ML20023D918

Provides Addl Info Re Util Request for Exemption from 10CFR50,App R Re Control Room Fire Per 830318 Meeting. Alternate Operator Actions Can Be Completed to Facilitate Safe Shutdown Following Fire in Control Boards

ML20023D918
Person / Time
Site:	Millstone
Issue date:	05/25/1983
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
B10796, TAC-48643, NUDOCS 8306060154
Download: ML20023D918 (31)

Text

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a ggg General Offices e Seldon Street, Berlin Connecticut P.O. BOX 270 2,,"

$ Z .""$ C " ~ HARTFORD. CONNECTICUT 06141-0270 (203) 666-69 M L L J %Z', "J' ',","2',","",

May 25,1983 Docket No. 50-336 B10796 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

(1) W. G. Counsil letter to D. G. Eisenhut, dated March 1,1982, Docket No. 50-336.

(2) W. G. Counsil letter to D. G. Eisenhut, dated July 16, 1982, Docket No. 50-336.

(3) W. G. Counsil letter to D. G. Eisenhut, dated April 15,1983.

(4) D. M. Crutchfield letter to W. G. Counsil, dated January 6, 1983.

(5) H. R. Denton letter to W. G. Counsil, dated May 10,1982.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Control Room Fire Review Supporting Exemption from 10CFR50, Appendix R By References (1) and (2), Northeast Nuclear Energy Company (NNECO) submitted a request for and provided information in support of an exemption for the Millstone Unit No. 2 control room from certain requirements set forth in Appendix R to 10CFR Part 50. On March 18, 1983, a meeting was held between our respective Staffs in your Bethesda office for the purposes of discussing the NRC's draf t Safety Evaluation Report (SER) (Reference (4)) of the Reference (1) and (2) information. At the meeting our respective Staffs agreed that the Millstone Unit No. 2 control room should be evaluated consistent with criteria 8306060154 830525 l PDR ADOCK 05000336  !

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i used to evaluate the Haddam Neck Plant control room.1 Further, it was agreed that the only apparent outstanding issue regarding the Millstone Unit No. 2 control room exemption request related to an evaluation of alternative actions which could be taken by operators to safely shutdown the plant in the event of a fire inside the control boards. We informed the Staff of our efforts to evaluate the Millstone Unit No. 2 main and auxiliary control panels and our preliminary i conclusions that alternate operator actions would be available to achieve safe shutdown in the event of a fire inside the control boards. It is the purpose of this letter to provide information which confirms the preliminary conclusions presented to the Staff during our March 18, meeting. The attached information presents the results of failure mode and effects analyses of the main and auxiliary control boards in the Millstone Unit No. 2 control room.

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The evaluations demonstrate that alternate operator actions can be completed to bring the Plant to safe shutdown following a fire in the main or auxiliary control boards. From the results of these analyses, as set forth in the attachment, ~' -

NNECO has concluded that, taking into consideration possible spurious .

equipment operation and time and manpower required to accomplish functions, safe shutdown 2 can be achieved assuming the loss of the main control board or auxiliary control panels as described in the attachment. It remains NNECO's contention that a fire of such magnitude is incredible in the control room due to the unique active and passive fire protection features of this fire area as described in Reference (3). NNECO's position in this regard is supported by the probabilistic risk assessment of Reference (1).

1 Specifically, assurances needed to be provided which reflect the following:

(1) operability to safe shutdown with loss of two adjacent main control board panel sections or a single fully enclosed auxiliary control board panel, or a technically justified evaluation of a fire within the main control board of a magnitude smaller than two adjacent main control board panels; (2) that spurious equipment operation can be compensated for using either a system approach or loss of adjacent panel sections analysis; (3) actions being taken outside of the control room are achievable considering a fire in the control room, time needed to accomplish the function, and manpower required.

These criteria are set forth in the NRC Staff's December 9,1982 letter to Connecticut Yankee Atomic Power Company summarizing the results of a December 1 meeting with the Staff (Docket No. 50-213).

2 As set forth in Reference (1), safe shutdown involves reactor trip and subsequent cooldown to cold shutdown with no off-site power.

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NNECO intends to incorporate the compensatory actions described in the attachment into a safe shutdown procedure. It is anticipated that color coding or other human factors motivated features will be utilized to facilitate the recognition of the equipment which must be operated to implement this procedure. Training will be conducted regularly to ensure familiarity with the required actions.

In addition, NNECO has provided responses to Section 8 of Enclosure 1 of the clarification of Generic Letter 81-12. This information was requested by the Staff for the Haddam Neck Plant and therefore is provided here for Millstone Unit No. 2 to facilitate your reviews of the control room exemption request.

In conclusion, we maintain that the information contained harein together with that submitted in References (1), (2), and (3) provides reasonable assurance that adequate safe shutdown capability is available in the event of a credible control room fire thus enabling the NRC Staff to grant the Millstone Unit No. 2 control room exemption request. Detailed operating procedures and the plant modifications required to achieve safe shutdown will be implemented on an agreed schedule subsequent to NRC Staff approval.

To the extent that the NRC Staff proposes to take action to deny the control room exemption request or any of the remaining unresolved exemption requests, .

NNECO reaffirms its request as set forth in Reference (3) for an appeal meeting with Mr. Richard Vollmer. NNECO also reiterates that implementation schedules for all proposed Appendix R related modifications will be developed following Staff disposition of all pending exemption requests.

We trust you will find this information satisfactory.

Very tru'ly yours, NORTHEAST NUCLEAR EhERGY COMPANY

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. 8[dt W. C. 'Counsil Senior Vice President cc: W. V. Johnson R. H. Vollmer l

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Docket No. 50-336 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Control Room Fire Analysis May,1983

Northeast Nuclear Energy Company (NNECO) performed failure mode and effects analyses of the main control board (MCB) and auxiliary control board (ACB) at the Millstone Unit No. 2 to determine the impact on safe shutdown of a control room fire which involves the internals of these panels. The results of the analyses presented herein demonstrate that safe shutdown can be achieved with alternate operator actions performed inside and outside the control room assuming the complete loss of the main control board (MCB) or single, enclosed auxiliary control board (ACB) panels. The purpose of the analyses was to demonstrate:

1. operability to safe shutdown with loss of two adjacent main control board panels or a single enclosed auxiliary control board panel or a technically justified evaluation of a fire within the MCB of a magnitude smaller than two adjacent sections;

2. spurious operation of affected equipment can be cempersated for using either a systems approach or a loss of adjacent panel section analysis; and

3. actions taken outside the control room are achievable considering a fire in the control room, time needed to accomplished the function and manpower required, The control panel wiring installed in the Millstone Unit No. 2 control room cabinets is IEEE-383 qualified providing a high degree of resistance to damage from the effects of a fire. The damage threshold for cabling qualified to IEEE-383 has been demonstrated to be on the order of 2600C. This quality coupled with the Halon 1301 suppression system proposed to be installed in the MCB and ACB together with prompt and effective operator response will ensure any postulated MCB fire is limited to less than two adjacent panel sections.

For each MCB panel or ACB panel (See Figure 1), all devices on the front, rear and within the panel section were evaluated as well as the control circuit wiring in, eround, among and through the board sections. The evaluation determined whether the circuitry was credited in the safe shutdown concept as described in Reference (1) or had the potential for deleterious effects on safe shutdown due to spurious operation of the circuit. For instances satisfying either criterion above, compensatory actions have been identified to ensure that safe shutdown is achieved. For the purpose of evaluating operator actions required following a fire it was assumed that the circuit failures are " worst case" and that affected components / equipment assumed a state adverse to that required for safe shutdown. The compensatory actions or alternate shutdown actions consist of remote operation and monitoring of safe shutdown equipment and instrumentation, respectively, at Panel C21B proposed to be located in Fire Area T-5, plus manually opening control circuits, manually operating circuit breakers or motor controllers and manual valve manipulations.

Table I lists the components of the MCB and ACB, which, if damaged by fire, could compromise safe shutdown capabilities through inoperability or spurious operations. A brief discussion of the alternate shutdown actions is also provided for 'each circuit / component assuming each potential failure mode. Only those circuits / components which have been determined to have an effect on safe shutdown are presented in Table 1, however the analysis was performed for all MCB and ACB circuits / components. Table 1 identifies the MCB or ACB circuit, system affected and specific components within that system, failure

modes of the MCB circuit, the effect on safe shutdown of the particular failure mode and a brief discussion of the compensatory actions or plant modifications which alleviate the effect.

Table 2 presents (1) a summary of the alternate shutdown actions which must be employed assuming a fire in the MCB and (2) the times associated with physically performing such actions.

The alternate shutdown actions assuming a control room fire were developed to achieve the following:

1. assure reactor trip

2. remove decay heat via the atmospheric dump valves and supply auxiliary feedwater to the steam generators;

3. isolate the primary system to maintain inventory and restore charging flow to accommodate reactor coolant shrink and leakage.

4. monitor safe shutdown instrumentation.

The analyses of the ACB panels have demonstrated that a fire in any ACB panel will not effect safe shutdown. The safe shutdown related equipment housed in the ACB's includes the emergency bus sequencing circuitry for the diesel generators in Panels RCO2B and RCO2C and the redundant source range neutron monitors located in Panels RCOSA, RCO5B, RCO5C and RCO5D. These six panels are enclosed and separated by sheet metal panels. A fire in any cabinet will render only one train of safe shutdown equipment inoperable. The redundant train will remain available to shut the plant down.

Assuming a fire in the MCB or ACB, the fire brigade function would be fulfilled by personnel from both Millstone Unit No. I and 2 as is current practice. The on shif t complement of personnel at both Plants is more than adequate to fulfill both the fire fighting and alternate shutdown activities for a postulated control room fire.

Communications between operators would be through normal interplant systems with portable two-way radios as backup.

Plant modifications required to implement these actions consist of modifications to the control and instrumentation circuitry in the Hot Shutdown Panel located in Fire Area T-4. This Panel will be modified to provide a new panel in Fire Area T-5, remote from the control room, from which to operate certain safe shttdown equipment. This modification was discussed in Reference (2).

Figures 2 and 3 present a conceptual design configuration for these circuits.

This design ensures one train of selected safe shutdown equipment will remain available following a single fire in area A-42, T-4 or T-5.

The fellowing information h provided in response to the clarification of Generic Letter No. 81-12 (Reference (5)) as it regards the alternate operator actions described herein.

Ouestion

a. List the system (s) or portions thereof used to provide the shutdown capability with the loss of offsite power.

Response

A complete description of the normal method for plant shutdown is provided in Section V of Reference (1).Section VI provides a discussion of the safe shutdown concept for Appendix R. The following systems or portions thereof are utilized to maintain hot shutdown with a loss-of-offsite power following a fire:

1. Service water pumps and associated valves.

2. Chemical and volume control system (CVCS) consisting of the charging pumps, refueling water storage tank, boric acid gravity feed piping, and associated valves.

3. Diesel generator and associated emergency electrical equipment.

4. Main steam system consisting of the atmospheric steam dump valves, main steam safety valves, main steam isolation valves, and steam to the auxiliary feedwater pump turbine.

5. Turbine driven auxiliary feedwater pump and associated valving with its water supply being the Condensate Storage Tank.

- 6. Instrumentation for pressurizer level, pressurizer pressure, steam generator level, reactor coolant ' system temperature (TCOLD) and source range neutron monitor.

Cold shutdown is achieved using the following systems:

1. Low Pressure Safety Injection pump, shutdown cooling heat exchanger, and associated valves.

2. Reactor Building Closed Cooling Water (RBCCW) pump, RBCCW heat exchanger and associated valves.

3. Service water pumps and associated valves.

4. Diesel generator and associated equipment

5. Chemical and volume control system consisting of charging pumps, refueling water storage tank, and associated valves.

6. Instrumentation listed in Number 6 above.

Question

b. For those systems identified in "la" for which alternative or dedicated shutdown capability must be provided, list the equipment and components of the normal shutdown system in the fire area and identify the functions of the circuits of the normal shutdown system in the fire area (power to what equipment, control of what components and instrumentation).

Describe the system (s) er portions thereof used to provide the alternative shutdown capability for the fire area and provide a table that lists the equipment and components of the alternative shutdown system for the fire area. For each alternative system identify the function of the new circuits being provided. Identify the location (fire zone) of the alternative shutdown equipment and/or circuits that bypass the fire area and verify that the alternative shutdown equipment and/or circuits are separated from the fire area in accordance with Section III.G.2.

Response

Postulating a fire in the main control board or auxiliary control panel which renders the power supply or control of any safe shutdown system component inoperable would necessitate the operation of that component from a remote location. These alternate operator actions, their location within the plant and the time to complete them is provided in Table 2. Table I herein identifies the component of the safe shutdown system located in the main control board and describes the function (i.e., power supply, control circuit, instrumentation) of the circuit for that component.

The alternate operator actions are performed using existing plant equipment including local manual valve manipulation, motor control center starter and molded case circuit breaker operation and 4.16kv and 480 VAC circuit breaker operation. The location where each alternate operator action is performed is presented in Table 2.

Modifications to the existing Hot Shutdown Panel (C-21) located in Fire Area T-4 are planned which will enable the operation of certain safe shutdown equipment remote from the control room in the event of a MCB fire. One train of charging, auxiliary feedwater, atmospheric steam dump valves and safe shutdown instrumentation will be provided at a new panel (C-21B)in Fire Area T-5. These controls are currently wired in parallel with the MCB circuits. The MCB circuitry will be provided with isolation devices at C-21B which will ensure the operability of Panel C-21B in the event of a main control room fire.

NNECO discussed conceptual modifications to the Hot Shutdown Panel Circuitry (C-21) in Fire Area T-4 in Reference (2).

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i Questions

c. Provide drawings of the alternative shutdown system (s) which highlight any i connections to the normal shutdown systems P& ids for piping and

] components, elementary wiring diagrams for electrical cabling. Show the

! electrical location of all breakers for power cables, and isolation devices for control and instrumentation circuits for the alternative shutdown system for that fire area.

Response

Alternate shutdown systems are not proposed by NNECO to achieve safe

shutdown in the event of a fire in the control room at Millstone Unit No. 2.

l Alternate operator actions will be performed using existing plant equipment such as motor control centers, circuit breakers and manual valves. Modifications to the Hot Shutdown Panel (C-21) are depicted in the attached Figures 2 and 3 and

are discussed in response to Question b.

i Questions

d. Verify that changes to safety systems will not degrade safety systems; (e.g., new isolation switches and control switches should meet design

criteria and standards in the FSAR for electrical equipment in the system 1' that the switch is to be installed; cabinets that the switches are to be mounted in should also meet the same criteria (FSAR) as other safety

+ related cabinets and panels; to avoid inadvertent isolation from the control room, the isolation switches should be keylocked or alarmed in the control room if in the " local" or " isolated" position; periodic checks should be made

to verify that the switch is in the proper position for normal operation; and a single transfer switch or other new device should not be a source of a failure which causes loss of redundant systems).

! Response i

Modifications to existing safety systems at Millstone Unit No. 2 to facilitate the i' alternate operator actions described herein will be reviewed in accordance with 10CFR50.59. All designs will meet or exceed the original criteria and standards to which the plant was constructed. Detailed designs will be developed following Staff dispostion of the pending exemption requests.

! Question j e. Verify that licensee procedures have been or will be developed which j describe the tasks to be performed to effect the shutdown method.

Provide a summary of these procedures outlining operator actions.

Response

l Operating procedures will be developed to effect safe shutdown following a fire in the control room. These procedures will include the alternate operator

actions outlined in Tables 2 and 3. The Tables can be considered a summary of the contents of these procedures.

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Question

f. Verify that the manpower required to perform the shutdown functions using the procedures of "e" as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specifications.

Response

Adequate manpower is available considering the minimum shif t crew compliment to complete the alternate operator actions outlined in Table 2. The fire brigade function requiring five people (Technical Specification requirement) will be supplemented by personnel from Millstone Unit No. I who have been trained for fire fighting at Millstone Unit No. 2.

Question

g. Provide a commitment to perform adequate acceptance tests of the alternative shutdown capability. These tests should verify that: equipment operates from the local control station when the transfer or isolation switch is placed in the " local" position and that the equipment cannot be operated from the control room; and that equipment operates from the control room but cannot be operated at the local control station when the transfer or isolation switch is placed in the " remote" position.

Response

Appropriate acceptance testing will be performed on all modifications installed to facilitate the alternate operator actions identified herein.

Questions

h. Provide Technical Specifications of the surveillance requirements and limiting conditions for operation for that equipment not already covered by existing Technical Specifications. For example, if new isolation and control switches are added to a shutdown system, the existing Technical Specification surveillance requirements should be supplemented to verify l system / equipment functions from the alternate shutdown station at testing i intervals consistent with the guidelines of Regulatory Guide 1.22 and IEEE

338. Credit may be taken for other existing tests using group overlap test l concepts.

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Response

Upon completion of the design and installation of the isolation circuitry for Panel C-21 to enhance local manual operation, NNECO will propose appropriate Technical Specification limiting conditions for operator and surveillance requirements, if warranted.

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Ouestion

i. For new equipment comprising the alternative shutdown capability, verify that the systems available are adequate to perform the necessary shutdown function. The functions required should be based on previous analyses, if possible (e.g., in the FSAR), such as a loss of normal AC power for the alternative capability should be the same or equivalent to that relied on in the above analysis.

Response

The systems and equipment utilized to achieve safe shutdown following a fire in either the main control board or any fully enclosed auxiliary panel are those systems and equipment normally used for plant operation. NNECO is proposing only to control the systems and equipment from a location remote from the control room. The only change is the delay in obtaining control of Safe Shutdown components from remote locations as compared to the lesser time required when control is accomplished in the control room. The acceptability of these time intervals was demonstrated in Reference (2). As such, the systems are adequate to perform the intended functions.

Plant modifications necessary to achieve safe shutdown after a fire in the control board (s) will adhere to all appropriate design criteria and standards for such changes as discussed in response to Question d.

Question

j. Verify that repair procedures for cold shutdown systems are developed and material for repairs is maintained on site. Provide a summary of these procedures and a list of material needed for repairs.

Response

Alternate operator actions to achieve co'd shutdown following a fire in the main control board or the auxiliary control panels are delineated in Table 3.

Procedures will be prepared describing repairs to cold shutdown related equipment and dedicated materials will be maintained on site. A list of materials required for repair of certain cold shutdown equipment is provided in Reference (2).

TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION COI CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS P42A LOW PRESSURE RUNNING LOSS OF PUMP IF TRIP PUMD AT BREAKER SAFETY IN3ECTION MINI-FLOW RECIRCU-P42B PUMPS, SHUTDOWN LATION NOT OPEN COOLING PUMPS NOT RUNNING NONE l

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TABLEI EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION CO2 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS CONTROL FOR PUMPS PI8A CHEMICAL / VOLUME RUNNING NONE OPERATE PUMP FROM P18B CONTROL SYSTEM-P18C PANEL C-21 BIN FIRE CHARGING PUMPS NOT RUNNING LOSS OF CHARGING AREA T-5.

FLOW CONTROL CIRCUITS CHEMICAL / VOLUME OPEN NONE FOR VALVES: CONTROL SYSTEM-2-CH-518 CHARGING FLOW CLOSED LOSS OF CHARGING OPEN CONTROL CIRCUITRY 2-CH-519 PATH FLOW FOR VALVES 2-CH-518,519 2-CH-429 OR DEENERGIZE CONTROL CIRCUIT AT D.C.

DISTRIBUTION PANEL.

OPEN VALVE CH-429 LOCALLY WITH HANDWHEEL.

CONTROL CIRCUITS CHEMICAL / VOLUME CLOSED NONE FOR VALVES: CONTROL SYSTEM 2-CH-515 LETDOWN FLOW OPEN LOSS OF RCS MANUALLY CLOSE 2-CH-516 PATH LEVEL VALVE 2-CH-089 CONTROL CIRCUIT PRESSURIZER CLOSED NONE FOR VALVE AUXILIARY SPRAY 2-CH-517 OPEN DECREASE IN RCS CLOSE VALVE BY OPENING PRESSURE CONTROL CIRCUIT OR DEENERGIZE CONTROL CIRCUIT AT D.C.

DISTRIBUTION PANEL.

TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (M.CB)

SECTION C03 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS j

PRESSURIZER RCS PRESSURIZER HEATERS OFF NONE PRESSURE AND LEVEL CONTROL HEATERS ON INCREASE IN TRIP PRESSURIZER I RCS FRESSURE HEATERS AT BREAKERS LOSS OF LEVEL MODULATE CHARGING CONTROL PUMP FLOW AT PANEL C-21B CONTROL FOR RCS/ PRESSURIZER CLOSED NONE VALVES SPRAY VALVES 2-RC-100E OPEN DECREASE IN RCS TRIP RCP's IF 2-RC-100F PRESSURE IF RCP's RUNNING OR TAKE RUNNING MANUAL CONTROL AT PANEL C-21B CONTROL FOR RCS/ HEAD VENT CLOSED NONE VALVES: VALVES AND 2-RC-414 PRESSURIZER VENT OPEN LOSS OF COOLANT VALVES ARE DEENERGIZED 2-RC-415 VALVES DURING NORMAL OPERA-2-RC-416 TIONS WITH FUSES PULLED 2-RC-417 2-RC-422 2-RC-423 2-RC-424 2-RC-425 CCNTROL FOR RCS/ PRESSURIZER CLOSED NONE OPEN D.C. BREAKER TO VALVES: POWER OPERATED OPEN DECREASE IN RCS ENSURE VALVES ARE 2-RC-402 RELIEF VALVES PRESSURE CLOSED 2-RC-404

TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION C04 l CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS REACTOR TRIP CONTROL RODS RODS IN NONE PUSH BUTTONS RODS OUT NO REACTOR MANUALLY OPEN TRIP BREAKERS TCB-1 THRU TCB-3 IN FIRE AREA A-35 MAKEUP FLOW CHEMICAL / VOLUME BORATE NONE BORATION CONTROL CONTROL SYSTEM AS IS NONE CIRCUIT DILUTE DECREASE IN MANUALLY CLOSE SHUTDOWN VALVES:

MARGIN 2-CH-512 2-CH-196 MANUALLY OPEN VALVES:

CH-508 CH-509 i

TABLEI EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION C05 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS CONTROL OF FEED MAIN FEEDWATER RUNNING OVERFILL OF TRIP PUMPS WATER PUMPS SYSTEM STEAM GENERATORS LOCALLY PIA NOT RUNNING NONE USE AUXILIARY PIB FEED WATER CONTROLS AT PANEL C-21B CONTROL OF AUXILIARY FEED RUNNING POTENTIAL OVERFILL USE STEAM PUMPS WATER SYSTEM / OF STEAM GENERATORS DRIVEN AUXILIARY P9A ELECTRIC DRIVEN NOT RUNNING NONE FEEDWATER PUMP.

P9B PUMPS CONTROL AT PANEL C-21B. TRIP ELECTRIC PUMP P9A AT BREAKER.

CONTROL P9B at C-21B CONTROL FOR AUXILIARY FEED WATER OPEN NONE VALVES: SYSTEM / STEAM CLOSED 2-MS-201 SUPPLY TO AUXILIARY LOSS OF AUXILIARY CONTROL VALVE 2-HV-4188 2-MS-202 FEED PUMP FEEDWATER TURBINE FROM PANEL C-21B 2-HV-4188 OPEN VALVES 2-MS-201 AND 2-MS-202 MANUALLY AT HANDWHEEL.

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TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION C05 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY i

AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS CONTROL FOR AUXILIARY FEED- OPEN ~E VALVES: WATER SYSTEM /

2-FW-43A FEEDWATER FLOW CLOSED LOSS OF AUXILIARY CONTROL VALVE 2-FW-43B 2-FW-43B PATH FEED FLOW FROM PANEL C-21B 2-FW-44 SPEED CONTROL AUXILIARY FEED ., HIGH/ LOW SPEED LOSS OF STEAM CONTROL TURBINE SPEED FOR STEAM DRIVEN WATER SYSTEM / TURBINE AUXILIARY AT PANEL C-21B.

AUXILIARY FEED STEAM DRIVEN PUMP FEEDWATER PUMP PUMP CONTROL FOR VALVES:

2-MS-220A MAIN STEAM / CLOSED NONE 2-MS-220B BLOWDOWN ISOLATION OPEN LOSS OF FEEDWATER REMOVE AIR SUPPLY AT VALVES DEPLETION OF VALVE TO MANUAL LY CLOSE ~

CONDENSATE VALVES CONTROL FOR MAIN STEAM / CLOSED NONE VALVES: MAIN STEAM ISOLATION OPEN UNCONTROLLED CLOSE VALVES BY OPENING 2-MS-64A VALVES COOLDOWN OF RCS D.C. POWER CIRCUIT 2-MS-64B BREAKERS

TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB) i SECTION C05 t

CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS CONTROL FOR VALVES:

1 2-MS-190 A MAIN STEAM / CLOSED NONE 2-MS-190B ATMOSPHERIC STEAM DUMP VALVES OPEN UNCONTROLLED CONTROL VALVE 2-MS-190B COOLDOWN AT PANEL C-21B CLOSE VALVE 2-MS-190A LOCALLY BY REMOVING AIR SUPPLY l

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TABLE 1 EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION C06 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS CONTROL FOR SERVICE WATER / OPEN NONE VALVES: DIESEL HEAT CLOSED LOSS OF COOLING ISOLATE AIR TO VALVE 2-SW-89A EXCHANGER OU'ILET TO DIESEL GENERATORS LOCALLY TO OPEN VALVES 2-SW-89B VALVES CONTROL FOR SERVICE WATER / RUNNING NONE PUMPS: PUMPS P5A NOT RUNNING LOSS OF COOLING START PUMPS AT CIRCUIT PSB TO DIESEL GENERATORS BREAKERS UPON START OF PSC DIESELS

TABLE 1 l

EFFECT ON SAFE SHUTDOWN (TO HOT SHUTDOWN) WITH TOTAL LOSS OF MAIN CONTROL BOARD (MCB)

SECTION C08 CIRCUIT SYSTEM / EQUIPMENT FAILURE MODES EFFECT ON SAFE COMPENSATORY AFFECTED SHUTDOWN ACTION / PLANT MODIFICATIONS l

DIESEL GENERATOR EMERGENCY POWER LNP WITH AUTO NONE l CONTROLS SUPPLY / DIESEL START AND LOAD 15G-12 U GENERATOR CONTROLS SEQUENCING l 15G-13 U AND SEQUENCERS LNP WITH NO NO EMERGENCY 1. ISOLATE DIESEL AUTO START AND POWER CONTROL FROM MCB NO LOAD SEQUENCING AND OPERATE LOCALLY

l TABLEI NOTES

1. ABBREVIATIONS: MCC - MOTOR CONTROL CENTER RCS - REACTOR COOLANT SYSTEM RCP - REACTOR COOLANT PUMP MSIV - MAIN STEAM ISOLATION VALVE LNP - LOSS OF NORMAL POWER

2. A FIRE IN ANY PANEL OTHER THAN THOSE IDENTIFIED IN TABLE 1 HAS BEEN DETERMINED TO HAVE NO IMPACT ON SAFE SHUTDOWN.

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TABLE 2 PRIORITY ALTERNATE SHUTDOWN OPERATOR ACTIONS FIRE IN PANELS COI THRU C08 PLANT TRANSITI COMPENSATORY TIME REQUIRED LOCATION TIME ACTION FOR ACTION NOTES OPERATOR A. FIRE AREA A-28 i MINUTE 1. ISOLATE DIESEL CONTROL NEGLIGIBLE AND A-29 CIRCUlTRY FROM CONTROL ROOM

2. START DIESEL GENERATORS 1 MINUTE

3. OPEN VALVES: 1 MINUTE 2-SW-89A 2-SW-89B

4. VERIFY CHARGING FLOW FIRE AREAS I MINUTE PATH IS OPEN. OPEN VALVES:

A-35 and A-36 2-CH-518 1 MINUTE 2-CH-519 FIRE AREA 1 MINUTE 2-CH-429 0.5 MINUTES A-18 FIRE AREA 0.5 MINUTES 5. PROVIDE PROPER BORATION 1 MINUTE A-14 WITH CONTROL OF VALVES:

2-CH-508 2-CH-509 FIRE AREA CLOSE VALVE: 1 MINUTE A-14 2-CH-512 CLOSE VALVE:

FIRE AREA 1 MINUTE 2-CH-196 1 MINUTE A-9

TABLE 2 PRIORITY ALTERNATE SHUTDOWN OPERATOR ACTIONS FIRE IN PANELS C01 THRU C08 PLANT TRANSITI COMPENSATORY TIME REQUIRED LOCATION TIME ACTION FOR ACTION NOTES i

OPERATOR B. FIRE AREAS 1 MINUTE 1. TRIP LPSI PUMP 1 MINUTE TOTAL TIME FOR T-7, T-8 BREAKERS ALL ACTIONS

2. START SERVICE WATER PUMPS PSA, P5C

3. TRIP AUXILIARY FEEDWATER PUMP P9A.

4. TRIP RCP's IF REQUIRED FIRE AREA 0.5 MINUTES 5. TRIP MAIN FEED PUMPS 0.5 MINUTES T-12 FIRE AREA 1 MINUTE 6. TRIP PRESSURIZER HEATER 0.5 MINUTES A-15, T-4 BREAKERS FIRE AREA 1 MINUTE 7. ISOLATE PRESSURIZER 0.5 MINUTES A-35, A-36 or A-42 AUXILIARY SPRAY-VALVE 2-CH-517 FIRE AREAS 1 MINUTE 8. OPEN VALVES: 2-MS-201,202 2 MINUTES A-50, A-51 CLOSE VALVE 2-MS-190A FIRE AREA 1 MINUTE 9. ISOLATE LETDOWN FLOW - 0.5 MINUTES A-18 CLOSE VALVE 2-CH-089 FIRE AREA 1 MINUTE 10.CLOSE VALVES 0.5 MINUTES A-17 MS-220 A, B

TABLE 2 PRIORITY ALTERNATE SHUTDOWN OPERATOR ACTIONS FIRE IN PANELS C01 THRU C08 PLANT TRANSITI COMPENSATORY TIME REQUIRED LOCATION TIME ACTION FOR ACTION NOTES OPERATOR C. FIRE AREAS 1 MINUTE 1. OPEN BREAKERS 0.5 MINUTES TOTAL TIME A-35, A-36 TCBI THRU TCB8 FOR ALL ACTION IS

2. OPEN BREAKER NO. 3 0.5 MINUTES IN PANEL NO. D-12, BREAKER NO. 3 IN PANEL TRIPS CONTROL D-22, BREAKER NO.18 RODS AND IN PANEL DV-10 AND CLOSES PORV's BREAKER NO.18 IN AND MSIV's PANEL NO. DV-70.

FIRE AREA 3. ISOLATE B DIVISION SAFE CONTINUOUS T-5 SHUTDOWN CIRCUITS FROM MAIN CONTROL BOARD AND INITIATE SAFE SHUTDOWN ACTIONS FROM PANEL C21B2, CLOSE VALVE 2-FW-44

TABLE 2 NOTES

1. Transit time is that time required to travel between areas. Initiallocation is assumed to be the control room.

2. Controls and instrumentation to be located on Panel C21B include the following:

o Charging pump control o Steam driven and electric driven auxiliary feedwater pumps and associated valves and flow control to SG No. 2 o Atmospheric steam dump valve control for SG No. 2 o Cold leg temperature - loop 2 (SG No. 2) o Pressurizer pressure and level instrumentation o SG pressure and level (SG No. 2) instrumentation o Condensate Storage Tank level instrumentation o Hot Leg temperature - Loop 2 (SG No. 2) to be included

TABLE 3 COLD SHUTDOWN ALTERNATE SHUTDOWN OPERATOR ACTIONS FIRE IN PANELS C01 THRU C08 COMPENSATORY TIME REQUIRED ACTION FOR ACTION

1. OPEN VALVES 2 MINUTES 4

2-SW-3.1 A 2-SW-3.1 B 2-SW-8.1 A 2-SW-8.1 B TO PROVIDE SERVICE WATER TO RBCCW HEAT EXCHANGERS

2. OPEN VALVES: 10 MINUTES 2-RB-211 A THRU 211 F 2-RB-4.1 A THRU 4.1 F i 2-RB-251 A i

2-RB-251 B

! 2-RB-13.1 A 2-RB-13.1 B RBCWW HEADER SUCTION AND DISCHARGE TO SHUTDOWN COOLING HEAT EXCHANGERS

3. START RBCCW 2 MINUTES PUMPS:

P11 A Pil B P11 C

4. CLOSE VALVES: 2 MINUTES 2-SI-662 2-51-663 2-51-659 2-S1-660

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I TABLE 3 COLD SHUTDOWN ALTERNATE SHUTDOWN OPERATOR ACTIONS FIRE IN PANELS Col THRU CO8 COMPENSATORY TIME REQUIRED ACTION FOR ACTION

5. OPEN VALVES: 3 MINUTES 2-SI-615 2-SI-625 2-SI-635 2-SI-645 2-SI-651 2-SI-652 RCS FLOW TO SHUTDOWN COOLING HEAT EXCHANGERS

6. START LPSI PUMPS 2 MINUTES P42A P42B l 7. MODULATE VALVES AS REQUIRED 2-SI-657 2-SI-306 TO CONTROL COOLDOWN RATE AND HEAT REMOVAL

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