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Audit Question Processing Form (For Staff use only)
AQ-72 Question Initiated By: Schin, Bob Date: 7/21/2003 Regulatory Basis for Question:
Question:
How much time (in minutes) does it take to perform the fire protection procedural step of removing the sliding links? The time should be measured from the receipt of the fire detection alarm in Fire Area 2104.
Response
Actuation of all 11 SRVs due to fire induced spurious actuation of the non-safety electrical backup to the mechanical relief function is not part of the current licensing basis of Plant Hatch because it results from multiple hot shorts (2).
However, step 9.3.2.1 to open links to prevent the SRVs from opening in the unlikely event of multiple hot shorts occurring (or terminate SRV actuation should the SRVs already have opened) was added to the fire procedure 34AB-X43-001-2 as a prudent additional action, in spite of the fact that the assumption of multiple hot shorts is not part of the Plant Hatch current licensing basis.
Since spurious actuation of all 11 SRN's due to multiple hot shorts is not considered probable and is not part of the Plant Hatch current licensing basis, the referenced procedural step to open links is not a step that is trained on in a manner to assure that it can be performed within a certain prescribed time (it is not considered a time critical action). Therefore, SNC cannot provide a bounding time to perform the referenced procedural step (as measured from the receipt of the fire detection alarm in Fire Area 2104) that captures with high confidence the time period it would likely take operators to complete the action.
Selected training and operations personnel have reviewed the subject procedure and the actions required to reach and complete step 9.3.2.1 in the event of a fire in Fire-Area 2104,-and provided an estimated time-of minutes. However, the individual circumstances associated with an event could cause that time interval to be longer or shorter. Again, please note that operators are not trained to perform this step within a certain prescribed period of time.
(For Staff use only)
Response by: Tully, Cindy Reviewed by: Luker, Ira Staff init:
I NRC Status: In Progress 5