 DID 1-PA-1E 4KVS-1DF 4KVS-1DF-1F1-OCT 4KVS-1DF-1F4-OCT 4KVS-1DF-1F7 4KVS-1DF-1F9 Align AE and DF bus loads as required. BV1-2013 RR 1-PA-1E MOV-1RW-106B MOV-1RW-114B Deenergize MOV-1RW-106B at MCC1-E4, de-energize MOV-1RW-114B at MCC1-E3 and open both valves.

Align 4KVS-1DF for diesel start. De-energize MOV-1RW-102B2 at MCC1-E1 and manually close it. De-energize MOV-1RW-102B1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1B at 4KVS-1DF and manually open MOV-1RW-102B1 to provide River Water flow, OR De-energize MOV-1RW-102C2 at MCC1-E1 and manually close it. DE-energize MOV-1RW-102C1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1C at 4KVS-1DF and manually open MOV-1RW-102C1 to provide River Water flow. Start other DF bus loads as required. BV1-2016 RR 1-PA-1E 1VS-F-16B 1VS-F-55B Install portable ventilation for Emergency Switchgear. BV1-2017 RR 1-PA-1E 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2784 RR Attachment L-15-150 Page 132 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-PA-1E MOV-1RW-103A MOV-1RW-103B MOV-1RW-103C MOV-1RW-103D MOV-1RW-106A MOV-1RW-106B MOV-1RW-114A MOV-1RW-114B MOV-1RW-104A MOV-1RW-104C MOV-1RW-116A MOV-1RW-116B De-energize MOV-1RW-103C at MCC1-E3, de-energize MOV-1RW-103D at MCC1-E4 and close both valves.

BV1-2999 DID 1-PA-1G MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B Rack breaker for 1CH-P-1C off of 4KVS-1DF and rack breaker for 1CH-P-1B onto 4KVS-1DF to allow the pump to be started from the Control Room BV1-2024 DID 1-PA-1G PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2020 RR 1-PA-1G 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2631 RR 1-PT-1 PCV-1MS-101A-P PCV-1MS-101B-P PCV-1MS-101C-P HCV-1MS-104-P Manually close PCV-1MS-101A to stop SG A steam flow.

Manually close PCV-1MS-101B to stop SG B steam flow. Manually close PCV-1MS-101C to stop SG C steam flow. Manually close HCV-1MS-104 to stop SG A B & C steam flow. BV1-2177 RR 1-PT-1 480VUS-1-8N4 480VUS-1-9P5 1-CIB-SPUR De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2179 DID 1-PT-1 MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D De-energize MOV-1SI-867A at MCC1-E5, de-energize MOV-1SI-867B at MCC1-E6 and manually close the valves to isolate the SI flow path. BV1-2180 DID 1-PT-1 MOV-1CH-289 De-energize MOV-1CH-289 at MCC1-E5 and manually close it, OR Close manual valve 1CH-30 to stop excessive RCS makeup. BV1-2181 RR Attachment L-15-150 Page 133 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-PT-1 LT-1QS-100A LT-1QS-100B LT-1QS-100C LT-1QS-100D De-energize 1SI-P-1A at 4KVS-1AE and De-energize 1SI-P-1B at 4KVS-1DF to stop flow from the containment sump. De-energize MOV-1CH-115B at MCC1-E3 and open it to align suction to the charging pumps. BV1-2183 DID 1-PT-1 FCV-1FW-103A Isolate and vent the instrument air to fail FCV-1FW-103A closed to ensure adequate AFW flow. BV1-2184 DID 1-PT-1 MOV-1RW-103A MOV-1RW-103B MOV-1RW-103C MOV-1RW-103D MOV-1RW-104A MOV-1RW-104B MOV-1RW-104C MOV-1RW-104D MOV-1RW-104 1-CIB-SPUR De-energize MOV-1RW-103A at MCC1-E3, de-energize MOV-1RW-103B at MCC1-E4 and close both valves. BV1-2185 DID 1-PT-1 MOV-1RW-106A MOV-1RW-114A 1-CIB-SPUR Deenergize MOV-1RW-106A at MCC1-E4, de-energize MOV-1RW-114A at MCC1-E3 and open both valves. Align 4KVS-1AE for diesel start. De-energize MOV-1RW-102C1 at MCC1-E2 and manually close it. Manually start 1WR-P-1C at 4KVS-1AE to provide River Water flow, OR De-energize MOV-1RW-102A2 at MCC1-E1 and manually throttle it 10% open THEN manually start 1WR-P-1A at 4KVS-1AE and manually open MOV-1RW-102A2 to provide River Water flow. Start other AE bus loads as required. BV1-2186 DID 1-PT-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2746 RR 1-PT-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2863 RR 1-QP-1 4KVS-1AE-1E16 MOV-1FW-151B MOV-1FW-151D MOV-1FW-151F 1FW-P-3A Open HYV-1FW-100A at 1FW-PNL-100A, open HYV-1FW-100B at 1FW-PNL-100B, open HYV-1FW-100C at 1FW-PNL-100C, manually open MOV-1FW-155A, manually open MOV-1FW-155B, manually open MOV-1FW-155C, manually open FCV-1FW-479, manually open FCV-1FW-489 and manually open FCV-1FW-499 to align the flow path from 1FW-P4 to the steam generators. Locally start 1FW-P-4, locally open MOV-1FW-160 and manually throttle FCV-1FW-479 to control SG A feed flow, manually throttle FCV-1FW-489 to control SG B and manually throttle FCV-1FW-499 to control SG C feed flow. BV1-2236 RR Attachment L-15-150 Page 134 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-QP-1 480VUS-1-8N4 480VUS-1-9P5 De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2237 DID 1-QP-1 4KVS-1AE-1E16-OCT Align AE and DF bus loads as required. BV1-2238 RR 1-QP-1 PCV-1MS-101A-P PCV-1MS-101B-P PCV-1MS-101C-P HCV-1MS-104-P Manually throttle PCV-1MS-101A to control SG A steam flow.

Manually throttle PCV-1MS-101B to control SG B steam flow. Manually throttle PCV-1MS-101C to control SG C steam flow.

Manually throttle HCV-1MS-104 to control SG A B & C steam flow. BV1-2241 DID 1-QP-1 4KVS-1AE-1E16 4KVS-1DF-1F16 MOV-1MS-105 MOV-1FW-151A MOV-1FW-151B MOV-1FW-151C MOV-1FW-151D MOV-1FW-151E MOV-1FW-151F De-energize 1FW-P-3B at 4KVS-1DF to stop train B AFW flow. De-energize 1FW-P-3A at 4KVS-1AE and de-energize MOV-1MS-105 at MCC1-E6 and manually close it to stop train A AFW flow. BV1-2242 RR 1-QP-1 MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D De-energize MOV-1SI-867A at MCC1-E5, de-energize MOV-1SI-867B at MCC1-E6 and manually close the valves to isolate the SI flow path. BV1-2243 DID 1-QP-1 TV-1MS-101A TV-1MS-101B TV-1MS-101C Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valves. They are in the fire. Att. S BV1-3039 will install valves to permit isolation of air from outside this fire compartment (RAI 03)

BV1-2644 RR 1-QP-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually close HCV-1MS-104 to stop SG A, B & C steam flow.

Manually close PCV-1MS-101A to stop SG A steam flow, manually close PCV-1MS-101B to stop SG B steam flow and manually close PCV-1MS-101C to stop SG C steam flow. BV1-2864 DID 1-QP-1 FCV-1FW-103A De-energize 1FW-P-3B at 4KVS-1DF to stop train B AFW flow. BV1-2972 RR 1-RC-1 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 PCV-1RC-455A PCV-1RC-455B De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2149 RR Attachment L-15-150 Page 135 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 1-RC-1 PCV-1RC-455C-P PCV-1RC-455D-P PCV-1RC-456-P PT-1RC-444 PT-1RC-445 Close PCV-1RC-455C, PCV-1RC-455D and PCV-1RC-456 at the keylock switches to stop RCS depressurization. BV1-2150 DID 1-RC-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2152 RR 1-RC-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2835 RR 1-RC-1 Spurious SI De-energize MOV-1SI-867A at MCC1-E5 and de-energize MOV-1SI-867B at MCC1-E6 and close both valves. BV1-2873 DID 1-RC-1 PCV-1RC-455D PCV-1RC-456 MOV-1RC-536-P MOV-1RC-537-P Transfer control of reactor head vent valves SOV-RC102B, 103B and 105 to the BIP and open the valves as necessary for RCS depressurization.

BV1-2888 DID 1-TB-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-1934 RR 1-TB-1 1WT-TK-10 To align River Water to AFW pump suction: Close 1RW-306. Open 1RW-206, 1RW-207, 1RW-208, 1RW-209 and 1RW-210. Close 1WT-225, 1WT-226 and 1WT-227. Locally monitor running AFW pump suction pressure at PI1FW156, PI1FW156A, or PI1FW156B, and if any running AFW pump suction pressure drops below 8 PSIG, flush strainer 1RWYS47 by opening 1RW901, allowing the strainer to flush for several seconds, and closing 1RW901. BV1-2618 RR 3-CR-1 PCV-1MS-101A-P PCV-1MS-101B-P PCV-1MS-101C-P HCV-1MS-104-P Manually close PCV-1MS-101A to stop SG A steam flow.

Manually close PCV-1MS-101B to stop SG B steam flow. Manually close PCV-1MS-101C to stop SG C steam flow. Manually close HCV-1MS-104 to stop SG A B & C steam flow. BV1-2251 RR Attachment L-15-150 Page 136 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 4KVS-1A-1A5 4KVS-1B-1B5 4KVS-1C-1C5 PCV-1RC-455A PCV-1RC-455B De-energize 1RC-P-1A at 4KVS-1A, de-energize 1RC-P-1B at 4KVS-1B and de-energize 1RC-P-1C at 4KVS-1C to prevent an RCP seal LOCA. BV1-2255 RR 3-CR-1 1CH-E-1 MOV-1CH-381 De-energize MOV-1CH-381 at MCC1-E6 and manually close it OR Manually close 1CH-214 OR manually close 1CH-216 to isolate seal return. BV1-2257 RR 3-CR-1 MOV-1CH-115C-P MOV-1CH-115E-P MOV-1CH-115B 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1AE-1E11 4KVS-1AE-1E15 De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction.

De-energize MOV-1CH-115D at 480VUS-1-P and open it to align suction to the charging pumps. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2258 RR 3-CR-1 4KVS-1DF 4KVS-1DF-1F7 4KVS-1DF-1F9 1EEEG2 PNL-DG-SEQ-2 4KVS-1DF-1F12 Align AE and DF bus loads as required. BV1-2259 RR 3-CR-1 LT-1QS-100A LT-1QS-100B LT-1QS-100C LT-1QS-100D 1-MTR-SIGNAL De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to prevent pump damage on loss of suction.

De-energize 1SI-P-1A at 4KVS-1AE and De-energize 1SI-P-1B at 4KVS-1DF to stop flow from the containment sump. De-energize MOV-1CH-115D at 480VUS-1-P and open it to align suction to the charging pumps Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow. BV1-2261 DID 3-CR-1 480VUS-1-8N12 480VUS-1-9P12 480VUS-1-1B7 480VUS-1-8N13 480VUS-1-9P13 De-energize the A and D group heaters at 480VUS18-N, de-energize the control group heater at 480VUS11B and de-energize the B and E group heaters at 480VUS19-P to prevent RCS overpressure. BV1-2262 DID 3-CR-1 480VUS-1-8N4 480VUS-1-9P5 1-CIB-SPUR De-energize 1QS-P-1A at 480VUS-1-8N4 and de-energize 1QS-P-1B at 480VUS-1-9P5 to stop quench spray flow. BV1-2264 DID 3-CR-1 LCV-1CH-460A SW-ISO-CH460A Close LCV-1CH-460 at the keylock switch to isolate letdown. BV1-2268 RR Attachment L-15-150 Page 137 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 MOV-1RW-103A MOV-1RW-103B MOV-1RW-103C MOV-1RW-103D MOV-1RW-106A MOV-1RW-106B MOV-1RW-114A MOV-1RW-114B MOV-1RW-104A MOV-1RW-104B MOV-1RW-104C MOV-1RW-104D MOV-1RW-104 MOV-1RW-116A MOV-1RW-116B 1-CIB-SPUR De-energize MOV-1RW-103C at MCC1-E3, de-energize MOV-1RW-103D at MCC1-E4 and close both valves. BV1-2269 DID 3-CR-1 MOV-1RW-102B1 MOV-1RW-106B MOV-1RW-114B MOV-1RW-103B 1-CIB-SPUR Trip the #2 diesel to prevent damage. Deenergize MOV-1RW-106B at 480VUS-1-P, de-energize MOV-1RW-114B at 480VUS-1-N and open both valves. Align 4KVS-1DF for diesel start. Restart the #2 diesel. De-energize MOV-1RW-102B2 at MCC1-E1 and manually close it. De-energize MOV-1RW-102B1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1B at 4KVS-1DF and manually open MOV-1RW-102B1 to provide River Water flow, OR De-energize MOV-1RW-102C2 at MCC1-E1 and manually close it. De-energize MOV-1RW-102C1 at MCC1-E2 and manually throttle it 10% open THEN manually start 1WR-P-1C at 4KVS-1DF and manually open MOV-1RW-102C1 to provide River Water flow. Start other DF bus loads as required. BV1-2270 DID 3-CR-1 MOV-1SI-836-P MOV-1SI-869A-P MOV-1SI-869B-P MOV-1SI-867A MOV-1SI-867B MOV-1SI-867C MOV-1SI-867D Spurious SI De-energize 1CH-P-1A(C) at 4KVS-1AE and De-energize 1CH-P-1B(C) at 4KVS-1DF to stop excessive RCS makeup flow. De-energize MOV-1SI-836, 867A and 869A at 480VUS-1-N, de-energize MOV-1SI-867B and 869B at 480VUS-1-P and manually close the valves to isolate the SI flow paths. Manually start 1CH-P-1B or 1CH-P-1C at 4KVS-1DF to provide RCS makeup flow.

BV1-2271 BV1-2272 DID 3-CR-1 MOV-1SI-869B De-energize MOV-1SI-869B at 480VUS-1-1P and manually throttle to provide an alternate makeup flow path. BV1-2274 DID Attachment L-15-150 Page 138 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 TV-1BD-100A TV-1BD-100B TV-1BD-100C TV-1BD-101A1 TV-1BD-101A2 TV-1BD-101B1 TV-1BD-101B2 TV-1BD-101C1 TV-1BD-101C2 TV-1BD-107A TV-1BD-107B TV-1BD-107C De-energize TV-1BD-100A, B & C at PNL-DC-3, de-energize TV-1BD-101A1, B1 & C1 at PNL-VITBUS-1 and de-energize TV-1BD-101A2, B2 & C2 at PNL-VITBUS-2 to stop blowdown flow. BV1-2276 DID 3-CR-1 TV-1MS-101A TV-1MS-101B TV-1MS-101C Close 1IA-85-6 and open 1IA-85-53 and IA-85-54 to close the Main Steam Trip Valves. BV1-2277 DID 3-CR-1 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151C MOV-1FW-151E Manually start 1FW-P-3B at 4KVS-1DF. De-energize MOV-1FW-151A, C & E at 480VUS-1-P. Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2279 DID 3-CR-1 MOV-1CH-289 De-energize MOV-1CH-289 at MCC1-E5 and manually close it, OR Close manual valve 1CH-30 to stop excessive RCS makeup. BV1-2282 RR 3-CR-1 4KVS-1A-1A1 4KVS-1B-1B1 4KVS-1C-1C1 4KVS-1D-1D1 HYV-1FW-100A HYV-1FW-100B HYV-1FW-100C De-energize 1FW-P-1A at 4KVS-1A & 1B and de-energize 1FW-P-1B at 4KVS-1C & 1D to stop main feedwater flow to the steam generators. BV1-2331 DID 3-CR-1 4KVS-1DF-1F2 4KVS-1DF-1F10 4KVS-1DF-1F14 Trip the #2 diesel to prevent damage. Align 4KVS-1DF for diesel start. Restart the #2 diesel. Manually start 1WR-P-1B or 1C at 4KVS-1DF. Start other DF bus loads as required. BV1-2332 DID Attachment L-15-150 Page 139 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 PCV-1RC-455C-P PCV-1RC-455D-P PCV-1RC-456-P PT-1RC-444 PT-1RC-445 Close PCV-1RC-455C, PCV-1RC-455D and PCV-1RC-456 at the keylock switches to stop RCS depressurization. BV1-2334 RR 3-CR-1 4KVS-1AE-1E16 MOV-1MS-105 4KVS-1DF-1F16 MOV-1FW-151A MOV-1FW-151B MOV-1FW-151C MOV-1FW-151D MOV-1FW-151E MOV-1FW-151F De-energize 1FW-P-3A at 4KVS-1AE and manually trip 1FW-P-2 to stop train A AFW flow. De-energize MOV-1FW-151A, C & E at 480VUS-1-P. Manually throttle MOV-1FW-151E to control SG A AFW flow. Manually throttle MOV-1FW-151C to control SG B AFW flow. Manually throttle MOV-1FW-151A to control SG C AFW flow. BV1-2416 RR 3-CR-1 1VS-F-16B 1VS-F-55B Install portable ventilation for Emergency Switchgear. BV1-2426 RR 3-CR-1 1VS-AC-1B 1VS-C-1B 1VS-E-4B 1VS-F-40B 1VS-P-3B Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV1-2480 RR 3-CR-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2574 RR 3-CR-1 SOV-1RC-102B SOV-1RC-103B

SOV-1RC-105 LI-1FW-475BP LI-1RC-460BP NI-1NI-32A PI-1RC-403B PTI-1RC-410B PTI-1RC-29BP BIP Power Use supplementary controls and monitoring from the BIP. BV1-2695 DID Attachment L-15-150 Page 140 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 Spurious SI 4KVS-1AE-1E11-P 4KVS-1AE-1E15-P 4KVS-1DF-1F11-P 4KVS-1DF-1F15-P De-energize 1CH-P-1A(C) at 4KVS-1AE OR De-energize 1CH-P-1B(C) at 4KVS-1DF to control charging/HHSI flow. BV1-2707 DID 3-CR-1 4KVS-1B-1B2 4KVS-1D-1D2 De-energize 1CN-P-1A at 4KVS-1B and de-energize 1CN-P-1A at 4KVS-1B to stop condensate flow to the steam generators. BV1-2759 DID 3-CR-1 PCV-1MS-101A PCV-1MS-101B

PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2865 RR 3-CR-1 PCV-1RC-455C MOV-1RC-535-P Transfer control of reactor head vent valves SOV-RC102B, 103B and 105 to the BIP and open the valves as necessary for RCS depressurization. To align Containment Sump recirculation to maintain long-term cooling, perform the following. De-energize MOV-1SI-860B and 863B at 480VUS-1-P and open them, de-energize MOV-1SI-885B and 885D at 480VUS-1-P and close them, de-energize MOV-1CH-115D at 480VUS-1-P and close it and de-energize MOV-1SI-862B at 480VUS-1-P and close it. BV1-2889 DID 3-CR-1 MOV-1CH-115C De-energize MOV-1CH-115C at 480VUS-1-N and close it or De-energize MOV-1CH-115E at 480VUS-1-P and close it to prevent hydrogen intrusion into the suction of the charging pumps. BV1-2917 DID 3-YARD-1 4KVS-1AE 4KVS-1DF 1EE-EG-1 1EE-EG-2 1VS-D-22-1A 1VS-D-22-1B 1VS-D-22-2C 1VS-D-22-2D 1VS-F-22A 1VS-F-22B Identify the emergency bus that is energized or that is to be recovered. Local manual operator action to remove all control power from the selected emergency bus, strip the emergency bus, verify that the Emergency Diesel Generator has automatically started, or manually start it, if required. Local manual operator action will be required to manually sequence on all necessary emergency bus loads, if required.

BV1-2493 RR 3-YARD-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction. BV1-2657 RR Attachment L-15-150 Page 141 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-YARD-1 PCV-1MS-101A PCV-1MS-101B PCV-1MS-101C HCV-1MS-104 Manually throttle HCV-1MS-104 to control SG A, B, & C steam flow

OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2901 RR Generic 1-CTP-1 1-DG-1 1-PA-1A 1-PA-1C 1-SB-GEN 1-TO-1 1-TR-1 1-TR-2 1-TR-3 1-TR-4 1-TR-5 1-WH-1 3-AIS-1 3-ER-1 3-ER-2 3-IS-1 3-IS-2 3-IS-6 3-RH-1 3-SY-1 Manually throttle HCV-1MS-104 to control SG A, B, & C steam flow OR Manually throttle PCV-1MS-101A to control SG A steam flow, manually throttle PCV-1MS-101B to control SG B steam flow and manually throttle PCV-1MS-101C to control SG C steam flow. BV1-2771 RR and DID Attachment L-15-150 Page 142 Table 3 - BVPS-1 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) Generic 1-CTP-1 1-DG-1 1-PA-1A 1-PA-1C 1-SB-GEN 1-TO-1 1-TR-1 1-TR-2 1-TR-3 1-TR-4 1-TR-5 1-WH-1 3-AIS-1 3-ER-1 3-ER-2 3-IS-1 3-IS-2 3-IS-6 3-RH-1 3-SY-1 1WT-TK-10 Manually open 1FW-643, manually close 1FW-639, manually open 1FW-660 and manually close 1FW-663 to align 1WT-TK-26 to the AFW pump suction BV1-2772 RR

Attachment L-15-150 Page 143 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-ASP 2CHS-AOV200A 2CHS-AOV200C 2CHS-LCV460B De-energize 2CHS-AOV200A at PNL-DC2-11 and de-energize 2CHS-AOV200C at PNL-DC2-15 to isolate letdown flow.

OR Isolate instrument air to containment to fail 2CHS-AOV200A, B and C closed to prevent loss of RCS inventory. BV2-0765 RR 2-ASP 2SVS-PCV101A 2SVS-PCV101B De-energize 2SVS-PCV101A at MCC2-E05 to stop SG A steam flow. De-energize 2SVS-PCV101B at MCC2-E13 to stop SG B steam flow. BV2-1396 RR 2-ASP 4KVS-2AE-2E18 2FWE-HCV100A 2FWE-HCV100C 2FWE-HCV100E De-energize 2FWE-P23A at 4KVS-2AE to stop train A AFW flow. BV2-1364 RR 2-ASP 480VUS-2-8-7B 480VUS-2-8-7C De-energize the A and D backup group heaters at 480VUS28 to prevent RCS overpressure. BV2-0768 DID 2-ASP 2FWE-TK210 Provide an alternate suction to the AFW pumps. BV2-0779 RR 2-ASP 4KVS-2AE-2E12 De-energize the A Char ging/HHSI Pump at 4KVS-2AE to stop excess charging/HHSI pump flow. BV2-0769 DID 2-ASP 2RCS-PCV456 Close 2RCS-PCV456 at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV536 to isolate the

PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21B de-energize 2SIS-MOV8809B, 2SIS-MOV8887B, 2SIS-MOV8811B, 2RSS-MOV156D, 2SIS-MOV863B, 2RSS-MOV155D and 2SIS-MOV8890B at MCC2-E12 and then manually close 2SIS-MOV8809B, 2SIS-MOV8887B, 2RSS-MOV156D and 2SIS-MOV8890B, manually open 2SIS-MOV8811B, 2SIS-MOV863B and 2RSS-MOV155D. BV2-0766 RR and DID 2-CB-1 2CHS-E21 2CHS-MOV378 Close 2CHS-214 to isolate seal water return heat exchanger flow. BV2-0801 RR Attachment L-15-150 Page 144 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 2BDG-AOV100A1 2BDG-AOV100B1 2BDG-AOV100C1 2BDG-AOV101A1 2BDG-AOV101A2 2BDG-AOV101B1 2BDG-AOV101B2 2BDG-AOV101C1 2BDG-AOV101C2 De-energize 2BDG-AOV101A2, B2 and C2 at PNL-DC2-10 to isolate SG A, B and C blowdown flow. BV2-0797 DID 2-CB-1 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C De-energize 2SDS-AOV112A, B and C at PNL-AC2-03 to stop steam flow from SG A, B and C. BV2-0815 DID 2-CB-1 2SVS-HCV104 2SVS-PCV101A

2SVS-PCV101B 2SVS-PCV101C Throttle 2SVS-PCV101A from the ASP to control SG C pressure and throttle 2SVS-PCV101B from the ASP to control SG B pressure.

BV2-1397 PCS 2-CB-1 2SVS-HCV104 2SVS-PCV101A

2SVS-PCV101B 2SVS-PCV101C De-energize 2SVS-HCV104 at MCC2-E14 to stop SG A, B and C steam flow.

De-energize 2SVS-PCV101A at MCC2-E05 to stop SG A steam flow. De-energize 2SVS-PCV101B at MCC2-E13 to stop SG B steam flow. De-energize 2SVS-PCV101C at 480VUS28 to stop SG C steam flow. THEN Manually throttle 2SVS-HCV104 to control SG A, B and C pressure. Manually throttle 2SVS-PCV101A to control SG A pressure. Manually throttle 2SVS-PCV101B to control SG B pressure. Manually throttle 2SVS-PCV101C to control SG C pressure. BV2-1397 DID Attachment L-15-150 Page 145 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 2SWS-MOV102A 2SWS-MOV106A 2-CIB-SPURIf 2SWS-P21A and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close it. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV170A at MCC2-E01 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C1 at MCC2-E01, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C1 to provide A SWS flow. Start other AE bus loads as required.

OR If 2SWS-P21C and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close it. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV102A at MCC2-E01, restart the diesel, manually start 2SWS-P21A while manually opening 2SWS-MOV102A to provide A SWS flow. Start other AE bus loads as required. BV2-0818 RR 2-CB-1 2SWS-MOV102A 2SWS-MOV106A 2-CIB-SPURIf 2SWS-P21A and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close it. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV170A at MCC2-E01 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C1 at MCC2-E01, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C1 to provide A SWS flow. Start other AE bus loads as required.

OR If 2SWS-P21C and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close it. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV102A at MCC2-E01, restart the diesel, manually start 2SWS-P21A while manually opening 2SWS-MOV102A to provide A SWS flow. Start other AE bus loads as required. BV2-0851 RR 2-CB-1 2MSS-AOV101A 2MSS-AOV101B

2MSS-AOV101C De-energize 2MSS-AOV101A, B and C at PNL-DC2-10 to stop steam flow from SG A, B and C. BV2-0809 RR Attachment L-15-150 Page 146 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100C 2FWE-HCV100D 2FWE-HCV100E 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. Manually throttle 2FWE-HCV100E to control A train SG A flow. Manually throttle 2FWE-HCV100C to control A train SG B flow. Manually throttle 2FWE-HCV100A to control A train SG C flow

. BV2-0808 RR 2-CB-1 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F Throttle 2FWE-HCV100E at the ASP to control SG A level. Throttle 2FWE-HCV100C at the ASP to control SG B level.

BV2-0808 PCS 2-CB-1 4KVS-1G-1G5 4KVS-2A-2A1 4KVS-2B-2B1 4KVS-2C-2C1 4KVS-2D-2D1 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2FWS-P21A at 4KVS-2A & 4KVS-2B and de-energize 2FWS-P21B at 4KVS-2C & 4KVS-2D to stop main feedwater pump flow to the steam generators. BV2-0821 DID 2-CB-1 480VUS-2-2-2C 480VUS-2-8-7B 480VUS-2-8-7C 480VUS-2-9-7B 480VUS-2-9-7C De-energize the C control group heater at 480VUS22, de-energize the A and D backup group heaters at 480VUS28 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure

.BV2-0820 DID 2-CB-1 480VUS-2-2-2C 480VUS-2-8-7B 480VUS-2-8-7C 480VUS-2-9-7B 480VUS-2-9-7C Operate the A backup group heater at the ASP to control RCS pressure. BV2-0820 PCS 2-CB-1 2HVC-ACU201A 2HVC-MOD205A

2HVC-MOD206A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV2-1329 RR 2-CB-1 2CHS-LCV115C De-energize 2CHS-LCV115C at MCC2-E03 and manually close the valve OR De-energize 2CHS-LCV115E at MCC2-E04 and manually close the valve to prevent hydrogen intrusion into the charging pump suction. BV2-0806 DID Attachment L-15-150 Page 147 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 2CHS-MOV289 Manually open 2CHS-477 to bypass the charging flow control valve. Manually close 2CHS-30 to isolate the charging flow control valve. Manually throttle 2CHS-477 to control charging flow. BV2-0807 RR 2-CB-1 2RCS-PCV455C 2RCS-PCV455D 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 De-energize the C control group heater at 480VUS22, de-energize the A and D backup group heaters at 480VUS28 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-1413 DID 2-CB-1 2RCS-PCV455C 2RCS-PCV455D 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 Attempt to control 2RCS-PCV456 at the ASP. BV2-1413 PCS 2-CB-1 2RCS-SOV200A 2RCS-SOV200B 2RCS-SOV201A 2RCS-SOV201B 2RCS-HCV250A 2RCS-HCV250B Perform repair procedure to provide power to the reactor vessel head vent valves. BV2-1418 DID 2-CB-1 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-0812 RR 2-CB-1 Spurious SI 4KVS-2AE-2E12 4KVS-2AE-2E15 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow. BV2-0825 DID 2-CB-1 4KVS-2B-2B2 4KVS-2C-2C2 4KVS-2D-2D2 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2CNM-P21A at 4KVS-2B, de-energize 2CNM-P21B at 4KVS-2C and de-energize 2CNM-P21C at 4KVS-2D to stop condensate flow to the steam generators. BV2-1349 DID Attachment L-15-150 Page 148 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 4KVS-2AE-2E2 4KVS-2DF-2F2 2-CIB-SPUR Trip 2QSS-P21A at 4KVS-2AE to stop A train quench spray flow and trip 2QSS-P21B at 4KVS-2DF to stop B train quench spray flow. BV2-0824 RR 2-CB-1 4KVS-2AE Align AE and DF bus loads as required. BV2-0823 RR 2-CB-1 2CHS-LCV115C 2CHS-LCV115E 2CHS-LCV115B 4KVS-2AE-2E12 4KVS-2AE-2E15 2QSS-LT104A 2QSS-LT104B 2QSS-LT104C 2QSS-LT104D 2-CVCS-RAS De-energize 2CHS-P21A and 2CHS-P21C at 4KVS-2AE and de-energize 2CHS-P21B and 2CHS-P21C at 4KVS-2DF to prevent pump damage on loss of suction. De-energize 2CHS-LCV115B at MCC2-E03 and manually open it or open 2CHS-LCV115B from the ASP to align suction to the charging pumps. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-0796 BV2-0805 DID 2-CB-1 2QSS-LT104A 2QSS-LT104B 2QSS-LT104C 2QSS-LT104D 2-CVCS-RAS 2CHS-LCV115C 2CHS-LCV115E 2CHS-LCV115B 4KVS-2AE-2E12 4KVS-2AE-2E15 Spurious SI 2SIS-MOV836 2SIS-MOV840 2SIS-MOV867A 2SIS-MOV867B 2SIS-MOV867C 2SIS-MOV867D 2SIS-HCV868A 2SIS-HCV868B 2SIS-MOV869A 2SIS-MOV869B Open 2CHS-LCV115B from the ASP to provide suction to Charging/HHSI pump 2CHS-P21A and start 2CHS-P21 A from the ASP to provide RCS makeup. BV2-0796 BV2-0805 BV2-0816 BV2-1390 PCS Attachment L-15-150 Page 149 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 Spurious SI 2SIS-MOV836 2SIS-MOV840 2SIS-MOV867A 2SIS-MOV867B 2SIS-MOV867C 2SIS-MOV867D 2SIS-HCV868A 2SIS-HCV868B 2SIS-MOV869A 2SIS-MOV869B De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV836, 2SIS-MOV840, 2SIS-MOV867C and 2SIS-MOV869A at MCC2-E05 and manually close the valves and de-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-0816 BV2-1390 DID 2-CB-1 2RCS-PT444 2RCS-PT445 2RCS-PCV455C 2RCS-PCV455D Close 2RCS-PCV455C and 2RCS-PCV455D at the keylock isolation switches.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 and 2RCS-MOV537 to isolate the PORVs.

OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-0813 RR and

DID 2-CB-1 2FWE-TK210 Provide an alternate suction to the A AFW pump. BV2-0798 RR 2-CB-1 2SWS-STRM47 2SWS-PT117A 2SWS-AOV130A De-energize 2SWS-AOV130A at 480VUS-2-8 to restore the service water pump seal water supply. BV2-0850 DID Attachment L-15-150 Page 150 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-1 4KVS-2AE-2E14 4KVS-2AE-2E18 2FWE-HCV100C 2FWE-HCV100E 480VUS-2-8-7B 2SVS-PCV101A 2SVS-PCV101B 4KVS-2AE-2E12 2CHS-FCV122 2RCS-PCV456 2CHS-LCV460A 2CHS-LCV460B 2CHS-P22A 2CHS-SOV206 2EGS-EG2-1 2FWS-LI477F 2FWS-LI487F 2MSS-PI475F 2MSS-PI485F 2RCS-LI459AF 2RCS-PI403F 2RCS-PI455F 2RCS-TI413F 2RCS-TI423F 2RCS-TI410F 2RCS-TI420F 2FWE-FI100AF 2FWE-FI100BF

2NMS-NI31BF 2NMS-NI31DF ACB-42A ACB-2A10 ACB-2E7 ACB-2E10 2SWS-MOV113A 2SWS-MOV102A 2CHS-LCV115B ASP Power Supply Take the plant to "Safe and Stable" utilizing selected instruments and controls at the auxiliary shutdown panel, as directed. BV2-0855 DID Attachment L-15-150 Page 151 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-5 2HVC-ACU201A 2HVC-MOD205A 2HVC-MOD206A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV2-1194 RR 2-CB-6 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C De-energize 2SDS-AOV112A, B and C at PNL-AC2-03 to stop steam flow from SG A, B and C. BV2-1031 DID 2-CB-6 2SVS-HCV104 2SVS-PCV101A

2SVS-PCV101B 2SVS-PCV101C De-energize 2SVS-HCV104 at MCC2-E14 to stop SG A, B and C steam flow and manually throttle it to control SG A, B and C pressure. De-energize 2SVS-PCV101A at MCC2-E05 to stop SG A steam flow and manually throttle it to control SG A pressure. De-energize 2SVS-PCV101B at MCC2-E13 to stop SG B steam flow and manually throttle it to control SG B pressure. De-energize 2SVS-PCV101C at MCC2-E13 to stop SG C steam flow and manually throttle it to control SG C pressure. BV2-1398 RR 2-CB-6 2SVS-HCV104 2SVS-PCV101A

2SVS-PCV101B 2SVS-PCV101C Throttle 2SVS-PCV101A from the ASP to control SG C pressure and throttle 2SVS-PCV101B from the ASP to control SG B pressure.

BV2-1398 PCS 2-CB-6 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100C 2FWE-HCV100D 2FWE-HCV100E 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. Manually throttle 2FWE-HCV100E to control A train SG A flow. Manually throttle 2FWE-HCV100C to control A train SG B flow. Manually throttle 2FWE-HCV100A to control A train SG C flow. BV2-1028 RR 2-CB-6 4KVS-2DF-2F18 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F Throttle 2FWE-HCV100E at the ASP to control SG A level. Throttle 2FWE-HCV100C at the ASP to control SG B level.

BV2-1028 PCS 2-CB-6 480VUS222C 480VUS287B 480VUS297B 480VUS297C De-energize the C control group heater at 480VUS22, de-energize the A backup group heater at 480VUS28 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-1034 DID 2-CB-6 2HVC-ACU201A 2HVC-MOD205A 2HVC-MOD206A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV2-1334 RR 2-CB-6 2FWE-TK210 Provide an alternate suction to the AFW pumps. BV2-1356 RR Attachment L-15-150 Page 152 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-6 2CHS-LCV115C De-energize 2CHS-LCV115C at MCC2-E03 and manually close the valve OR De-energize 2CHS-LCV115E at MCC2-E04 and manually close the valve to prevent hydrogen intrusion into the charging pump suction. BV2-1026 RR 2-CB-6 4KVS-2A-2A6 4KVS-2B-2B6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A and de-energize 2RCS-P21B at 4KVS-2B to prevent an RCP seal LOCA. BV2-1029 RR 2-CB-6 4KVS-2AE-2E12 4KVS-2AE-2E15 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow. BV2-1037 DID 2-CB-6 2SISMOV867B 2SISMOV867D 2SIS-HCV868B 2SISMOV869B De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE and manually throttle 2SIS-MOV867D to control RCS makeup flow. BV2-1032 BV2-1391 DID 2-CB-6 2CHS-LCV115C 2CHS-LCV115E 2CHS-LCV115B 4KVS-2AE-2E12 4KVS-2AE-2E15 De-energize 2CHS-P21A and 2CHS-P21C at 4KVS-2AE and de-energize 2CHS-P21B and 2CHS-P21C at 4KVS-2DF to prevent pump damage on loss of suction. De-energize 2CHS-LCV115B at MCC2-E03 and manually open it or open 2CHS-LCV115B from the ASP to align suction to the charging pumps. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-1024 RR 2-CB-6 2RCS-PT444 2RCS-PT445 2RCS-PCV455C 2RCS-PCV455D Close 2RCS-PCV455C at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 to isolate the PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-1030 RR and DID 2-CB-6 4KVS-2DF-2F2 Trip 2QSS-P21B at 4KVS-2DF to stop quench spray flow. BV2-1038 RR Attachment L-15-150 Page 153 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-6 4KVS-2AE Align AE and DF bus loads as required. BV2-1353 RR Attachment L-15-150 Page 154 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CB-6 4KVS-2AE-2E14 4KVS-2AE-2E18 2FWE-HCV100C 2FWE-HCV100E 480VUS-2-8-7B 2SVS-PCV101A 2SVS-PCV101B 4KVS-2AE-2E12 2CHS-FCV122 2RCS-PCV456 2CHS-LCV460A 2CHS-LCV460B 2CHS-P22A 2CHS-SOV206 2EGS-EG2-1 2FWS-LI477F 2FWS-LI487F 2MSS-PI475F 2MSS-PI485F 2RCS-LI459AF 2RCS-PI403F 2RCS-PI455F 2RCS-TI413F 2RCS-TI423F 2RCS-TI410F 2RCS-TI420F 2FWE-FI100AF 2FWE-FI100BF

2NMS-NI31BF 2NMS-NI31DF ACB-42A ACB-2A10 ACB-2E7 ACB-2E10 2SWS-MOV113A 2SWS-MOV102A 2CHS-LCV115B ASP Power Supply Take the plant to "Safe and Stable" utilizing selected instruments and controls at the auxiliary shutdown panel, as directed. BV2-1354 DID Attachment L-15-150 Page 155 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-1 2CHS-E21 2CHS-MOV381 Close 2CHS-214 to isolate seal water return heat exchanger flow. BV2-0953 RR 2-CV-1 2BDG-AOV100A1 2BDG-AOV100B1 2BDG-AOV100C1 2BDG-AOV101A1 2BDG-AOV101A2 2BDG-AOV101B1 2BDG-AOV101B2 2BDG-AOV101C1 2BDG-AOV101C2 De-energize 2BDG-AOV101A2, B2 and C2 at PNL-DC2-10 to isolate SG A, B and C blowdown flow. BV2-0952 DID 2-CV-1 2CHS-AOV200A 2CHS-AOV200B 2CHS-AOV200C 2CHS-LCV460B De-energize 2CHS-AOV200A at PNL-DC2-11 and de-energize 2CHS-AOV200C at PNL-DC2-15 to isolate letdown flow.

OR Isolate instrument air to containment to fail 2CHS-AOV200A, B and C closed to prevent loss of RCS inventory. BV2-0959 RR 2-CV-1 2SWS-MOV102C1 2SWS-MOV102C2 2SWSMOV103B 2-CIB-SPUR If 2SWS-P21B and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close it. De-energize 2SWE-MOV116B at MCC2-E04 and close if spuriously opened. De-energize 2SWS-MOV106B at MCC2-E04 and verify that it is open to align the B SWS flow path. De-energize 2SWS-MOV170B at MCC2-E02 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C2 at MCC2-E02, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C2 to provide B SWS flow. Start other DF bus loads as required.

OR If 2SWS-P21C and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close it. De-energize 2SWE-MOV116B at MCC2-E04 and close if spuriously opened. De-energize 2SWS-MOV106B at MCC2-E04 and verify that it is open to align the B SWS flow path. Restart the diesel and start other DF bus loads as required. BV2-0976 RR and DID Attachment L-15-150 Page 156 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-1 2SWS-MOV106B 2-CIB-SPUR If 2SWS-P21B and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close if to spuriously opened. De-energize 2SWE-MOV116B at MCC2-E04 and close it and de-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. De-energize 2SWS-MOV170B at MCC2-E02 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C2 at MCC2-E02, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C2 to provide B SWS flow. Start other DF bus loads as required.

OR IF 2SWS-P21C and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close if spuriously opened. De-energize 2SWE-MOV116B at MCC2-E04 and close it and de-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. Restart the diesel and start other DF bus loads as required. BV2-0977 RR 2-CV-1 2MSS-AOV101A 2MSS-AOV101B 2MSS-AOV101C De-energize 2MSS-AOV101A, B and C at PNL-DC2-10 to stop steam flow from SG A, B and C. BV2-0964 RR 2-CV-1 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C De-energize 2SDS-AOV112A, B and C at PNL-AC2-03 to stop steam flow from SG A, B and C. BV2-0972 DID 2-CV-1 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C De-energize 2SVS-HCV104 at MCC2-E14 to stop SG A, B and C steam flow.

Manually close 2SVS-PCV101A to stop SG A steam flow. Manually close 2SVS-PCV101B to stop SG B steam flow. Manually close 2SVS-PCV101C to stop SG C steam flow. THEN Manually throttle 2SVS-HCV104 to control SG A, B and C pressure. Manually throttle 2SVS-PCV101A to control SG A pressure. Manually throttle 2SVS-PCV101B to control SG B pressure. Manually throttle 2SVS-PCV101C to control SG C pressure.

BV2-0974 BV2-1399 DID RR Attachment L-15-150 Page 157 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-1 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100C 2FWE-HCV100D 2FWE-HCV100E 2FWE-HCV100F Manually throttle 2FWE-HCV100E and 2FWE-HCV100F to control SG A AFW flow. Manually throttle 2FWE-HCV100C and 2FWE-HCV100D to control SG B AFW flow. Manually throttle 2FWE-HCV100A and 2FWE-HCV100B to control SG C AFW flow. BV2-0961 BV2-0962 DID RR 2-CV-1 4KVS-1G-1G5 4KVS-2A-2A1 4KVS-2B-2B1 4KVS-2C-2C1 4KVS-2D-2D1 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2FWS-P21A at 4KVS-2A & 4KVS-2B and de-energize 2FWS-P21B at 4KVS-2C & 4KVS-2D to stop main feedwater pump flow to the steam generators. BV2-0979 RR 2-CV-1 480VUS222C 480VUS287B 480VUS287C 480VUS297B 480VUS297C De-energize the C control group heater at 480VUS22, de-energize the A and D backup group heaters at 480VUS28 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-0978 DID 2-CV-1 2HVC-ACU201B 2HVC-MOD205B

2HVC-MOD206B Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV2-0963 RR 2-CV-1 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-0947 RR 2-CV-1 2CHS-LCV115E De-energize 2CHS-LCV115C at MCC2-E03 and manually close the valve OR De-energize 2CHS-LCV115E at MCC2-E04 and manually close the valve to prevent hydrogen intrusion into the charging pump suction. BV2-0957 DID 2-CV-1 2CHS-MOV289 Manually open 2CHS-477 to bypass the charging flow control valve. Manually close 2CHS-30 to isolate the charging flow control valve. Manually throttle 2CHS-477 to control charging flow. BV2-0960 RR 2-CV-1 2RCS-PCV455D 2RCS-PCV456 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 Perform repair procedure to allow the opening of 2RCS-MOV536. BV2-1414 DID Attachment L-15-150 Page 158 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-1 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-0971 RR and DID 2-CV-1 Spurious SI 4KVS-2AE-2E12 4KVS-2AE-2E15 De-energize 2CHS-P21A(C) at 4KVS-2AE to control charging/HHSI flow. BV2-0980 DID 2-CV-1 4KVS-2B-2B2 4KVS-2C-2C2 4KVS-2D-2D2 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2CNM-P21A at 4KVS-2B, de-energize 2CNM-P21B at 4KVS-2C and de-energize 2CNM-P21C at 4KVS-2D to stop condensate flow to the steam generators. BV2-1367 RR 2-CV-1 Spurious SI 2SIS-MOV836 2SIS-MOV840 2SIS-MOV867A 2SIS-MOV867B 2SIS-MOV867C 2SIS-MOV867D 2SIS-HCV868A 2SIS-MOV869A 2SIS-MOV869B De-energize 2CHS-P21A(C) at 4KVS-2AE and de-energize 2CHS-P21C at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV836, 2SIS-MOV840, 2SIS-MOV867C and 2SIS-MOV869A at MCC2-E05 and manually close the valves and de-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Start 2CHS-P21B or 2CHS-P21C at 4KVS-2DF to provide RCS makeup flow. BV2-0973 BV2-1392 DID 2-CV-1 2CHS-LCV115C 2CHS-LCV115E 2QSS-LT104A 2QSS-LT104C 2-CVCS-RAS De-energize 2CHS-P21A and 2CHS-P21C at 4KVS-2AE and de-energize 2CHS-P21C at 4KVS-2DF to prevent pump damage on loss of suction. De-energize 2CHS-LCV115D at MCC2-E04 and manually open it to align suction to the charging pumps. Manually start 2CHS-P21B or 2CHS-P21C at 4KVS-2DF to provide RCS makeup flow. BV2-0951 BV2-0958 DID Attachment L-15-150 Page 159 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-1 2RCS-PT445 2RCSPCV455D 2RCSPCV456 Close 2RCS-PCV455D, 2RCS-PCV455D and 2RCS-PCV456 at the keylock isolation switches.

OR Perform repair procedure to allow the closing of 2RCS-MOV537, 2RCS-MOV535 and 2RCS-MOV536 to isolate the PORVs.

OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21B de-energize 2SIS-MOV8809B, 2SIS-MOV8887B, 2SIS-MOV8811B, 2RSS-MOV156D, 2SIS-MOV863B, 2RSS-MOV155D and 2SIS-MOV8890B at MCC2-E12, de-energize 2CHS-LCV115D at MCC2-E04 and then manually close 2SIS-MOV8809B, 2SIS-MOV8887B, 2RSS-MOV156D and 2SIS-MOV8890B, manually open 2SIS-MOV8811B, 2SIS-MOV863B and 2RSS-MOV155D and then manually close 2CHS-LCV115D. BV2-0981 RR and

DID 2-CV-1 2SWS-STRM48 Manually backwash the service water seal water strainer in accordance with procedure instructions. BV2-0982 DID 2-CV-1 4KVS-2AE-2E2 4KVS-2DF-2F2 2-CIB-SPUR Trip 2QSS-P21A at 4KVS-2AE to stop A train quench spray flow and trip 2QSS-P21B at 4KVS-2DF to stop B train quench spray flow. BV2-0950 RR 2-CV-2 2QSS-LT104B 2QSS-LT104D 2-CVCS-RAS 2CHS-LCV115E Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-1000 BV2-1001 DID 2-CV-2 2SVS-HCV104 Manually close 2SVS-HCV104 to stop SG A, B and C steam flow. BV2-1006 DID 2-CV-2 4KVS-2DF-2F18 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. BV2-1351 RR 2-CV-2 480VUS-2-9-7B 480VUS-2-9-7C De-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-1009 DID 2-CV-2 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1014 RR 2-CV-2 4KVS-2B-2B6 4KVS-2C-2C6 De-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-1012 RR 2-CV-2 Spurious SI 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow. BV2-1013 DID Attachment L-15-150 Page 160 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-2 Spurious SI 2SISMOV867B 2SISMOV867D 2SIS-HCV868B 2SISMOV869B De-energize 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Manually throttle 2SIS-MOV867D to control RCS makeup flow. BV2-1005 BV2-1393 DID 2-CV-2 2RCS-PCV455C Close 2RCS-PCV455C at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 to isolate the PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B.

BV2-1003 RR and DID 2-CV-2 4KVS-2AE-2E2 4KVS-2DF-2F2 2-CIB-SPUR Trip 2QSS-P21A at 4KVS-2AE to stop A train quench spray flow and trip 2QSS-P21B at 4KVS-2DF to stop B train quench spray flow. BV2-1011 DID 2-CV-3 2QSS-LT104B 2QSS-LT104D 2-CVCS-RAS 2CHS-LCV115E Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-0923 BV2-1316 DID 2-CV-3 2MSS-AOV101A 2MSS-AOV101B 2MSS-AOV101C De-energize 2MSS-AOV101A, B and C at PNL-DC2-10 to stop steam flow from SG A, B and C. BV2-0926 RR 2-CV-3 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C De-energize 2SDS-AOV112A, B and C at PNL-AC2-03 to stop steam flow from SG A, B and C. BV2-0933 DID Attachment L-15-150 Page 161 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-3 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C Manually close 2SVS-HCV104 to stop SG A, B and C steam flow. Manually close 2SVS-PCV101A to stop SG A steam flow. Manually close 2SVS-PCV101B to stop SG B steam flow. Manually close 2SVS-PCV101C to stop SG C steam flow. THEN Manually throttle 2SVS-HCV104 to control SG A, B and C pressure. Manually throttle 2SVS-PCV101A to control SG A pressure. Manually throttle 2SVS-PCV101B to control SG B pressure. Manually throttle 2SVS-PCV101C to control SG C pressure. BV2-0936 BV2-1427 DID 2-CV-3 4KVS-2DF-2F18 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. BV2-1423 RR 2-CV-3 4KVS-1G-1G5 4KVS-2A-2A1 4KVS-2B-2B1 4KVS-2C-2C1 4KVS-2D-2D1 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2FWS-P21A at 4KVS-2A & 4KVS-2B and de-energize 2FWS-P21B at 4KVS-2C & 4KVS-2D to stop main feedwater pump flow to the steam generators. BV2-0941 DID 2-CV-3 480VUS-2-2-2C 480VUS-2-9-7B 480VUS-2-9-7C De-energize the C control group heater at 480VUS22 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-0940 DID 2-CV-3 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-0993 RR 2-CV-3 2RCS-SOV200B 2RCS-SOV201B 2RCS-HCV250A 2RCS-HCV250B Perform repair procedure to provide power to the reactor vessel head vent valves. BV2-1420 DID 2-CV-3 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-0930 RR Attachment L-15-150 Page 162 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-CV-3 Spurious SI 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow. BV2-0943 DID 2-CV-3 4KVS-2B-2B2 4KVS-2C-2C2 4KVS-2D-2D2 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2CNM-P21A at 4KVS-2B, de-energize 2CNM-P21B at 4KVS-2C and de-energize 2CNM-P21C at 4KVS-2D to stop condensate flow to the steam generators. BV2-1348 DID 2-CV-3 Spurious SI 2SIS-MOV867B 2SISMOV867D 2SIS-HCV868A 2SIS-HCV868B 2SISMOV869B De-energize 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Manually throttle 2SIS-MOV867D to control RCS makeup flow. BV2-0934 BV2-1394 DID 2-CV-3 2RCS-PT444 2RCS-PCV455C Close 2RCS-PCV455C at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 to isolate the PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-0931 RR and DID 2-CV-3 4KVS-2AE-2E2 4KVS-2DF-2F2 2-CIB-SPUR Trip 2QSS-P21A at 4KVS-2AE to stop A train quench spray flow and trip 2QSS-P21B at 4KVS-2DF to stop B train quench spray flow. BV2-0942 DID 2-CV-6 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1051 RR 2-CV-6 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-1050 RR 2-DG-2 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1487 RR Attachment L-15-150 Page 163 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-MS-1 2MSS-AOV101A 2MSS-AOV101B 2MSS-AOV101C Close 2IAS-610-37 and open 2IAS-610-36 or 2IAS-39 to fail 2MSS-AOV101A, B and C closed to stop steam flow from SG A, B and C. BV2-1149 DID 2-MS-1 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C Close 2IAS-610-37 and open 2IAS-610-36 or 2IAS-39 to fail 2SDS-AOV112A, B and C closed to stop steam flow from SG A, B and C. BV2-1151 DID 2-MS-1 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C Initially, decay heat removal will be via the main steam code safeties. In the event that a main steam code safety sticks open, provide RCS makeup from RWST to compensate for reactivity change and RCS shrink. Actions to be performed in Control Room. BV2-1152 BV2-1153 PCS 2-MS-1 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1155 RR 2-PA-3 2CHS-LCV115C 2CHS-LCV115E 2CHS-LCV115B 2CHS-LCV115D Open and rack out the breaker for failed charging pump 2CHS-P21B or 2CHS-P21C at 4KVS-2DF and rack in and close the DC control power for spare charging pump 2CHS-P21B or 2CHS-P21C at 4KVS-2DF to allow pump start from the Control Room.

BV2-0839 BV2-1467 DID Attachment L-15-150 Page 164 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-PA-3 2SWS-MOV103A 2SWS-MOV103B 2SWS-MOV107A 2SWS-MOV107D If 2SWS-P21B and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close if spuriously opened. De-energize 2SWE-MOV116B at MCC2-E04 and close if spuriously opened. De-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. Manually throttle 2FWE-HCV100E to control SG A AFW flow. Manually throttle 2FWE-HCV100C to control SG B AFW flow. De-energize 2SWS-MOV102C2 at MCC2-E02, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C2 to provide B SWS flow. Start other DF bus loads as required.

OR If 2SWS-P21C and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 to prevent spurious opening. De-energize 2SWE-MOV116B at MCC2-E04 and close it and de-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. Manually throttle 2FWE-HCV100E to control SG A AFW flow. Manually throttle 2FWE-HCV100C to control SG B AFW flow. De-energize 2SWS-MOV102B at MCC2-E02, restart the diesel, manually start 2SWS-P21B while manually opening 2SWS-MOV102B to provide B SWS flow. Start other DF bus loads as required. BV2-0842 DID 2-PA-3 2SWS-MOV102A 2SWS-MOV106A 2SWS-MOV106B If 2SWS-P21B and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close if spuriously opened. De-energize 2SWE-MOV116B at MCC2-E04 and close if spuriously opened. De-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. Manually throttle 2FWE-HCV100E to control SG A AFW flow. Manually throttle 2FWE-HCV100C to control SG B AFW flow. De-energize 2SWS-MOV102C2 at MCC2-E02, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C2 to provide B SWS flow. Start other DF bus loads as required. OR If 2SWS-P21C and 2SWE-P21B are damaged, stop the 2-2 diesel to prevent overheating. De-energize 2SWS-MOV103B at MCC2-E04 and close if spuriously opened. De-energize 2SWE-MOV116B at MCC2-E04 and close if spuriously opened. De-energize 2SWS-MOV106B at MCC2-E04 and open it to align the B SWS flow path. Manually throttle 2FWE-HCV100E to control SG A AFW flow. Manually throttle 2FWE-HCV100C to control SG B AFW flow. De-energize 2SWS-MOV102B at MCC2-E02, restart the diesel, manually start 2SWS-P21B while manually opening 2SWS-MOV102B to provide B SWS flow. Start other DF bus loads as required. BV2-0841 DID Attachment L-15-150 Page 165 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-PA-3 4KVS-2AE-2E18 2FWE-HCV100C 2FWE-HCV100E De-energize 2FWE-P23A at 4KVS-2AE to stop train A AFW flow. BV2-1444 RR 2-PA-3 480VUS-2-8-7B De-energize the A backup group heater at 480VUS28 to prevent RCS overpressure. BV2-0844 DID 2-PA-3 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-0847 RR 2-PA-3 2CHS-LCV115C 2CHS-LCV115E Isolate hydrogen to the Aux Building and Align and start B LHSI Pump BV2-0838 DID 2-PA-3 4KVS-2AE Align AE and DF bus loads as required. BV2-1321 RR 2-PA-4 2CHS-LCV115C 2CHS-LCV115E Manually rack in the breaker and turn on the breaker control DC for 2CHS-P21C at 4KVS-2DF to allow the pump to be started from the Control Room to restore normal charging flow. BV2-0858 DID 2-PA-4 2SWE-MOV116A 2SWE-MOV116B 2SWS-MOV103A 2SWS-MOV103B 2SWS-MOV107A 2SWS-MOV107D If 2SWS-P21A and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A and 2SWE-MOV116A at MCC2-E03 and close them to prevent pump runout. Restart the diesel and manually start 2SWS-P21C to provide A SWS flow. Start other AE bus loads as required.

OR If 2SWS-P21C and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A and 2SWE-MOV116A at MCC2-E03 and close them to prevent pump runout. Restart the diesel and manually start 2SWS-P21A to provide A SWS flow. Start other AE bus loads as required. BV2-0860 DID 2-PA-4 2CHS-LCV115C De-energize 2CHS-LCV115C at MCC2-E03 and manually close the valve OR De-energize 2CHS-LCV115E at MCC2-E04 and manually close the valve to prevent hydrogen intrusion into the charging pump suction. BV2-0857 DID 2-PA-6 2CHS-LCV115C Manually rack in the breaker and turn on the breaker control DC for 2CHS-P21C at 4KVS-2AE to allow the pump to be started from the Control Room to restore normal charging flow. BV2-1226 DID 2-PA-7 2CHS-LCV115E Manually rack in the breaker and turn on the breaker control DC for 2CHS-P21C at 4KVS-2DF to allow the pump to be started from the Control Room to restore normal charging flow. BV2-1234 DID 2-PT-1 2BDG-AOV100C1 2BDG-AOV101C1 2BDG-AOV101C2 De-energize 2BDG-AOV101C2 at PNL-DC2-10 to isolate SG C blowdown flow. BV2-1080 DID Attachment L-15-150 Page 166 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-PT-1 2QSS-LT104A 2QSS-LT104B 2QSS-LT104C 2QSS-LT104D 2-CVCS-RAS 2CHS-LCV115B De-energize 2CHS-LCV115B at MCC2-E03 and manually open it to align suction to the charging pumps. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE and De-energize MOV-2CHS-289 at MCC 2-E05 and manually open , then throttle 2CH-477, FCV-2CH-122 bypass valve, to control RCS makeup flow. BV2-1079 BV2-1081 DID 2-PT-1 2FWE-HCV100A 2FWE-HCV100C 2FWE-HCV100E 2MSS-SOV102 4KVS-2AE-2E18 De-energize 2FWE-P23A at 4KVS-2AE and manually trip 2FWE-P22 to stop train A AFW flow. Manually throttle 2FWE-HCV100F to control B train SG A AFW flow. Manually throttle 2FWE-HCV100D to control B train SG B AFW flow. Manually throttle 2FWE-HCV100B to control B train SG C AFW flow. BV2-1083 BV2-1379 DID 2-RC-1 4KVS-2AE 4KVS-2AE-2E4 4KVS-2DF 4KVS-2DF-2F4 Align AE and DF bus loads as required. BV2-1046 RR 2-RC-1 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps.. BV2-0905 RR 2-RC-1 2RCS-PCV455C 2RCS-PCV455D 2RCS-PCV456 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 Perform repair procedure to allow the opening of 2RCS-MOV536. BV2-1415 DID 2-RC-1 2RCS-SOV200A 2RCS-SOV200B 2RCS-SOV201A 2RCS-SOV201B 2RCS-HCV250A 2RCS-HCV250B Perform repair procedure to provide power to the reactor vessel head vent valves. BV2-0911 DID 2-RC-1 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-0914 RR and DID Attachment L-15-150 Page 167 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-RC-1 2CHS-AOV200A 2CHS-AOV200C 2CHS-LCV460B De-energize 2CHS-AOV200A at PNL-DC2-11 and de-energize 2CHS-AOV200C at PNL-DC2-15 to isolate letdown flow.

OR Isolate instrument air to containment to fail 2CHS-AOV200A, B and C closed to prevent loss of RCS inventory. BV2-1359 RR 2-RC-1 2RCS-PT444 2RCS-PT445 2RCS-PCV455C 2RCS-PCV455D 2RCS-PCV456 Close 2RCS-PCV455C, 2RCS-455D and 2RCS-PCV456 at the keylock isolation switches.

OR Perform repair procedure to allow the closing of 2RCS-MOV535, 2RCS-MOV536 and 2RCS-MOV537 to isolate the PORVs.

OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-0913 RR and DID 2-SB-1 2CHS-LCV115C 2CHS-LCV115E De-energize 2CHS-P21A and 2CHS-P21C by manually stopping the 2-1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-2A to prevent pump damage due to loss of pump suction. BV2-0985 DID 2-SB-1 2SVS-PCV101A 2SVS-PCV101B

2SVS-PCV101C Manually close 2SVS-PCV101A to stop SG A steam flow. Manually close 2SVS-PCV101B to stop SG B steam flow. Manually close 2SVS-PCV101C to stop SG C steam flow. BV2-0988 RR 2-SB-1 2FWE-HCV100A 2FWE-HCV100C 2FWE-HCV100E De-energize 2FWE-P23A by manually stopping the 2-1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-2A to stop A train AFW flow. BV2-1424 RR 2-SB-1 Spurious SI 4KVS-2AE-2E12 4KVS-2AE-2E15 De-energize 2CHS-P21A and 2CHS-P21C by manually stopping the 2-1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-2A to control charging/HHSI flow. BV2-0990 DID 2-SB-1 Spurious SI 2SIS-MOV867A 2SISMOV867C De-energize 2CHS-P21A and 2CHS-P21C by manually stopping the 2-1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-2A to control charging/HHSI flow. De-energize 2SIS-MOV867C at MCC2-E05 and close it to isolate the spuriously opened SI flow path. BV2-1563 DID 2-SB-1 4KVS-2AE-2E2 De-energize 2QSS-P21A at 4KVS-2AE to stop quench spray flow. BV2-0991 DID Attachment L-15-150 Page 168 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-SB-1 480VUS287B 480VUS287C De-energize the A and D backup group heaters by manually stopping the 2-1 diesel generator and de-energizing off-site power to the AE bus at 4KVS-2A to prevent RCS overpressure. BV2-0989 DID 2-SB-1 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-0983 RR 2-SB-1 2RCS-PCV455D 2RCS-PCV456 Close 2RCS-PCV455D and 2RCS-PCV456 at the keylock isolation switches.

OR Perform repair procedure to allow the closing of 2RCS-MOV537 and 2RCS-MOV536 to isolate the PORVs.

OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-0987 RR and DID 2-SB-1 2CHS-AOV200A 2CHS-AOV200C 2CHS-LCV460B De-energize 2CHS-AOV200A at PNL-DC2-11 and de-energize 2CHS-AOV200C at PNL-DC2-15 to isolate letdown flow.

OR Isolate instrument air to containment to fail 2CHS-AOV200A, B and C closed to prevent loss of RCS inventory. BV2-0986 RR 2-SB-10 480VUS-2-2-2C De-energize the C control group heater at 480VUS22 to prevent RCS overpressure. BV2-1243 DID 2-SB-10 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-1245 DID 2-SB-2 2CHS-LCV115E De-energize 2CHS-P21B and 2CHS-P21C by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D to pump damage due to loss of suction. BV2-1339 DID 2-SB-2 2SVS-HCV104 Manually close 2SVS-HCV104 to stop SG A, B and C steam flow. BV2-1095 RR 2-SB-2 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F De-energize 2FWE-P23B by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D to stop B train AFW flow. BV2-1425 RR 2-SB-2 Spurious SI 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21B and 2CHS-P21C by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D to control charging/HHSI flow. BV2-1096 DID Attachment L-15-150 Page 169 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-SB-2 Spurious SI 2SIS-MOV867B 2SISMOV867D De-energize 2CHS-P21B and 2CHS-P21C by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D to control charging/HHSI flow. De-energize 2SIS-MOV867D at MCC2-E06 and close it to isolate the spuriously opened SI flow path. BV2-1564 DID 2-SB-2 4KVS-2DF-2F2 De-energize 2QSS-P21B by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D to stop quench spray flow. BV2-1098 RR 2-SB-2 480VUS287B 480VUS287C 480VUS297B 480VUS297C De-energize the B and E backup group heaters by manually stopping the 2-2 diesel generator and de-energizing off-site power to the DF bus at 4KVS-2D, and de-energize the A and D backup group heaters at 480VUS28 to prevent RCS overpressurization. BV2-1097 DID 2-SB-2 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1099 RR 2-SB-2 2RCSPCV455C Close 2RCS-PCV455C at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 to isolate the PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-1092 RR and DID 2-SB-3 2CHS-LCV115E 4KVS-2AE-2E15 Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-1054 DID 2-SB-3 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C Manually close 2SVS-HCV104 to stop SG A, B and C steam flow and manually throttle it to control SG A, B and C pressure. De-energize 2SVS-PCV101A at MCC2-E05 to stop SG A steam flow and manually throttle it to control SG A pressure. De-energize 2SVS-PCV101B at MCC2-E13 to stop SG B steam flow and manually throttle it to control SG B pressure. De-energize 2SVS-PCV101C at MCC2-E13 to stop SG C steam flow and manually throttle it to control SG C pressure. BV2-1063 BV2-1400 DID RR Attachment L-15-150 Page 170 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-SB-3 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100C 2FWE-HCV100D 2FWE-HCV100E 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. Manually throttle 2FWE-HCV100E to control A train SG A AFW flow. Manually throttle 2FWE-HCV100C to control A train SG B AFW flow. Manually throttle 2FWE-HCV100A to control A train SG C AFW flow. BV2-1056 BV2-1426 RR DID 2-SB-3 480VUS-2-2-2C 480VUS-2-9-7B 480VUS-2-9-7C De-energize the C control group heater at 480VUS22 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-1065 DID 2-SB-3 2HVC-ACU201A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation. BV2-1057 RR 2-SB-3 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1332 RR 2-SB-3 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA. BV2-1066 RR 2-SB-3 Spurious SI 4KVS-2DF-2F12 4KVS-2DF-2F15 4KVS-2AE-2E15 De-energize 2CHS-P21C at 4KVS-2AE OR Trip 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow. BV2-1067 DID 2-SB-3 Spurious SI 2SIS-MOV867B 2SISMOV867D 2SIS-HCV868A 2SIS-HCV868B De-energize 2CHS-P21C at 4KVS-2AE OR Trip 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow.

De-energize 2SIS-MOV867D at MCC2-E06 and close it to isolate spuriously opened SI flow paths.

Manually throttle 2SIS-MOV867D to control RCS makeup flow. BV2-1062 DID 2-SB-3 2RCS-PCV455C 2RCS-PCV456 Close 2RCS-PCV455C at the keylock isolation switch.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 to isolate the PORV. OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B. BV2-1060 RR and DID Attachment L-15-150 Page 171 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 2-SB-3 4KVS-2DF-2F2 Trip 2QSS-P21B at 4KVS-2DF to stop quench spray flow. BV2-1068 DID 2-SB-4 480VUS-2-2-2C De-energize the C control group heater at The Switchyard. BV2-0785 DID 2-SB-4 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-0784 RR 2-SB-4 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 De-energize 2RCS-P21A, 1B and 1C at the Switchyard to prevent an RCP seal LOCA. BV2-0795 RR 2-SB-6 4KVS-2AE-2E18 2FWE-HCV100A 2FWE-HCV100C 2FWE-HCV100E De-energize 2FWE-P23A at 4KVS-2AE to stop train A AFW flow. BV2-1380 DID 2-SB-6 480VUS287B 480VUS287C De-energize the A and D backup group heaters at 480VUS28 to prevent RCS overpressure. BV2-1250 DID 2-SB-8 480VUS-2-9-7B 480VUS-2-9-7C De-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-1134 DID 2-SB-8 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1136 RR 2-SG-1S 2MSS-SOV102 4KVS-2AE-2E18 2FWE-HCV100A 2FWE-HCV100C 2FWE-HCV100E 2FWE-HCV100B 2FWE-HCV100D 2FWE-HCV100F De-energize 2FWE-P23A at 4KVS-2AE and manually close 2MSS-15 to trip 2FWE-P22 to stop train A AFW flow. Manually throttle 2FWE-38 to control B train AFW flow. BV2-1126 BV2-1460 DID 2-SG-1S 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps. BV2-1129 RR 3-CR-1 2CHS-E212CHS-MOV378 Close 2CHS-214 to isolate seal water return heat exchanger flow. BV2-0866 RR Attachment L-15-150 Page 172 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 2BDG-AOV100A1 2BDG-AOV100B1 2BDG-AOV100C1 2BDG-AOV101A1 2BDG-AOV101A2 2BDG-AOV101B1 2BDG-AOV101B2 2BDG-AOV101C1 2BDG-AOV101C2 De-energize 2BDG-AOV101A2, B2 and C2 at PNL-DC2-10 to isolate SG A, B and C blowdown flow. BV2-0865 DID 3-CR-1 2CHS-LCV115C 2CHS-LCV115E 2CHS-LCV115B 4KVS-2AE-2E12 4KVS-2AE-2E15 De-energize 2CHS-P21A and 2CHS-P21C at 4KVS-2AE and de-energize 2CHS-P21B and 2CHS-P21 C at 4KVS-2DF to prevent pump damage on loss of suction. De-energize 2CHS-LCV115B at MCC2-E03 and manually open it or open 2CHS-LCV115B from the ASP to align suction to the charging pumps. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow. BV2-0873 RR 3-CR-1 2SWE-MOV116A 2SWE-MOV116B 2SWS-MOV102C1 2SWS-MOV102C2 2SWS-MOV103A 2SWS-MOV103B 2SWS-MOV107A 2SWS-MOV107D 2-CIB-SPUR If 2SWS-P21A and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close if spuriously opened. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and verify that it is open to align the A SWS flow path. De-energize 2SWS-MOV170A at MCC2-E01 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C1 at MCC2-E01, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C1 to provide A SWS flow. Start other AE bus loads as required.

OR If 2SWS-P21C and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close if spuriously opened. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and verify that it is open to align the A SWS flow path. De-energize 2SWS-MOV102A at MCC2-E01, restart the diesel, manually start 2SWS-P21A while manually opening 2SWS-MOV102A to provide A SWS flow. Start other AE bus loads as required. BV2-0883 DID Attachment L-15-150 Page 173 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 2SWS-MOV102A 2SWS-MOV106A 2-CIB-SPUR If 2SWS-P21A and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close if spuriously opened. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV170A at MCC2-E01 and open it to align seal water to 2SWS-P21C. De-energize 2SWS-MOV102C1 at MCC2-E01, restart the diesel, manually start 2SWS-P21C while manually opening 2SWS-MOV102C1 to provide A SWS flow. Start other AE bus loads as required.

OR IF 2SWS-P21C and 2SWE-P21A are damaged, stop the 2-1 diesel to prevent overheating. De-energize 2SWS-MOV103A at MCC2-E03 and close if spuriously opened. De-energize 2SWE-MOV116A at MCC2-E03 and close if spuriously opened. De-energize 2SWS-MOV106A at MCC2-E03 and open it to align the A SWS flow path. De-energize 2SWS-MOV102A at MCC2-E01, restart the diesel, manually start 2SWS-P21A while manually opening 2SWS-MOV102A to provide A SWS flow. Start other AE bus loads as required. BV2-0894 DID 3-CR-1 2MSS-AOV101A 2MSS-AOV101B 2MSS-AOV101C De-energize 2MSS-AOV101A, B and C at PNL-DC2-10 to stop steam flow from SG A, B and C. BV2-0875 RR 3-CR-1 2SDS-AOV112A 2SDS-AOV112B 2SDS-AOV112C De-energize 2SDS-AOV112A, B and C at PNL-AC2-03 to stop steam flow from SG A, B and C. BV2-0880 DID 3-CR-1 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C De-energize 2SVS-HCV104 at MCC2-E14 to stop SG A, B and C steam flow and manually throttle it to control SG A, B and C pressure. De-energize 2SVS-PCV101A at MCC2-E05 to stop SG A steam flow and manually throttle it to control SG A pressure. De-energize 2SVS-PCV101B at MCC2-E13 to stop SG B steam flow and manually throttle it to control SG B pressure. De-energize 2SVS-PCV101C at MCC2-E13 to stop SG C steam flow and manually throttle it to control SG C pressure. BV2-0882 DID 3-CR-1 2SVS-HCV104 2SVS-PCV101A 2SVS-PCV101B 2SVS-PCV101C Throttle 2SVS-PCV101A from the ASP to control SG C pressure and throttle 2SVS-PCV101B from the ASP to control SG B pressure.

BV2-0882 PCS Attachment L-15-150 Page 174 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 2FWE-HCV100A 2FWE-HCV100B 2FWE-HCV100C 2FWE-HCV100D 2FWE-HCV100E 2FWE-HCV100F De-energize 2FWE-P23B at 4KVS-2DF to stop train B AFW flow. Manually throttle 2FWE-HCV100E to control A train SG A flow. Manually throttle 2FWE-HCV100C to control A train SG B flow. Manually throttle 2FWE-HCV100A to control A train SG C flow. BV2-0874 DID 3-CR-1 4KVS-1G-1G5 4KVS-2A-2A1 4KVS-2B-2B1 4KVS-2C-2C1 4KVS-2D-2D1 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2FWS-P21A at 4KVS-2A & 4KVS-2B and de-energize 2FWS-P21B at 4KVS-2C & 4KVS-2D to stop main feedwater pump flow to the steam generators. BV2-0888 DID 3-CR-1 480VUS-2-2-2C 480VUS-2-8-7B 480VUS-2-8-7C 480VUS-2-9-7B 480VUS-2-9-7C De-energize the C control group heater at 480VUS22, de-energize the A and D backup group heaters at 480VUS28 and de-energize the B and E backup group heaters at 480VUS29 to prevent RCS overpressure. BV2-0884 DID 3-CR-1 2HVC-ACU201A Install a 5000 CFM portable fan in the Control Room doorway to supply temporary ventilation.

BV2-1328 RR 3-CR-1 2FWE-TK210 Perform actions of procedure 2OM-53A.1.A-1.8 to provide an alternate suction to the AFW pumps.

BV2-0891 RR 3-CR-1 2CHS-LCV115C De-energize 2CHS-LCV115C at MCC2-E03 and manually close the valve OR De-energize 2CHS-LCV115E at MCC2-E04 and manually close the valve to prevent hydrogen intrusion into the charging pump suction.

BV2-0871 DID 3-CR-1 2CHS-MOV289 Manually open 2CHS-477 to bypass the charging flow control valve. Manually close 2CHS-30 to isolate the charging flow control valve.

Manually throttle 2CHS-477 to control charging flow.

BV2-0887

RR 3-CR-1 2RCS-PCV455C 2RCS-PCV455D 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 Perform repair procedure 2OM-56C.4.F-8 to allow the opening of 2RCS-MOV536. Open PORV 2RCS-PCV456 at the ASP.

BV2-1416 DID Attachment L-15-150 Page 175 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 2RCS-PCV455C 2RCS-PCV455D 2RCS-MOV535 2RCS-MOV536 2RCS-MOV537 Attempt to control 2RCS-PCV456 at the ASP. BV2-1416 PCS 3-CR-1 2RCS-SOV200A 2RCS-SOV200B 2RCS-SOV201A 2RCS-SOV201B 2RCS-HCV250A 2RCS-HCV250B Perform repair procedure 2OM-56C.4.F-19 to provide power to the reactor vessel head vent valves.

BV2-1422 DID 3-CR-1 4KVS-2A-2A6 4KVS-2B-2B6 4KVS-2C-2C6 2RCS-PCV455A 2RCS-PCV455B De-energize 2RCS-P21A at 4KVS-2A, de-energize 2RCS-P21B at 4KVS-2B and de-energize 2RCS-P21C at 4KVS-2C to prevent an RCP seal LOCA.

BV2-0877 RR 3-CR-1 Spurious SI 4KVS-2AE-2E12 4KVS-2AE-2E15 4KVS-2DF-2F12 4KVS-2DF-2F15 De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to control charging/HHSI flow.

BV2-0886 DID 3-CR-1 4KVS-2B-2B2 4KVS-2C-2C2 4KVS-2D-2D2 2FWS-HYV157A 2FWS-HYV157B 2FWS-HYV157C De-energize 2CNM-P21A at 4KVS-2B, de-energize 2CNM-P21B at 4KVS-2C and de-energize 2CNM-P21C at 4KVS-2D to stop condensate flow to the steam generators.

BV2-1350 DID Attachment L-15-150 Page 176 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 Spurious SI 2SIS-MOV836 2SIS-MOV840 2SIS-MOV867A 2SIS-MOV867B 2SIS-MOV867C 2SIS-MOV867D 2SIS-HCV868A 2SIS-HCV868B 2SIS-MOV869A 2SIS-MOV869B De-energize 2CHS-P21A(C) at 4KVS-2AE AND De-energize 2CHS-P21B(C) at 4KVS-2DF to stop excessive RCS makeup flow. De-energize 2SIS-MOV836, 2SIS-MOV840, 2SIS-MOV867C and 2SIS-MOV869A at MCC2-E05 and manually close the valves and de-energize 2SIS-MOV867D and 2SIS-MOV869B at MCC2-E06 and close them to isolate spuriously opened SI flow paths. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE and manually throttle 2SIS-MOV836 to control RCS makeup flow.

BV2-0881 BV2-1395 DID 3-CR-1

2RCS-PT444 2RCS-PT445 2RCS-PCV455C 2RCS-PCV455D Close 2RCS-PCV455C and 2RCS-PCV455D at the keylock isolation switches.

OR Perform repair procedure to allow the closing of 2RCS-MOV535 and 2RCS-MOV537 to isolate the PORVs.

OR To provide a flow path from the containment sump to Charging/HHSI pump 2CHS-P21A de-energize 2SIS-MOV8809A, 2SIS-MOV8887A, 2SIS-MOV8811A, 2RSS-MOV156C, 2SIS-MOV863A, 2RSS-MOV155C and 2SIS-MOV8890A at MCC2-E11, de-energize 2CHS-LCV115B at MCC2-E03 and then manually close 2SIS-MOV8809A, 2SIS-MOV8887A, 2RSS-MOV156C and 2SIS-MOV8890A, manually open 2SIS-MOV8811A, 2SIS-MOV863A and 2RSS-MOV155C and then manually close 2CHS-LCV115B.

BV2-0878 RR and DID 3-CR-1 2SWS-STRM47 2SWS-PT117A 2SWS-AOV130A De-energize 2SWS-AOV130A at 480VUS-2-8 to restore the service water pump seal water supply.

BV2-0893 DID 3-CR-1 4KVS-2AE-2E2 4KVS-2DF-2F2 2-CIB-SPUR Trip 2QSS-P21A at 4KVS-2AE to stop A train quench spray flow and trip 2QSS-P21B at 4KVS-2DF to stop B train quench spray flow.

BV2-0890 RR 3-CR-1 4KVS-2AE Align AE and DF bus loads as required. BV2-1327 RR Attachment L-15-150 Page 177 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-CR-1 4KVS-2AE-2E14 4KVS-2AE-2E18 2FWE-HCV100C 2FWE-HCV100E 480VUS-2-8-7B 2SVS-PCV101A 2SVS-PCV101B 4KVS-2AE-2E12 2CHS-FCV122 2RCS-PCV456 2CHS-LCV460A 2CHS-LCV460B 2CHS-P22A 2CHS-SOV206 2EGS-EG2-1 2FWS-LI477F 2FWS-LI487F 2MSS-PI475F 2MSS-PI485F 2RCS-LI459AF 2RCS-PI403F 2RCS-PI455F 2RCS-TI413F 2RCS-TI423F 2RCS-TI410F 2RCS-TI420F 2FWE-FI100AF 2FWE-FI100BF

2NMS-NI31BF 2NMS-NI31DF ACB-42A ACB-2A10 ACB-2E7 ACB-2E10 2SWS-MOV113A 2SWS-MOV102A 2CHS-LCV115B ASP Power Supply Take the plant to "Safe and Stable" utilizing selected instruments and controls at the auxiliary shutdown panel, as directed.

BV2-0892 DID Attachment L-15-150 Page 178 Table 4 - BVPS-2 PCS Actions and RAs Classified as Being Credited for Defense in Depth (DID) or Risk Reduction (RR) 3-YARD-1 2CHS-LCV115B 2CHS-LCV115D De-energize 2CHS-LCV115B at MCC2-E03 and manually open it to align suction to the charging pumps. Manually start 2CHS-P21A or 2CHS-P21C at 4KVS-2AE to provide RCS makeup flow.

BV2-1109 DID Generic 2-DG-1 2-TB-1 2-TR-4 2-TR-5 3-RH-1 3-IS-2 3-SY-1 2FWE-TK210 Provide an alternate suction to the AFW pumps. BV2-1330 RR

Attachment L-15-150 Page 179

Response:

The BVPS fire PRA models take credit for a number of risk reduction modifications which are listed in Table S-2 of the LA R; however, the RCP shutdown seals and incipient detection are the only modifications credited to offset the risk increases of the NFPA 805 transition in the risk o ffset calculation. The other risk reduction modifications in LAR Table S-2 are credited in the fire PRA models for both the base case and compliant case when calculating delta risk, so they do not serve to offset any risk increase in the risk offs et calculation.

There are two primary reasons the risk offset calculation only takes advantage of the

new RCP shutdown seals and the incipient detection systems. First, these two modifications provide the greatest risk benefit of all the individual modifications being implemented as a result of the BVPS transition to NFPA 805. Since the new seals do

not resolve any specific VFDR but result in a significant risk reduction across the model, extending to other initiators beyond fire, th ey seemed an obvious choice to use for the risk offset calculation in order to obtain full credit representing their overall benefit to the PRA model and the station's safety posture as a whole. Incipient detection, on the

other hand, benefits only fire initiators; however, it too is a very real safety improvement to the station which goes well beyond what is strictly required for compliance. The incipient detection systems being installed at BVPS are designed to reduce the risk of Attachment L-15-150 Page 180 what would otherwise be, by a wide margin, the most significant fire scenarios at both units. Since incipient detection provides such a great improvement in the risk of some of the most significant fire sources without actually being required to resolve any particular VFDR, it seemed prudent to also cr edit this modification in the risk offset calculation.

Secondly, these two modifications are chosen for the risk offset calculation because they are among the easiest to remove from the FPRA models in order to actually perform the calculations. Other modifications such as fire-wrapping cables, moving detectors for code compliance, motor-operat ed valve (MOV) modifications to allow manual operation subsequent to spurious o peration, and so on, are more fully integrated into the underlying assumptions and structure of the PRA model such that they would be difficult to remove in order to produce the baseline risk numbers necessary for calculating the risk offset.

Conversely, the PRA modeling of the RCP shutdown seals and the incipient detections systems both include reliability variables

which can be set to guaranteed failure (that is, 1.0) in order to easily remove credit for these modifications and simplify the process of calculating risk offset and overall delta risk.

Table 5 below lists the modifications in Tabl e S-2 of the LAR whic h are categorized as VFDR or Risk Reduction modifications. The m odifications listed as "VFDR" resolve a VFDR (or multiple VFDRs), but many of th em also serve to reduce risk in some capacity. The modifications listed as "Risk Reduction" do not resolve any VFDR, and serve only to reduce the FPRA risk. Those m odifications listed in Table S-2 of the LAR and not shown here are categorized as "Code Compliance" and serve to resolve a compliance issue with the relevant code of record.

Table 5: LAR Table S-2 Plant Modifications BV1-0746 Manual isolation valves for each individual area will be added to permit lock out of local

areas supplied by the CO2 systems VFDR No BV1-1675 FPRA determined t hat affected cables are to be re-routed, or protected with fire barrier

wrap VFDR No BV1-2088 The proposed change wil l revise circuitry in order to ensure ventilation is available for

the fire area thereby eliminating manual action VFDR No BV1-2115 Change normal system alignment of these valves (MSIV bypass valves) to de-

energized shut VFDR No BV1-2283 Relocate temperat ure switch (TS-1HV-55B) and associated cable from 1-ES-1 VFDR No Attachment L-15-150 Page 181 Table 5: LAR Table S-2 Plant Modifications ventilation duct to 1-ES-2 fire compartment. BV1-2448 Installation of anti-motoring relays protected from fire will correct this issue (PCB-331 &

PCB-341 fail to trip) VFDR No BV1-2806 The control circuit associated with the offsite power feeder breakers and the EDG

will be modified to a llow manual alignment while preventing automat ic transfer of the EDG to the bus while it is powered from

offsite power VFDR No BV1-3024 Retire the BVPS-1 Boron Injection Surge Tank (BIT) and associated piping and

instrumentation by shutting TV-1SI-884A (BIT Recirc to Boron Inj Surge Tk Isol), B (BIT Recirc to Boron Inj Surge Tk Isol), and

C (Boron Recirc to BIT Isol) and isolate the

air supply to these valves. BIT heaters, 1SI-EH-1A and 1B, will also be permanently electrically disconnected. VFDR No BV2-0378

/

BV2-0401 Install an automatic fire suppression system

in the Train B Emergency Switchgear fire compartment VFDR No BV2-0406 Manual isolation valves for each individual area will be added to permit lock out of local

areas supplied by the CO2 systems VFDR No BV2-0511 Install fire barri er wrap on affected conduits (to eliminate a manual action transferring

EDG ventilation control to the ASP for

certain fires) VFDR No BV2-0753 Installation of anti-motoring relays protected from fires will correct this issue (PCB-351 & PCB-362 fail to trip) VFDR No BV2-1292 Once the loop fill valves 2RCS-MOV556A, B and C are in their normal system

arrangement of shut during power operation, de-energize the power supply to these MOVs VFDR No BV1-1875 Incipient detection will be installed in certain cabinets that potentially cause risk

significant fires Risk Reduction Yes Attachment L-15-150 Page 182 Table 5: LAR Table S-2 Plant Modifications BV1-2648 Modify MOVs to ensure manual operation capability after potentia l spurious operation Risk Reduction No BV1-2854 Computer Inve rter (INV-CMP) to be relocated to adjacent fire compartment (1-MG-1) Risk Reduction No BV1-3039 Add an isolation va lve and vent valve to the instrument air supply of each BVPS-1 Main

Steam Isolation Valve (TV-1MS-101A, B,

&C) operators in the Main Steam Valve

House (MSVH) in order to shut the MSIVs

by a Recovery Action for a fire in the

quench spray / auxiliary feedwater pump

room that prevents the MSIVs from

shutting.

Risk Reduction No BV1-3062 Install a low leak age Reactor Coolant Pump seal for each pump Risk Reduction Yes BV1-3064 Install a modi fication to reduce the cavitation that is reducing the service life of

existing Motor Driven Fire PP Modulating Relief Valve, RV-1FP-201 Risk Reduction No BV2-0828 Install a low leak age Reactor Coolant Pump seal for each pump Risk Reduction Yes BV2-0829 Incipient detection will be installed in certain cabinets that potentially cause risk

significant fires Risk Reduction Yes BV2-1018 Modify the PORV c ontrol circuits to provide a control switch located outside

Containment that has capability to close the

PORVs for fires located outside

Containment. For a fire in the compartment

containing the new PORV control switch

protect cables associated with the PORV

block valve to ensure the PORV can be

isolated to mitigate the LOCA Risk Reduction No BV2-1435 Modify MOVs to ensure manual operation capability after potentia l spurious operation Risk Reduction No

Attachment L-15-150 Page 183

Response:

The methodology that was used at BVPS to evaluate DID and safety margin includes:

Defense in Depth Approach

For a FRE, a review of the impact of the VFDR's on DID was performed addressing each of the elements below.

1. Evaluate the fire area for the impact of the VFDR's on fire protection DID. Fire protection DID is achieved when an adequat e balance of each of the following elements is provided:

a. Preventing fires from starting b. Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting fire damage; and c. Providing an adequate level of fire pr otection for structures, systems, and components important to safety, so t hat a fire that is not promptly extinguished will not prevent essential plant safety functions from being

performed.

2. In general, the DID requirement is satisfied if the proposed change does not result in a substantial imbalance among those elements. Table 6:

Attachment L-15-150 Page 184 and Table 7: provide examples of the proce ss used by the DID expert panel to review the balance between DID echelons to determine if a substantial imbalance exists.

In the event there was an imbalance in the DID echelons during the evaluation, an expert panel evaluated options available to reduce the imbalance and selected the optimum combinat ion to address the issue. Examples of the types of changes to the fire pr otection program made in response to this assessment include:

a. Addition of transient combustible exclusion areas b. Restriction of access to identifi ed areas via a key control program c. Updating the fire brigade pre-fire plans and training material

3. A review to evaluate the potential for risk significant fire scenarios impact on VFDRs was completed. A fire scenario is defined as a unique quantification of a fire damage state (which may include severity factors and probability of non-suppression) multiplied by a conditional core damage probability (CCDP) or

conditional large early release probability (CLERP) to arrive at a CDF or LERF. For purposes of DID, "potentially ri sk significant" fire scenarios could be characterized as follows:

a. A scenario in which the calculated ri sk is equal to or greater than 1E-6 per year for CDF and/or 1E-7 per year for LERF, could be characterized as "potentially risk significant." b. A scenario in which the calculated risk falls between 1E-6 per year and 1E-8 per year for CDF, or between 1E

-7 per year and 1E-9 per year for LERF, and where DID echelon 1 and 2 attr ibutes are causing a significant reduction in risk, could be characterized as "potentially risk significant." c. A scenario in which the calculated risk is less than 1E-8 per year for CDF and/or 1E-9 for LERF, regardless of reliance on DID echelon 1 and 2

attributes, may be characterized as "potentially not risk significant." These values are considered "potentially not risk significant" based on being two to three orders of magnitude below t he acceptance criteria of RG 1.174 as referenced by RG 1.205, Rev. 1. d. A scenario with a high consequence (t hat is, CCDP greater than E-1) could be considered "potentially risk significant."

4. Fire protection features and system s relied upon to ensure DID are clearly identified in the assessment (that is, detection, suppression system, and so on).

5. Verify that DID is maintained by assessing and documenting that the balance is preserved among prevention of core damage, prevention of containment failure, and mitigation of consequences. Regulatory Guide 1.174 provides guidance on Attachment L-15-150 Page 185 maintaining the philosophy of nuclear safe ty defense-in-depth that is acceptable for NFPA 805 "Fire Risk Evaluations."

6. Each fire area was evaluated for the need to incorporate DID enhancements to provide assurance that plant per formance goals can be achieved and maintained. Documentation of these defense-in-depth enhancements are on a fire area basis and/or tied directly to a VFDR disposition, as appropriate.

7. The results of the DID review are in a tabular format, such as shown in Table 7: that follows. DID attributes were

evaluated for applicability to NFPA 805, Section 4.2.3 or 4.2.4.

a. If a DID attribute is credited for NSCA deterministic criteria, licensing action or engineering equivalency evaluation, the system/feature should already be considered to form an int egral part of defense-in-depth. The parent echelon of the system/feature was then evaluated against the process and considerations in Tables 6 and 7 to determine if any

improvements or changes are necessary, such as to offset a weakness in another echelon.

b. If the fire PRA credits any of the fi re protection features or a recovery action to improve the risk profile, then t hese attributes or features should

already be considered to form an integr al part of DID. The parent echelon of the system/feature was then ev aluated against the process and considerations in Tables 6 and 7 to determine if any improvements or changes are necessary, such as to offset a weakness in another echelon.

c. DID attributes that go above and bey ond the existing requirement(s) with the purpose of bolstering identified weaknesses within the defense-in-depth elements to maintain an overall balance should be designated as a change or improvement necessary for defense-in-depth.

Note- this may or may not invo lve a physical improvement to

the element, but by virtue of in cluding an attribute that was not required for deterministic or risk reasons, defense-in-depth is considered enhanced.

d. Features or enhancements required for DID warrant consideration for inclusion in the monitoring program.

Attachment L-15-150 Page 186 Fire Compartment: _________________ Date:

__________________

Members / Position:

__________________________________________________________________

______________________________________

_____

__________________________________________________________________

______________________________________

______________________

PRA Document: ____________________ Detailed Fire Model

____________________

Multi-Compartment Fire Analysis: ____________________ Initial Screening (Fire PRA Table 6-4A, Base Case OMA HEP Values sorted by CCDP):

Is CDF > 1E-06/year / LERF > 1E-07/year OR

CCDP > 1E-01?

Fire scenario data is taken at the time of the DID review. Additional Screening (Fire PRA Table 6-4A, Base Case OMA HEP Values sorted by CCDP):

Echelon 1 and/or 2 credited for risk reduction?

AND Is CDF >1E-08/year / LERF >1E-09/year?

Attachment L-15-150 Page 187 Fire scenario data is taken at the time of the DID review. Echelon 1 - Preventing fires from

starting Echelon 2 - Detecting fires

quickly and suppressing those

that occur, thereby limiting

damage Echelon 3 - Providing protection for systems and structures so

that safe shutdown can be

achieved Over-reliance and increased

length of time or risk in

performing programmatic

activities to compensate for

weaknesses in plant design is avoided. Pre-fire nuclear safety system redundancy, independence and

diversity are preserved Attachment L-15-150 Page 188 commensurate with the expected

frequency and consequences of challenges to the system and

uncertainties (e.g., no risk

outliers). (

.) Independence of DID elements are not degraded. Defenses against human errors

are preserved. The intent of the General Design

Criteria in Appendix A to 10 CFR

Part 50 is maintained. Recommended enhancements or

insights gained by DID review.

Operator Actions credited for

DID, but not included in Fire PRA

Table 6-1

Attachment L-15-150 Page 189 Combustible Control is

implemented in accordance

with Procedure 1/2-ADM-1906, "Control Of Transient

Combustible and Flammable

Materials." Hot Work Control is

implemented in accordance

with Procedure 1/2-ADM-1904, "Control of Ignition Sources (Hot Work) and Fire Watches." Fire Detection System Automatic Fire Suppression Portable Fire Extinguishers Hose stations and hydrants

located in the area(s) Fire Pre-Fire Plan

Attachment L-15-150 Page 190 Walls, floors ceilings and

structural elements are rated or have been evaluated as

adequate for the hazard Openings in the fire barrier are

rated or have been evaluated as adequate for the hazard Supplemental barriers (e.g.,

ERFBS, cable tray covers, etc.) Fire rated cable Guidance provided to

operations personnel detailing

the required success path(s)

including recovery actions to

achieve nuclear safety

performance criteria Attachment L-15-150 Page 191 Safety Margin Approach

A review of the impact of the change on safety margin was performed in the FREs. An acceptable set of guidelines for making that assessment is summarized below. Other equivalent acceptance guidelines may also be used.

1. Codes and standards or t heir alternatives accepted for use by the NRC are met, and 2. Safety analysis acceptance criteria in the licensing bases (that is, UFSAR, supporting analyses) are met or provide sufficient margin to account for analysis and data uncertainty.

The requirements related to safety margins for the change analysis are described for

each of the specific analysis types used in s upport of the fire risk evaluation. These analyses can be grouped into four categories:

1. Fire Modeling

2. Plant System Performance

3. PRA Logic Model

4. A Required Review of Success Path

1. Fire Modeling: Document the results of the qualitative safety margin review.

Include a review of the use of applic able codes and standards developed by industry and NRC staff to ensure realis tic yet conservative results.

2. Plant System Performance: The development of the fire risk evaluation involved the re-examination of plant system performance, given the specific demands associated with the postulated fire event.

The methods, input parameters, and acceptance criteria used in these analyses were reviewed against those used for the plant design basis events. This review served to establish that the safety margin inherent in the analyses for the plant design basis events has been

preserved in the analysis for the fire event and therefore satisfies the requirements of this section.

From a safety margin perspective, the evaluation of the plant system performance addressed the following topics:

a. Were input parameters for plant performance analyses (that is, heat transfer coefficients, pump performance curves) altered from those used for plant design basis events such that the margin was lessened? b. Were codes and standards used to determine plant system performance acceptable to the NRC?

Attachment L-15-150 Page 192 3. PRA Logic Model: The quantification fo r fire related CDF/LERF relies upon the fire PRA model. It is recognized that use of a fire PRA often requires model modifications to be performed to the inte rnal events PRA. These modifications may include altering basic event failure probabilities, adding basic events, and changing the logic structure. These changes were evaluated against the

methods and criteria for the overall fire PRA model development for consistency or confirmation of bounding treatment to conf irm that the safety margin inherent in the PRA model is preserved.

From a safety margin perspective, t he evaluation of the PRA logic model addressed the following topics:

a. Were the risk-informed, performance based processes utilized based upon NFPA 805, 2001 edition, endorsed by the NRC in 10 CFR 50.48(c)? b. Was the fire risk evaluation pr ocess in accordance with NEI 04-02, Revision 2, which is endorsed by the NRC in RG 1.205, Revision 1? c. Was the fire PRA developed in accordance with NUREG/CR-6850, which was developed jointly by the NRC and EPRI? 4. Success Path Review: Validate and document that t he VFDRs have been evaluated as acceptable (wit h or without modifications) based upon the following:

a. The measured change in CDF and LERF

b. Adequate DID and safety margins are maintained c. That the results of this evaluation meet the requi rements of NFPA 805 Section 4.2.4.2 and that a success path effectively remains free of fire damage and, therefore, t he nuclear safety perfo rmance criteria of NFPA 805 are met.

Attachment L-15-150 Page 193

Response: a) Westinghouse letter "Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements From Section 4 of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications For The Beaver Valley Unit 1 Fire Probabilistic Risk Assessment" dated April 2009 lists the initial BVPS-1 peer review as being performed against ASME/ANS RA-S-2008a. The changes between the

RA-S-2008 and RA-Sa-2009 standards were reviewed, and the RA-S-2008a standard used in the BVPS-1 2009 peer review was found to match the RA-Sa-2009 standard with respect to all the identified changes between RA-S-2008 and RA-Sa-2009. Additionally , the 2011 focused-scope peer review report presents a summary of all SRs and ho w they are met or not met. Any SR not reviewed as part of the focused-scope review was labeled as "[Initial Review]" and the summary of the SR from the 2009 peer review was carried forward into the 2011 report. All SRs bearin g this "[Initial Review]" label were reviewed to confirm the requirement had not changed between versions of the standard, and to confirm t hat the model summary in the report continued to adequately address the RA-Sa-2009 versio n of the SR. It is therefore determined that the 2009 BVPS-1 peer review was effectively performed against the ASME/ANS RA-Sa-2009 standar d even though this version was not officially published until after the peer review was performed, since the SRs in the

RA-S-2008a standard which was used fo r the 2009 BVPS-1 peer review match the SRs in the RA-Sa-2009 standard.

Attachment L-15-150 Page 194 b) RG 1.200, Revision 2, was followed by the BVPS-1 focused-scope peer review team in 2011, as well as by the BVPS-2 peer review team in 2012. In both cases the NRC's clarifications and qualifications in the Regulatory Guide were considered, and the NEI 07-12 peer review process was utilized.

Westinghouse letter "Follow-on Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements From Section 4 of the ASME/AN S Standard For The Beaver Valley Unit 1 Fire Probabilistic Risk Assessment" dated April

2011 states in section 1.1 "The purpose of this report is to document the final results of the Focused scope follow-on Peer Review of Beaver Valley Power

Station (BVPS) Unit 1 (BV1) Fire Pr obabilistic Risk Assessment (FPRA) against the requirements of Secti on 4 of the American Societ y of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA Standard (Reference 1) and any

Clarifications and Qualifications provi ded in the Nuclear Regulatory Commission (NRC) endorsement of the Standard contained in Revision 2 to Regulatory Guide (RG) 1.200 (Reference 9). This peer re view was performed using the process defined in Nuclear Energy In stitute (NEI) 07-12 (Referen ce 2)." Section 2.2 of the letter also further clarifies, "For a peer review of a Fire PRA against the ASME/ANS PRA Standard, the applicable portions of a hos t utility's Fire PRA are reviewed against the applic able ASME/ANS PRA Standard SRs in Section 4.2 of the ASME/ANS PRA Standard, following the guidance of Section 1.6 of the ASME/ANS PRA Standard.

Where the NRC has provi ded a clarification or qualification for a given SR in RG 1.200, the NRC clarificati on/qualification is considered to govern and the review is c onducted against the SR as clarified or qualified."

For BVPS-2, Westinghouse letter "Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirem ents From Section 4 of the ASME/AN S Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications For the Beaver Valley Station Unit 2 Fire Probabilistic Risk Assessment" dated Apr il 2012 states in section 1.1 "The purpose of this report is to document the final results of the Peer Review of the Beaver Valley Nuclear Station Unit 2 Fire Probabilistic Risk Assessment (Fire PRA) against the requirem ents of Section 4 of the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) Combined PRA standard RA-Sa-2009 (Reference 1). This peer review was performed using the process defined in Nuclear Energy In stitute (NEI) 07-12 (Reference 2)." Although the use of RG 1.200, Revision 2, is not clearly specified in the methodology sections of this BVPS-2 peer review report, the clarifications and qualifications presented in t he Regulatory Guide were considered in the review, as evidenced by a statement in Table 4-10: "The cumulative impact of the screened PAUs is small (less than 10 percent of fire CDF and LERF). The total CDF and LERF associated with the scr eened scenarios and PAUs are less than 10 percent of fire CDF and LERF (which meets the NRC clarification on QNS-C1 Attachment L-15-150 Page 195 in RG 1.200, Rev. 2)." Additionally, the lead reviewer from the BVPS-2 FPRA peer review confirmed via email that "-ye s, the BV-2 Fire PRA peer review was performed against the Reg Guide 1.

200 Rev. 2 and ASME/ANS-RA-Sa-2009 PRA Standard and the clarifications/qualifications presented in the RG 1.200, Rev. 2 were considered in the review."

v t e Letter Sequence Response to RAI
CAC:MF3301, (Approved, Closed) CAC:MF3302, (Approved, Closed)
Initiation Request Acceptance... Supplement, Supplement Administration Questions 3 March 2016 25 April 2016 9 October 2015 24 November 2015 7 April 2016 30 March 2016 2 December 2016 8 August 2017 Answers 27 May 2015 6 November 2015 21 December 2015 12 May 2016 30 January 2017 Results Approval, Approval Other: ML16158A002, ML17335A096, ML18058A942, ML18058A953, ML18058A985, ML18058B072, ML18059A798, ML18099A232
MONTHYEAR2016-06-01 [Table View]

L-15-150, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805

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SUBJECT:

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2.4 Conclusion

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L-15-150, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805

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SUBJECT:

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2.3 Evaluation

2.4 Conclusion

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