An NRC-identified finding of very low safety significance (Green), involving an
NCV of Indian Point Unit 3 Facility Operating License (
FOL) Condition 2.H, was identified because Entergy did not implement and maintain in effect all provisions of the
Fire Protection Program (
FPP), as approved by the NRC. Specifically, Entergy did not have an adequate post-fire operating procedure for its alternative shutdown capability to ensure that
safe shutdown (SSD) equipment analyzed to be available during the postulated fire in fire area ETN-4{2}, Upper Electrical Tunnel, were credited in the procedure. Entergy entered this issue into its corrective action program (
CAP) and promptly implemented compensatory measures by establishing a
fire watch. This finding was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of t he
Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). The team performed a Phase 2
Significance Determination Process screening for this issue, in accordance with NRC
IMC 0609, Appendix F, Fire Protection
Significance Determination Process. This finding affected the post-fire SSD category because the implementing procedures were adversely affected. The team determined that this finding screened to very low safety significance (Green) based upon task 2.3.5, because no credible fire ignition source scenarios were identified in fire area ETN-4{2} that could affect both electrical channels I and II cables. This finding did not have a cross-cutting aspects because it was a legacy issue and was considered to not be indicative of current licensee performance.
