Text

Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit 3
	ML101320263
Person / Time
Site:	Indian Point
Issue date:	05/04/2010
From:	Joseph E Pollock; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-10-043, TAC ME0799
	Download: ML101320263 (106)
	v • d • e

{{#Wiki_filter:Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President NL-10-043 May 4, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799) Indian Point Unit No. 3 Docket No. 50-286 License No. DPR-64

References:

1. NRC letter dated January 20, 2010, "Indian Point Nuclear Generating Unit Nos. 2 and 3 - Request for Additional Information Regarding Request for Exemption (TAC Nos. ME0798 and ME0799)

2. Entergy letter NL-09-117, "Revision to Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated October 1, 2009

3. Entergy letter NL-09-032, "Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated March 6, 2009

Dear Sir or Madam:

By letter dated March 6, 2009 (Reference 3), Entergy Nuclear Operations, Inc, (Entergy) requested exemptions from the requirements of 10 CFR 50, Appendix R in accordance with the guidance contained in NRC Regulatory Issue Summary 2006-010 (Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions), and in accordance with 10 CFR 50.12, "Specific exemptions." A revision to the exemption request was submitted by letter dated October 1, 2009 (Reference 2). The purpose of this letter is to provide responses to the Request for Additional Information contained in letter dated January 20, 2010 (Reference 1). Note that Reference 1 indicated that a

NL-10-043 Page 2 of 2 response would be provided within 60 days - this was changed to 104 days in discussions with the Senior Project Manager. As explained in the response to RAI-02.1 it has been determined that the operator manual action involving the local operation of Steam Generator Atmospheric Dump Valves does not require an exemption from the requirements of Appendix R, Paragraph III.G.2. This action is performed in the event of a fire in one of four Fire Areas. It has also been determined that only one OMA associated with local operation of one Auxiliary Feedwater Pump requires an exemption from the requirements of Paragraph III.G.2. Therefore, two OMAs for local operation of Auxiliary Feedwater equipment in one Fire Area are herein withdrawn from the Request for Exemption. Tables RAI-08.1 -1, RAI-08.1-2, RAI-08.1-4, and RAI-08.1-7 in Attachment 1 reflect those changes. Note that some of the information contained in Tables RAI-08.1-1 through RAI-08.1-8 of differs from the information previously provided in Tables 2 though 8 in of References 2 and 3, and notes in the tables explain those differences. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, IPEC Licensing Manager at (914) 734-6710. Sincerely, JEP/gd

Attachment:

1. Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point Energy Center Mr. Paul Eddy, New York State Department of Public Service Mr. Robert Callender, Vice President NYSERDA

ATTACHMENT 1 Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions ENTERGY NUCLEAR OPERATIONS, INC. Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-10-043 Docket No. 50-286 Attachment 1 Page 1 of 103 Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph IIl.G.2 for Use of Operator Manual Actions RAI-01.1 Provide a discussion of how the proposed arrangement achieves the underlying purpose of the rule.

RESPONSE

The underlying purpose of 10 CFR 50, Appendix R is to provide reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a single postulated fire in any plant area. Circuits which could cause maloperation or prevent the operation of redundant trains for post-fire safe-shutdown (SSD) and which are located in the same fire area must be protected in accordance with Paragraph III.G.2 of Appendix R. The intent of Paragraph III.G.2 is to ensure that one SSD equipment train remains "free of fire damage," and several alternatives are provided to establish a level of protection that provides reasonable assurance that one SSD equipment train will remain "free of fire damage." If such protection is not provided, then Paragraph III.G.2 specifies that alternative or dedicated shutdown capability be provided or an exemption from Paragraph III.G.2 be granted. For the fire areas for which this exemption is requested (Fire Areas AFW-6, PAB-2, ETN-4, TBL-5, and YARD-7), the plant's fire protection licensing basis indicates that Indian Point Unit No. 3 (IP3) is committed to compliance with Paragraph III.G.2. The explicit requirements of Paragraph III.G.2 mandate that (using one of the options given by III.G.2) the redundant trains should be adequately separated and protected, such that in the event of a fire in that area, at least one train will remain free of fire damage, and therefore operator manual actions (OMAs) for mitigation or recovery should not be required. However, as contained in the IP3 Appendix R Safe-Shutdown Analysis, in the event of a fire in one of the fire areas that are the subject of this exemption request, certain local OMAs are credited to prevent or mitigate certain undesirable equipment operations that may occur due to fire damage to cables or components located in that fire area. In each case, the OMAs described are taken in another area (outside the area affected by the fire) or, in certain cases, are implemented in the affected fire area, after 60 minutes have elapsed, to conservatively ensure that reentry to the fire-affected area is feasible. The NRC permits exemptions from Paragraph Ill.G.2, as described in Regulatory Information Summary (RIS) 2006-10 (Regulatory Expectations With Appendix R Paragraph lIl.G.2 Operator Manual Actions), via the use of OMAs as long as those actions are feasible and can be reliably implemented. Given that the OMAs can be shown to be performed feasibly and reliably, with the operating resources available, the underlying intent of Paragraph III.G.2 (i.e., of being capable of using one of the redundant SSD equipment trains to achieve and maintain hot shutdown conditions) is met. The required SSD function may be temporarily rendered non-functional due to fire

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 2 of 103 damage, but the OMAs discussed herein are structured to recover the SSD function in a sufficiently timely manner to support the Appendix R performance goals and ensure that hot shutdown conditions are achieved and maintained. The credited OMAs listed in Tables 08.1-1 through 0.8.1-8 have been confirmed to be feasible and reliable operator actions during the post-fire coping scenario. Therefore, since an acceptable alternative to the regulation that has been provided by the NRC has been demonstrated to be acceptable for the OMAs that are the subject of this Request for Exemption, no demonstrable fire/nuclear safety benefit would be gained by the installation of additional modifications to comply with Paragraph III.G.2 in lieu of the crediting of the defined OMAs as credible and reliable means of achieving and maintaining safe-shutdown conditions. Therefore, the underlying purpose of the rule, which is to provide reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a single postulated fire in any plant area, is satisfied and the application of the prescriptive requirements of Paragraph Ill.G.2 in these particular circumstances is not necessary to achieve the underlying purpose of the rule. RAI-02.1 Confirm and state whether an Exemption from III.G.2 requirements is the appropriate request for all of the OMAs (Operator Manual Actions] in the request, since safe shutdown capability is provided independent of the fire area of origin for many of the fire areas.

RESPONSE

General The OMAs for which exemption is requested are credited for use in the event of fire events that require a predominantly Central Control Room (CCR) based shutdown. Certain elements of the safe-shutdown (SSD) capability for each of these areas is independent of the fire area of origin, but not all of the features required to meet the Appendix R SSD performance goals are independent of the area. Hence it was Entergy's understanding at the time of submittal of the Request for Exemption dated March 6, 2009 and the Revision to the Request for Exemption dated October 1, 2009, that an exemption from the literal requirements of Paragraph III.G.2 is necessary to restore Appendix R compliance. Post-fire safe-shutdown is principally accomplished for these areas by remaining in the CCR and conducting a normal (non-alternative) shutdown. In response to RAI-02.1, Entergy has reviewed the initial request for exemption and researched whether several of the OMAs for which exemption was requested in predominantly III.G.2 areas may be properly classifiable as III.G.3 alternative shutdown actions, based on the specific alternative (not redundant) hardware that is utilized by these OMAs. However, the results of this review did not conclusively establish that an exemption from the requirements of Paragraph III.G.2 is not required for these actions.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 3 of 103 As such, a request for exemption from the requirements of Paragraph III.G.2 appears to be necessary for these OMAs, with two exceptions. It has been determined that the OMA involving the operation of the Steam Generator Atmospheric Dump Valves (SGADVs) using local control racks does not require an exemption from the requirements of Paragraph III.G.2 to allow the continued crediting of this action. The SGADVs have two functional/operational requirements in the IP3 safe-shutdown model: (1) they are required to be closed during hot shutdown to minimize Steam Generator inventory loss, and (2) they are required to be operable, at slightly over 4 hours into the scenario, to commence a controlled cooldown to permit reaching Residual Heat Removal shutdown cooling mode entry conditions. As such, the active function of the SGADVs is a cooldown/transition action, and not an action required to support achieving and maintaining hot shutdown conditions. Per the guidance of SECY 08-0093 dated June 30, 2008 (Resolution of Issues Related to Fire-Induced Circuit Failures), the passive hot shutdown function of the SGADVs is that of "components important to safety that could adversely affect safe shutdown," and therefore exemption from the literal requirements of Appendix R Paragraph III.G.2 is not required to maintain compliance. Accordingly, the OMA to locally operate the SGADVs is withdrawn from the Request for Exemption as applicable to Fire Areas AFW-6, ETN-4{1}, ETN-4{4}, and TBL-5. This change is reflected in the data tables presented herein. For Fire Area AFW-6, Entergy has revisited the Request for Exemption dated August 16, 1984 and the SER dated January 7, 1987 granted for this area, and has determined that the only OMA requiring a request for exemption under the purview of RIS 2006-10 is that for locally operating the circuit breaker for 33 Auxiliary Feedwater (AFW) Pump. The principal single-point vulnerability of the redundant AFW trains is the common pump control panel in the south end of the room. A fire involving this panel could render all AFW pumps inoperable due to to control circuit failure caused by fire effects, but as noted in the referenced SER and listed on Table RAI-08.1-1, the ability to locally close the circuit breaker (in Fire Area CTL-3) provides a means to remotely start one of the motor-driven AFW pumps. As the intent of the January 7, 1987 SER is understood by Entergy, the insignificant combustible content of the zone, minimal ignition sources, spatial separation of trains, and the full-area coverage smoke detection and wet-pipe sprinkler systems provide assurance that at least one of the valve trains will remain operable from the CCR, and motor-driven 33 AFW Pump located at the north end of the zone can be expected to remain operable. However, as noted above and in Table RAI-08.1-1, an OMA may be required to manually close the breaker for 33 AFW Pump, if all pump control circuits are damaged by a fire at the south end of the zone. Consequently, post-fire reentry to the AFW pump room would not be required. Accordingly, with reference to the specific OMAs described for Fire Area AFW-6 in the Request for Exemption dated March 6, 2009 and the Revision to the Request for Exemption dated October 1, 2009, the requests for exemption for all OMAs in Fire Area AFW-6, with the exception of the OMA to manually operate the circuit breaker for 33 AFW Pump, are withdrawn.

NL-10-043 Docket No. 50-286 Attachment 1 Page 4 of 103 The specific elements of the safe-shutdown performance goals that necessitate the Request for Exemption in each of the affected fire areas are as follows: Fire Area AFW-6 Area AFW-6 anticipates a predominantly CCR-based shutdown, with the exception of the local OMA required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. Therefore, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to continue crediting this OMA. SSD Performance Goal Impacted:

1. Reactor Coolant Heat Removal OMA to locally start one AFW pump Fire Area ETN-4f 11 Area ETN-4{1} anticipates a predominantly CCR-based shutdown, with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. The designated OMAs are structured to recover an impacted redundant SSD train. While these actions are performed outside of Area ETN-4{1}, they are not considered to constitute alternative safe-shutdown features in the context of Paragraph III.G.3, and hence it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 for the use of the below listed OMAs is appropriate.

SSD Performance Goals Impacted:

1. Support (Electrical Power)

As the availability of offsite power cannot be assured for a fire in this area, OMAs are credited for restoration of 480V buses via use of the Appendix R Diesel Generator. The credited OMAs also include the necessary circuit breaker manipulations.

2. Reactor Coolant Makeup and Reactivity Control Fire-induced cable damage may render the normal and alternate charging pump suction supply valves LCV-1 12C and LCV-1 12B inoperable. An OMA in the PAB is credited to locally close LCV-1 12C and open LCV-1 12B bypass valve 288. In addition, an OMA may be necessary to restore the charging makeup path to the RCS by opening bypass valve 227. OMAs in Fire Area PAB-2{2} and Fire Area TBL-5 may be necessary to align an alternate power source to 31 or 32 Charging Pump.

NL-10-043 Docket No. 50-286 Attachment 1 Page 5 of 103 3, Support (Component Cooling) Fire damage to Component Cooling pump cables may require the use of an OMA to repower the 32 CCW Pump from the alternate power supply, thereby recovering one of the redundant required safe-shutdown trains, or alternatively, to align City Water for cooling of the selected Charging pump. The OMAs, if required, are performed in Fire Areas TBL-5, PAB-2{2}, and/or PAB-2{4}.

4. Support (Service Water)

Damage to power supply cables may require the use of an OMA to periodically manually backwash the strainer associated with the selected Service Water pump.

5. Reactor Coolant Heat Removal Damage to power and/or control cables may require the use of OMAs to locally operate motor-driven 31 AFW Pump or the turbine-driven 32 AFW Pump, along with the associated AFW flow control valve(s) (FCV-405B or D; FCV-406B) and steam supply, isolation, and control valves PCV-1 31 OA, PCV-1 31 OB, PCV-1 139, and HCV-1118.

Fire Area ETN-4{31 Area ETN-4{3} anticipates a predominantly CCR-based shutdown, with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from, a fire in this area may impair one of the credited SSD equipment trains. Since the designated OMAs are structured to recover an impacted redundant SSD train, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 for the use of these OMAs is appropriate. SSD Performance Goal Impacted:

1. Reactor Coolant Heat Removal Damage to power and/or control cables may require the use of OMAs to locally operate turbine-driven 32 AFW Pump, along with the associated AFW flow control valve(s) (FCV-405C or D) and steam supply, isolation, and control valves PCV-1 31 OA, PCV-1 310B, PCV-1 139, and HCV-1 118.

Fire Area PAB-2f3l Area PAB-2{3} anticipates a predominantly CCR-based shutdown, with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. Since the designated OMAs are structured to recover an impacted redundant SSD train, it is Entergy's belief that a

NL-10-043 Docket No. 50-286 Attachment 1 Page 6 of 103 request for an exemption from the requirements of Paragraph III.G.2 for the use of this OMA is appropriate. SSD Performance Goals Impacted:

1. Reactor Coolant Makeup and Reactivity Control Fire-induced cable damage may render the normal and alternate Charging pump suction supply valves LCV-1 12C and LCV-1 12B inoperable. An OMA in the PAB is credited to locally close LCV-1 12C and open LCV-1 12B bypass valve 288.

Fire Area PAB-2{5l Area PAB-2{5} anticipates a predominantly CCR-based shutdown, with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. Since the designated OMAs are structured to recover an impacted redundant SSD train, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 for the Use of these OMAs is appropriate. SSD Performance Goals Impacted:

1. Reactor Coolant Makeup and Reactivity Control OMAs that may be required in response to fire-induced equipment maloperation due to a fire in this area include local closure of the 32 Charging Pump circuit breaker, local operation of the 32 Charging Pump speed control (scoop tube);

aligning alternate Charging pump suction by locally closing LCV-1 12C and opening LCV-1 12B bypass valve 288; and alignment of the Charging makeup path to the RCS by locally opening bypass valve 227. Fire Area TBL-5 Area TBL-5 anticipates a predominantly CCR-based shutdown,with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. Since the designated OMAs are structured to recover an impacted redundant SSD train, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 for the use of these OMAs is appropriate. SSD Performance Goals Impacted:

1. Support (Service Water)

Damage to power and/or control cables may require periodic manual backwash of the strainer associated with the selected Service Water pump.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 7 of 103

2. Reactor Coolant Heat Removal Damage to power and/or control cables may require local manual operation of AFW flow control valve FCV-406A and/or FCV-406B. and operation of the 31 AFW Pump recirculation valve FCV-1 121 bypass valve.

Fire Area YARD-7 Area YARD-7 anticipates a predominantly CCR-based shutdown, with the exception of the local OMAs required to protect/recover the credited SSD train, and is considered a III.G.2 area, in that the specific circuit impacts resulting from a fire in this area may impair one of the credited SSD equipment trains. Since the designated OMAs are structured to recover an impacted redundant SSD train, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 for the use of these OMAs is appropriate. SSD Performance Goal Impacted:

1. Support (Service Water)

Damage to power and/or control cables may require periodic manual backwash of the strainer associated with the selected Service Water pump, in Area YARD-7, and to align alternate power to a Service Water pump, in Fire Area TBL-5. RAI-02.2 State the specific requirements of III.G.2 that are not met for each of the requested OMAs, e.g., a lack of fire barriers, spatial separation, automatic suppression, etc.

RESPONSE

For each of the fire zones where OMAs are requested, the compliance with Paragraph III.G.2 is summarized in Tables RAI-GEN-1 through RAI-GEN-23. For each subject fire zone, the line item "App R III.G.2 Compliance" identifies compliance (Yes or No) for 3-hr Barrier, 20 ft Separation, or one-hour Enclosure. Also, the availability of suppression and/or detection in the fire zone is identified in the line item. RAI-02.3 Provide a summary of the plant-specific features that compensate for the lack of III.G.2-required features, identified in RAI-02.2, for each of the requested OMAs. For example, note any enhanced defense-in-depth measures such as a lack of ignition sources or combustibles, more robust or supplemental detection and suppression systems and other physical or administrative controls.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 8 of 103

RESPONSE

For each of the fire zones where OMAs are requested, Tables RAI-GEN-1 through RAI-GEN-23 provide a summary of plant-specific fire protection features in each fire zone. The tables provide an account of combustible loading (both fixed and transient), ignition sources, detection, suppression, administrative controls, and any additional fire protection features in the fire zone. RAI-02.4 Appendix R establishes the concept of defense-in-depth and III.G.2 requires operators be able to safely and reliably achieve and maintain hot shutdown capability from the control room. Provide a technical explanation that justifies how the proposed methods will result in a level of protection that is commensurate with that intended by IIl.G.2.

RESPONSE

The intent of Paragraph III.G.2 is to ensure that one SSD equipment train remains "free of fire damage," and several alternatives are provided to establish a level of protection that provides reasonable assurance that one SSD equipment train will remain "free of fire damage." As elaborated in the response to Generic Letter 86-10 (Implementation of Fire Protection Requirements), Question 3, which clarifies the definition of "free of fire damage," the intent of the requirements of Paragraphs III.G.2.a, IIl.G.2.b, and IIl.G.2.c is to ensure that at least one of the redundant trains is capable of performing its intended function during and after the postulated fire, as needed. The supporting IP3 thermal-hydraulic analyses demonstrate that the operation of the affected components is not needed during the actual fire, but that timely restoration of the function via appropriate OMAs is adequate to ensure the requisite safe-shutdown capability. The timely recovery of the affected safe-shutdown functions to ensure that the required functions are available in sufficient time to support the Appendix R safe-shutdown performance goals, meets the intent of the train protection requirements of Paragraph III.G.2. Tables RAI-08.1-1 through 08.1-8 describe the required OMAs, the time required to diagnose and perform these actions, and the resultant available time margin, defining the basis for ensuring that at least one SSD train is capable of performing its function, post-fire, as needed. Table RAI-06.1-1 describes the hazards and ignition sources in each of the fire areas and fire zones containing the cables and/or components of concern, and their general proximity and the expected effects of the fire hazards on the SSD cables and components. In each case, the IP3 safe-shutdown analysis and safe-shutdown coping methodology accommodates the expected fire-induced failure of the cables/components of concern, and is structured to ensure the restoration of function in an adequately timely manner. The underlying intent of Paragraph III.G.2 - which is to ensure that at least one SSD equipment train remains functional despite a postulated fire event - is met by virtue of strategic OMAs that are structured to prevent or recover from postulated fire damage to the credited SSD train, serving to ensure the train remains in service or is returned to service in a timely manner, to support achieving and maintaining safe, stable hot

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 9 of 103 shutdown conditions. The requirement of Paragraph III.G.2 to maintain one train free of fire damage is intended to ensure that, despite a fire in an area containing both redundant safe-shutdown equipment trains, one of the redundant SSD equipment trains can be relied upon to perform the necessary safe-shutdown function, without need to rely on alternative shutdown measures. If the credited SSD train is maintained free of fire damage by one of the methodologies presented by Paragraph III.G.2, or if the credited SSD train is successfully restored to functionality by a feasible and reliable OMA method, there is no adverse impact on the required post-fire safe-shutdown capability. The potential fire challenges in each fire area and fire zone containing cables and/or components of concern are described in Table RAI-06.1-1 and Tables RAI-GEN-1 through RAI-GEN-23. Given that the OMAs can be shown to be performed feasibly and reliably, with the operating resources available, the underlying intent of Paragraph III.G.2 (i.e., of being capable of using one of the redundant SSD equipment trains to achieve and maintain hot shutdown conditions) is met. As discussed above, the required SSD function may be temporarily rendered non-functional due to fire damage, but the OMAs discussed herein are structured to recover the SSD function in a sufficiently timely manner to support the Appendix R performance goals and ensure that hot shutdown conditions are achieved and maintained. The benchmark timed procedural evolutions and supporting analyses performed by Entergy have provided confirmation (as discussed herein in the responses to RAI-07.1, RAI-08.1, RAI-08.2, and RAI-09.1) that the credited OMAs can indeed be relied upon to ensure the post-fire functionality of one of the redundant SSD equipment trains. RAI-03.1 Provide a discussion of any other Exemptions or evaluations, including licensee-developed evaluations, e.g., Generic Letter 86-10 evaluations, which impact this request in any way and provide a justification for why such impact should be considered acceptable.

RESPONSE

For each of the fire zones where OMAs are performed, Tables RAI-GEN-1 through RAI-GEN-23 provide a listing of approved exemptions, engineering evaluations (i.e., 86-10 evaluations), and Fire Hazards Evaluations applicable to the fire zone. Line item "App R III.G.2 Exemptions" identifies if an exemption(s) is approved for the fire zone and cites the applicable SER letter granting the approval. Line item "Other Evaluations (i.e., 86-10)" lists applicable engineering evaluations by title and Entergy document number. A summary discussion of the applicable SERs or engineering evaluations is provided below.

NL-10-043 Docket No. 50-286 Attachment 1 Page 10 of 103 Fire Area AFW-6 / Fire Zone 23 SER dated January 7, 1987 approved an exemption from the requirements of Paragraph III.G.2 for the AFW Pump Room (Fire Zone 23) based on low fire hazard, area wide detection, and automatic water suppression. It is anticipated that the installed smoke detectors will provide early warning of fire conditions and initiate rapid fire brigade response before significant damage would occur. If fire were to occur, the automatic sprinkler system would actuate to control the fire, reduce room temperature, and protect shutdown cables and components. Engineering Report IP3-ANAL-FP-01052 (Fire Barrier Analysis: Auxiliary Boiler Feedwater Area AFW-6 to Turbine Building TBL-5) evaluated the non-rated penetrations (an unrated fire door assembly and a non-rated ventilation damper) through the 3-hour fire barrier between the AFW Pump Room (Fire Area AFW-6) and the Turbine Building (Fire Area TBL-5). The report concluded that potential fire propagation between Fire Areas AFW-6 and TBL-5 through the non-rated penetrations is not a credible event due to low fire loading on both sides of the barrier, area wide wet pipe sprinklers, and area wide detection in AFW-6. Therefore, the barrier penetrations provide an acceptable degree of separation between the two fire areas for the hazards present. Engineering Report IP3-ANAL-FP-01048 (Exterior Fire Area Boundary Analysis for the Auxiliary Feedwater Pump Room to Yard Area) evaluated the exterior fire area boundary of the AFW Pump Room (AFW-6). The report concluded that the existing external wall configuration is adequate to prevent the postulated exterior yard fire from impacting the operation of the AFW pumps based on greater than 20 foot separation, limited combustibles, and the automatic sprinkler system in the fire zone. Fire Area ETN-4 / Fire Zone 7A SER dated February 2, 1984 approved an exemption from the requirements of Paragraph III.G.2 for the Electrical Tunnel and Electrical Penetration Area, Fire Zones 7A, 60A, and 73A based on low fire hazard, area wide detection, and automatic water suppression in the fire zones. The installed smoke detectors will provide early warning of fire conditions and rapid fire brigade response before significant damage would occur. If fire were to occur, the automatic sprinkler system would actuate to limit fire damage. Additionally, the spatial separation between shutdown systems of 12 to 40 feet provides reasonable assurance that at least one train of shutdown cabling will remain free of fire damage. SER dated January 7, 1987 approved an exemption from the requirements of Paragraph III.G.2 for the Electrical Tunnel and Electrical Penetration Area, Fire Zones 7A, 60A, 73A, and 74A. The SER affirmed that the exemption approved by the SER of February 2, 1984 was still valid and addressed additional redundant instrument cabling not previously reviewed by the previous SER. As approved by the SER, the exemption was extended to include the Lower Penetration Area (Fire Zone 74A) based on 1-hour fire wrap installed on redundant instrument cabling in the Upper Penetration Area

NL-10-043 Docket No. 50-286 Attachment 1 Page 11 of 103 protecting the cabling until it entered the Lower Penetration Area, and automatic suppression and detection systems installed in the areas. Fire Area ETN-4 / Fire Zones 7A and 60A Engineering Report IP3-ANAL-FP-01053 (Evaluation of Supports Penetrating Barriers between Turbine Building and Cable Spreading Room and between Cable Spreading Room and Electrical Tunnels) evaluated unprotected cable tray supports for cable trays penetrating through the fire rated barrier wall between the Cable Spreading Room and the Electrical Tunnel at elevation 33'-0". The reportconcluded that the potential for the failure of the tray supports is unlikely based on:

The configuration of trays, the location of tray supports and strength of materials utilized.
The automatic suppression capabilities on both sides of the barrier of concern present high reliability that agent discharge will occur and extinguish a potential fire.
The cable characteristics of IP3 cable insulation has previously been accepted by the NRC for exclusion as an intervening combustible.
The actual fuel load due to storage of bulk or transient combustible materials is low. The fuel load is due mainly to actual cable insulation throughout the area.

    " The actuation of automatic detection and/or suppression systems will initiate prompt fire brigade response and manual fire fighting activities.

Engineering Report IP3-ANAL-FP-01 049 (Fire Barrier Analysis: Cable Spreading Room to Electrical Tunnels) evaluated the fire barrier between the Electrical Tunnel (Fire Zones 7A & 60A / Fire Area ETN-4) and the Cable Spreading Room (Fire Zone 11 / Fire Area CTL-3). The evaluation concluded that:

    " Although the wall is not a rated assembly, the existing fire barrier wall will perform its intended function to prevent the spread of fire between the cable spreading room and the common area of the electrical tunnels.

The overall construction of the wall is such that it possesses a high structural stability and a high fire resistance rating.

    " Early warning detection is provided in both the Electrical Tunnel and Cable Spreading Room. The actuation of automatic detection and/or suppression systems will initiate prompt fire brigade response and manual fire fighting activities.

Penetrations through the barrier are sealed to an equivalent 3-hour fire rating.
Fire loading primarily consists of cable insulation. The characteristics of IP3 cable insulation has previously been accepted by the NRC for exclusion as an intervening combustible.

       'The automatic suppression capabilities on both sides of the barrier of concern present high reliability that agent discharge will occur and extinguish a potential fire.

The anticipated fire load due to transient combustible materials is low.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 12 of 103 Engineering Report IP3-ANAL-FP-01325 (Fire Damper Assembly Analysis: Fire Dampers 4 and 9 Separating the Control Building from the Electrical Tunnel and the Turbine Building) evaluated the fire damper assembly between Fire Zone 7A (Fire Area ETN-4) and Fire Zone 35A (Fire Area CTL-3). The evaluation concluded that:

Although the damper assembly exceeds the UL listing for maximum size for multiple panel assemblies, the fire damper assemblies are considered adequate based on the configuration of the fire damper assemblies and the fire protection and prevention measures taken by the plant.
The construction of the damper assemblies is such that they possess high structural stability and integrity.
Postulated fires for either side of the damper assemblies do not present severe exposures to the dampers.

Fire Area PAB-2 / Fire Zones 5. 6. 7. and 21A SER dated January 7, 1987 approved an exemption from the requirements of Paragraph III.G.2 for the Primary Auxiliary Building (PAB), Fire Zones 5, 6, 7, and 21A, based on substantial wall construction, low fire load, and area wide detection. The installed smoke detectors will provide early warning of fire conditions and rapid fire brigade response before significant damage would occur. Fire Area PAB-2 / Fire Zone 27A Engineering Report IP3-ANAL-FP-01047 (Fire Barrier Analysis: Primary Auxiliary Building to Radioactive Machine Shop) evaluated the potential for a fire in the Radioactive Machine Shop (RAMS) Building at elevations 54' and 73' to spread into the PAB at elevations 55' and 73' and affect the operation of safe shutdown equipment. Both the PAB and the RAMS Building are part of Fire Area PAB-2. The report concluded that based upon the minimal fire loading in both the RAMS Building and the PAB in the vicinity of the door, the presence of early warning fire detection, and the location of fire suppression equipment for use by the onsite fire brigade, the spread of fire from the RAMS Building into the PAB is not considered a credible event. Fire Area PAB-2 / Fire Zones 1 and 58A SER dated January 7, 1987 approved an exemption from the requirements of Paragraph III.G.2 for the PAB, Fire Zones 1 and 58A, based on low combustible loading, automatic detection in the area, a partial height noncombustible barrier to protect 33 CCW Pump, and fire wrap to protect the normal power feed for 33 CCW Pump. Fire Area YARD-7 / Fire Zones 22 and 222 SER dated January 7, 1987 approved an exemption from the requirements of Paragraph III.G.2 for the Service Water Pumps (Back-up and Normal) based on large spatial separation between the pump groups (i.e., >100 ft), no significant combustibles or fire hazards between the pump groups, and anticipation that if a fire were to occur, it

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 13 of 103 would be rapidly detected by operations or security personnel initiating a fire brigade response using manual fire fighting equipment in the area. RAI-04.1 Where fire protection features such as detection and suppression systems and fire rated assemblies are installed, describe the technical basis for such installations including the applicable codes, standards, and listings.

RESPONSE

For each of the fire zones where OMAs are performed, Tables RAI-GEN-1 through RAI-GEN-23 provide a listing of the applicable Code of Record for the installed detection or suppression systems. A review of the installed systems was provided to the Staff in the evaluation of IP3 against the requirements of Appendix A to BTP 9.5-1 by letters submitted in 1976 through 1980. NRC SER of March 6, 1979 and the Supplement dated May 2, 1980 subsequently approved the IP3 Fire Protection Program and related systems. RAI-04.2 Provide a technical justification for any deviations from codes, standards and listings by independent testing laboratories in the fire areas that could impact this evaluation.

RESPONSE

Reviews of conformance for the IP3 NFPA Codes of Record have been performed, and deviations, where identified, have been dispositioned within these engineering reports. Where other deviations from other applicable codes, standards, or listings have been identified, these are documented and dispositioned within the IP3 Corrective Action Program. Additional specific deviations have been addressed in individual engineering analyses, as documented on Tables RAI-GEN-1 through RAI-GEN-23. RAI-04.3 Provide a technical justification for any non-rated fire protection assemblies.

RESPONSE

For each of the fire zones where OMAs are performed, non-rated assemblies (i.e., fire barriers) were evaluated to determine if the barriers are adequate for the fire hazards present, thereby meeting the requirements for fire area separation as required by Appendix R. The conclusions and technical basis for each evaluation as applicable to the subject fire zone are summarized below.

NL-10-043 Docket No. 50-286 Attachment 1 Page 14 of 103 Fire Area AFW-6 / Fire Zone 23 Engineering Report IP3-ANAL-FP-01052 evaluated the non-rated penetrations (an unrated fire door assembly and a non-rated ventilation damper) through the 3-hour fire barrier between the AFW Pump Room (Fire Area AFW-6) and the Turbine Building (Fire Area TBL-5). The report concluded that potential fire propagation between Fire Areas AFW-6 and TBL-5 through the non-rated penetrations is not a credible event due to low fire loading on both side of the barrier, area wide wet pipe sprinklers and area wide detection in AFW-6. Therefore, the barrier penetrations provide an acceptable degree of separation between the two fire areas for the hazards present. Engineering Report IP3-ANAL-FP-01 048 evaluated the exterior fire area boundary of the AFW Pump Room (AFW-6). The southwest exterior walls of the AFW Pump Room face toward the Transformer Yard and border the passageway between the AFW room and the Turbine Building. The report concluded that the substantial construction and configuration of the existing external wall, along with greater than 20 foot separation from the fire hazard, limited combustibles, and the automatic sprinkler system in the fire zone, are adequate to prevent the postulated exterior yard fire from impacting the operation of the AFW pumps. Fire Area ETN-4 / Fire Zones 7A and 60A Engineering Report IP3-ANAL-FP-01053 evaluated unprotected cable tray supports for cable trays penetrating through the fire rated barrier wall between the Cable Spreading Room and the Electrical Tunnel at elevation 33'-0". The report concluded that the potential for the failure of the tray supports is unlikely based on:

The configuration of trays, the location of tray supports and strength of materials utilized.
The automatic suppression capabilities on both sides of the barrier of concern present high reliability that agent discharge will occur and extinguish a potential fire.
The fire load consists mainly of cable insulation. The cable characteristics of IP3 cable insulation has previously been accepted by the NRC for exclusion as an intervening combustible.
The anticipated fire load due to transient combustible materials is low.
The actuation of automatic detection and/or suppression systems will initiate prompt fire brigade response and manual fire fighting activities.

Engineering Report IP3-ANAL-FP-01049 evaluated the fire barrier between the Electrical Tunnel (Fire Zones 7A & 60A / Fire Area ETN-4) and the Cable Spreading Room (Fire Zone 11 / Fire Area CTL-3). The evaluation concluded that:

Although the wall is not a rated assembly, the existing fire barrier wall will perform its intended function to prevent the spread of fire between the cable spreading room and the common area of the electrical tunnels.

NL-10-043 Docket No. 50-286 Attachment 1 Page 15 of 103

The overall construction of the wall is such that it possesses a high structural stability and a high fire resistance rating.
Early warning detection is provided in both the Electrical Tunnel and Cable Spreading Room. The actuation of automatic detection and/or suppression systems will initiate prompt fire brigade response and manual fire fighting activities.
Penetrations through the barrier are sealed to an equivalent 3-hour fire rating.
Fire loading primarily consists of cable insulation. The characteristics of IP3 cable insulation has previously been accepted by the NRC for exclusion as an intervening combustible.
The automatic suppression capabilities on both sides of the barrier of concern present high reliability that agent discharge will occur and extinguish a potential fire.
The anticipated fire load due to transient combustible materials is low.

Engineering Report IP3-ANAL-FP-01325 evaluated the fire damper assembly between Fire Zone 7A (Fire Area ETN-4) and Fire Zone 35A (Fire Area CTL-3). The evaluation concluded that:

Although the damper assembly exceeds the UL listing for maximum size for multiple panel assemblies, the fire damper assemblies are considered adequate based on the configuration of the fire damper assemblies and the fire protection and prevention measures taken by the plant.
The construction of the damper assemblies isý such that they possess high structural stability and integrity.
Postulated fires for either side of the damper assemblies do not present severe exposures to the dampers.

Fire Area PAB-2 / Fire Zone 27A Engineering Report IP3-ANAL-FP-01047 evaluated the potential for a fire in the RAMS Building at elevations 54' and 73' to spread into the PAB at elevations 55' and 73' and affect the operation of safe shutdown equipment. Both the PAB and the RAMS Building are part of Fire Area PAB-2. The report concluded that based upon the minimal fire loading in both the RAMS Building and the PAB in the vicinity of the door, the presence of early warning fire detection, and the location of fire suppression equipment for use by the onsite fire brigade, the spread of fire from the RAMS Building into the PAB is not considered a credible event. RAI-05.1 Provide critical details or assumptions regarding the in situ and transient fire hazards that could threaten redundant equipment for each fire area included in the requests. The information may include, but is not limited to:

The number, type, and location of potential ignition sources,

NL-10-043 Docket No. 50-286 Attachment 1 Page 16 of 103

The number and types of equipment that may exhibit high energy arcing faults, and the relationship between this equipment and any secondary combustibles,
The quantity of cables and other secondary combustibles and their relationship to potential ignition sources,
The cable type, e.g., thermoplastic or thermoset. If thermoplastic cables are used, provide a discussion of self-ignited cable fires,
Ratings for cables, e.g., IEEE-383, etc. If not rated, justify why fire spread would be assumed to be slow,

  " Controls on hot work and transient combustibles in the area, and the proximity of secondary combustibles that could be impacted by a transient fire, and

Dimensions of the rooms including ceiling heights.

RESPONSE

The request for additional detail relative to fire hazards in the fire areas of concern is considered to be adequately addressed by the seven discussion points as itemized above. Accordingly, Entergy's response is presented below on a point-by-point basis.

The number, type, and location of potential ignition sources The potential ignition sources in each fire zone of concern within the fire areas identified in the Request for Exemption have been tabulated consistent with the guidance of NUREG/CR-6850(EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities), Task 6. The ignition source information is presented for the fire areas of concern in Tables RAI-GEN-1 through RAI-GEN-23. The relationship of ignition source location to the safe-shutdown features of concern is discussed in Table RAI-06.1-1.
The number and types of equipment that may exhibit high energy arcing faults (HEAFs), and the relationship between this equipment and any secondary combustibles The number and types of equipment that present the potential for HEAFs in each fire zone of concern within the fire areas identified in the Request for Exemption have been identified consistent with the guidance of NUREG/CR-6850, Task 6.

The ignition source information is presented for the fire areas of concern on Tables RAI-GEN-1 through RAI-GEN-23. Note that the potential for HEAFs only exists in Fire Area TBL-5, Fire Zone 37A. The relationship of ignition source location to the safe-shutdown features of concern is discussed in Table RAI-06.1-1.

The quantity of cables and other secondary combustibles and their relationship to potential ignition sources The quantity and character of fixed/in-situ combustibles in each fire zone of concern within the fire areas identified in the Request for Exemption are presented for the fire areas of concern on Tables RAI-GEN-1 through

NL-10-043 Docket No. 50-286 Attachment 1 Page 17 of 103 RAI-GEN-23. Cable in each fire zone is quantified by its British Thermal Unit (BTU) contribution to the fixed combustible loading for that fire zone. Table line item "Cable Insulation Quantity in BTU" lists the specific cable BTU contribution and loading in BTU/sq ft. Fire severity is given in minutes based on an equivalent fire severity of 80,000 BTU/sq ft/hour. The cable type, e.g., thermoplastic or thermoset. If thermoplastic cables are used, provide a discussion of self-ignited cable fires Cable types installed at IP3 during original construction include both thermoplastic and thermoset cables, as described below. Cables installed via subsequent plant modifications and cable replacement/maintenance activities are of thermoset construction, as discussed below. As noted below, one category of original plant cables is of thermoplastic (PVC-insulated) construction, but given the asbestos-glass braid outer jacket construction, the performance of this cable can be expected to more closely approximate that of a thermoset cable construction. Glass braid jacketed cable is marketed for use in factories where molten steel or glass may make contact with the cable, for use in high temperature equipment such as heaters and transformers, and as internal wiring for cooking appliances, typical - Bay Associated High-Temperature Wire and Cable. Cables with glass braid jacket material are also marketed for Appendix R as rated fire cables (i.e., 1-hour, typical - Rockbestos-Surprenant Corp. Firezone CRC Cable, Spec. RSS-5-142). With respect to the significance of self-ignited cable fires involving the thermoplastic-insulated cables, these scenarios are considered to be of low likelihood, based on overcurrent protection provided for power and control circuits, and the current-limited characteristics of instrumentation cables, in addition to the substantial construction of the outer asbestos-glass fiber jacket on these cables. However, based on the consistent use of flame-retardant cables throughout IP3, there is reasonable assurance that any cable tray fire (whether self-ignited or externally initiated) will be limited in scope and severity. Ratings for cables, e.g., IEEE-383, etc. If not rated, justify why fire spread would be assumed to be slow The cable originally specified for low power and control applications for IP3 is described in Design Basis Document IP3-DBD-307 (480V AC Electrical Distribution System), which in turn includes references to United Engineers and Constructors Specification 9321-05-113-7, and WEDCO letter IPP-4620 dated April 3, 1974, which described flame test requirements for original plant cables. Original IP3 plant cable is of flame-retardant construction, predominantly constructed of PVC insulation, with a lead or asbestos-glass braid jacket. The fire retardant properties of the original IP3 cables were demonstrated by the following tests for flame retardance:

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 18 of 103 CON ED Bonfire Test (EO-6068-3) Standard Vertical Flame Test (ASTM-D-470-59T) Five Minute Vertical Flame Test With these types of fire resistant cable, a fire will not propagate along the cable. This characteristic was illustrated by a fire which occurred at Indian Point Unit No. 2 (1P2) - which utilizes original plant cable with the same construction and flame test qualification as IP3- in November 1971 during IP2 plant construction. The fire was of such intensity that building structural steel and electrical equipment were damaged, yet the cable in overhead trays was not damaged beyond the exposure area, nor did it re-ignite after the external sources of combustion had been extinguished. New low power control and instrumentation cable is required to meet similar flame resistance requirements as the original cable, via qualification to IEEE 383 Flame Test requirements, as documented in Design Basis Document IP3-DBD-307. Controls on hot work and transient combustibles in the area, and the proximity of secondary combustibles that could be impacted by a transient fire Hot work in all of the fire areas identified in the Request for Exemption is subject to control of hot work activities in accordance with procedure EN-DC-127 (Control of Hot Work and Ignition Sources). All hot work requires review and approval by a qualified Hot Work Supervisor and/or Fire Protection Engineering, and a hot work permit issued for such activities is not valid for more than 24 hours. If required, the activity may be reevaluated by a Hot Work Supervisor and/or Fire Protection Engineering, and the permit may be extended on a daily basis to a maximum valid duration of 31 days. In summary, hot work activities are strictly controlled, and qualified Hot Work Supervisors and/or Fire Protection Engineering remain cognizant of all active hot work permits. With the exception of Fire Areas TBL-5 and YARD-7, all of the fire areas identified in the Request for Exemption are subject to the Indian Point Energy Center Transient Combustible Control Program, as implemented via procedure EN-DC-161 (Control of Combustibles), and are controlled as "Level 2" combustible control areas. Small quantities of combustibles are permitted in these areas, but unattended combustibles exceeding any of the following quantities require formal prior review and approval by Fire Protection Engineering, with imposition of additional compensatory actions or protective measures, as determined to be required:

100 lbs of fire-retardant treated lumber
25 lbs of loose ordinary combustibles
5 gallons of combustible liquid in an approved container
One pint of flammable liquid in an approved container
One 20-oz flammable aerosol can

NL-10-043 Docket No. 50-286 Attachment 1 Page 19 of 103 With respect to the effects of the proximity of transient combustibles to "secondary combustibles," the guidance of procedure EN-DC-161 includes consideration by Fire Protection Engineering of any structures, systems, and components (SSCs) or other combustible materials in the affected area that could be impacted by the presence and staging of the transient combustibles. Where the performance of a Transient Combustible Evaluation is indicated, these parameters are reviewed, and additional guidance is provided in the Transient Combustible Evaluation, as needed, to protect adjacent combustibles, provide protection for combustibles located within a defined footprint, to constrain the staging location of the transient combustibles, or to specify other measures as deemed appropriate by Fire Protection Engineering. Fire Area TBL-5, consisting of the Turbine Building and certain adjacent fire zones, does not contain safety-related SSCs and is not subject to the explicit transient combustible controls of EN-DC-1 61. However, procedure OAP-01 7 (Plant Surveillance and Operator Rounds) includes inspection guidelines for operator rounds, which include monitoring for general area cleanliness, and for any housekeeping problems that may present a fire or safety concern. Consequently, operator rounds performed each shift provide for the monitoring of Area TBL-5 and other plant areas for accumulations of combustibles that could present an unacceptable fire safety challenge. Similarly, procedure EN-MA-132 (Housekeeping) includes guidance for monitoring general area cleanliness as well as monitoring for accumulations of combustibles. Dimensions of the rooms including ceiling heights Room dimensions (square footage), including ceiling heights, for the fire zones of concern within the fire areas identified in the Request for Exemption are presented in Tables RAI-GEN-1 through RAI-GEN-23. RAI-06.1 Provide a description of the proximity of the redundant train equipment or in situ hazards and the spatial relationship between the redundant trains in the fire area such that if they are damaged, manual actions would be necessary. Note, that this question is distance from the RAI addressing Ignition Sources and Combustible Loading, which is generally focused on the combustibles in an area, whereas, this RAI addresses the specific relationship between ignition sources and combustibles and the redundant trains.

RESPONSE

The Appendix R safe-shutdown analysis (SSA) evaluates the adequacy of train separation on a fire area basis, and where determined to be an appropriate means of protecting or recovering an affected equipment train, the SSA identifies OMAs that can be taken to mitigate a fire-induced failure of both trains. However, with few exceptions (e.g., Fire Area AFW-6), the IP3 fire areas are comprised of a number of fire zones, separated from each other by spatial separation and/or barriers of various types and

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 20 of 103 construction. Table RAI-06.1-1 and supporting Tables RAI-GEN-1 through RAI-GEN-23 are based on the recognition, as established by the IP3 Fire Hazards Analysis, that the fire hazards, mitigating features, and resultant fire effects are fundamentally addressed at the fire zone level. For many fire zones, there is a reasonable expectation that the damage footprint from the credible fire scenario would be confined to the boundaries of the zone of origin, and not involve an all-consuming fire that would engulf all fire zones within a given fire area. To that end, the referenced tables provide a view of the discrete challenges to the cables and/or components necessary to achieve and maintain safe hot shutdown conditions. In most cases, a fire in any given zone would create conditions that could require the invocation of only a small subset of the OMAs that have been credited for the affected fire area, as listed on Tables RAI-08.1-1 through RAI-08.1-8. As such, the operational challenge imposed by any given fire zone scenario can be expected to be less severe than the operator action set tabulated for the overall fire area. This reduced challenge, in turn, is supportive of enhanced feasibility and reliability of the credited OMAs. RAI-06.2 Provide a description of the suppression, detection, and any other systems that are present and capable of mitigating the postulated events for the fire areas included in this request.

RESPONSE

The requested information is summarized In Table RAI-06.1-1 under "Comments."

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 21 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / SSD Feature ProximityFixed Significant to Proximity to Ignition Sources Comments Zone Combustibles AFW-6 / All three AFW pumps, Small quantities of The cable runs and Nonmechanistic ignition of control or instrument cables in the overhead 23 flow control valves, cable in overhead pump motors are the trays would present an immediate impact on redundant AFW trains, as and associated cables trays, with pumps credible ignition the trays contain (in part) control cables serving the AFW flow control and valves at floor sources. Cables valves elevation. The trays serving the AFW The remaining fixed combustibles, consisting of a minute quantity of containing cables pumps and flow lube oil and electrical cabinets, present no credible challenge to the serving the AFW control valves are AFW components in the zone flow control valves located in or adjacent are also located in to overhead trays The smoke detection system provides assurance of early warning of a the overhead area. above the AFW fire condition, enabling brigade response prior to significant fire pumps. development. The automatic wet-pipe sprinkler system provides assurance of effective control of any significant fire that may occur, sharply limiting the scope of any fire damage.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 22 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / Proximity to Proximity to Ignition SSD Feature Significant Fixed Sources Comments Zone Combustibles ETN-4{1} I/ Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 7AS with: 32 CCW pump; combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, AFW flow control in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control South valves FCV-405B, D; in trays. The subject procedure. region of FCV-406B cables, in part, are The flame-retardant characteristics of the cables ensure that any fire Fire Zone located in these would be limited in scope and severity. 7A as trays. described The smoke detection system provides assurance of early warning of a herein fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage. ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 7AN with: 31 AFW Pump; combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, 31 AFW Pump in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control North recirculation valve in trays. The subject procedure. region of FCV- 121; cables, in part, are The flame-retardant characteristics of the cables ensure that any fire Fire Zone AFW flow control located in these would be limited in scope and severity. 7A as valves FCV-405B, D; trays. described FCV-406B; The smoke detection system provides assurance of early warning of a herein 32 Charging Pump fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage.

NL-10-043 Docket No. 50-286 Attachment 1 Page 23 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area S Proximity to Proximity to Ignition Corments SSD Feature Significant Fixed Sources Zone Combustibles ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 60AS with: 32 AFW Pump combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, steam supply valve in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control PCV-1 139, steam in trays. The subject procedure. supply isolation valves cables, in part, are The flame-retardant characteristics of the cables ensure that any fire PCV-1310A, 13101B, located in these would be limited in scope and severity. and speed control trays. valve HCV-1118; 31 The smoke detection system provides assurance of early warning of a Charging Pump; AFW fire condition, enabling brigade response prior to significant fire flow control valves development. The automatic preaction sprinkler system for all cable FCV-405B, D, FCV- trays in the area provides assurance of prompt control of any credible 406B; Charging fire, sharply minimizing the potential area of damage. makeup path valve(s) HCV-142/227; Charging suction path valves LCV-1 12B/C

NL-10-043 Docket No. 50-286 Attachment 1 Page 24 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / Proximity to Proximity to Ignition Zone SSD Feature Significant Fixed Sources Comments Combustibles ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 60AN with: 32 AFW Pump combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, steam supply isolation in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control valves PCV-1310A, in trays. The subject procedure. 131 OB; 38 Service cables, in part, are The flame-retardant characteristics of the cables ensure that any fire Water Pump strainer located in these would be limited in scope and severity trays. The smoke detection system provides assurance of early warning of a fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 25 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proximity to Proximity to Ignition Significant Fixed roximit Comments Zone SSD Feature Combustibles Sources ETN-4{3} / Cables associated The dominant Principal ignition Combustibles other than cables in trays are minimal throughout the 73A with: 32 AFW Pump combustible material sources consist of zone. The credible fire scenario would involve transient combustibles, speed control valve in the zone is cable cable tray runs, which are tightly controlled to "Level 2" limits, per administrative control HCV- 1118; 32 AFW in trays. The subject junction boxes, and procedure, or a fire initiating at the single transformer in the zone. Pump steam supply cables, in part, are electrical cabinets The flame-retardant characteristics of the cables ensure that any fire valve PCV-1 139; 32 located in these distributed throughout would be limited in scope and severity, whether the cables are involved AFW Pump steam trays. the zone, and one dry as primitedary copeuandlseverin the casesare involved isolation valves PCV- transformer, located as primary or secondary combustibles (as in the case of a fire initiated 131OA/B; AFW flow near the north end of at the transformer in the zone) control valves FCV- the zone. The cables The smoke detection system provides assurance of early warning of a 405C, D of concern are fire condition, enabling brigade response prior to significant fire located in or adjacent development. The automatic preaction sprinkler system for all cable to trays that are trays in the area provides assurance of prompt control of any credible above one or more of fire, sharply minimizing the potential area of damage. the junction boxes and electrical cabinets. PAB-2{3} / Cables associated with Cables and valve The only credible There is no clear mechanism for ignition of the lubricating oil contained 6 Charging pump LCV-1 12B are ignition source, the within the pump suction path valves located adjacent to Charging pump The smoke detection system provides assurance of early warning of a LCV-1 12C/B the Charging pump, motor, is located at fire condition, enabling brigade response prior to significant fire containing the midpoint of the develo nt Manual valve 288 is lubricating oil, the zone, while LCV- development

          -also located in this     dominant                112B and cables are zone                     combustible in the     located at the south zone                   end of the zone.

NL-10-043 Docket No. 50-286 Attachment 1 Page 26 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Proximity to Proximity to Ignition Corn Fire SSD Feature Significant Fixed Sourcesments Zone Combustibles PAB-2{5} / Cables associated with Fixed combustibles Ignition sources are The open arrangement of the corridor and spacing between ignition 4A 32 Charging Pump in the zone are three electrical sources, and small inventory of cables, provides reasonable assurance minimal, consisting cabinets, widely that any fire occurring in the zone will be minimal in scope of damage of a small quantity of spaced in the zone, incurred cable in trays, and and one dry-type incidental transformer, located combustibles. in the southeast end Cables associated of the zone. The with 32 Charging cables of concern are Pump are routed in routed above one or the overhead of the more ignition zone. sources. PAB-2{5} / Cables associated with Fixed combustibles Ignition sources are The minimal ignition sources and small inventory of cables provide 18A 32 Charging Pump in the zone are two waste gas reasonable assurance that any fire occurring in the zone will be minimal minimal, consisting compressor motors in scope of damage incurred of a small quantity of and a cable run. The cable in trays, and cables of concern are incidental routed above one or combustibles. more of the ignition Cables associated sources. with 32 Charging Pump are routed in the overhead of the zone.

NL-10-043 Docket No. 50-286 Attachment 1 Page 27 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proximity to SSD Feature Significant Fixed Sources Comments Zone Combustibles PAB-2{5} / Cables associated with Fixed combustibles Ignition sources The minimal ignition sources and small inventory of cables provide 19A 32 Charging Pump in the zone are include a cable run, reasonable assurance that any fire occurring in the zone will be minimal minimal, consisting electrical cabinets, in scope of damage incurred of a small quantity of and transformers cable in trays, and located in the incidental northeast and combustibles. northwest corners of Cables associated the zone. The cables with 32 Charging of concern are routed Pump are routed in above one or more of the overhead of the the ignition sources. zone. PAB-2{5} / Cables associated with The fixed Ignition sources Combustibles other than cables in trays are minimal, throughout the 27A Charging pump combustibles in the consist of several zone. The credible fire scenario would involve transient combustibles, suction path valves zone are minimal, widely spaced which are tightly controlled to "Level 2" limits, per administrative control LCV-1 12B/C consisting principally electrical boxes, a procedure. of RadOperations Opromateials and cable run, and a wnd catleruneat. Te Combustibles in this large zone are widely distributed, presenting and sPpe mandrials cables ofcern are minimal potential for significant involvement, in response to initiation by and supplies, and a cables of concern are a y sn l g ii n s u c nt e z n small quantity of routed in the vicinity any single ignition source in the zone cables in trays of one or more of the ignition sources.

NL-10-043 Docket No. 50-286 Attachment 1 Page 28 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / Proximity to Proximity to Ignition Corments SSD Feature Significant Fixed Sources Zone Combustibles PAB-2{5} / Cables associated with Combustibles in the The sole ignition The minimal ignition sources and small inventory of cables provide 30A Charging pump zone consist of a source is the cable reasonable assurance that any fire occurring in the zone will be minimal suction path valves small quantity of tray run, presenting a in scope of damage incurred LCV-1 12B/C cables in trays and minimal potential for incidental materials, fire initiation The cables of concern are routed in or adjacent to the trays in the zone. PAB-2{5} I Cables associated with Combustibles in the The sole ignition The minimal ignition sources and small inventory of cables provide 58A 32 Charging Pump zone consist of a source is the cable reasonable assurance that any fire occurring in the zone will be minimal small quantity of tray run, presenting a in scope of damage incurred cables in trays and minimal potential for The smoke detection system provides assurance of early warning of a incidental materials, fire initiation fire condition, enabling brigade response prior to significant fire The cables of developm ent concern are routed development in or adjacent to the trays in the zone. PAB-2{5}1 Cables associated with Combustibles in the The ignition sources The minimal ignition sources and small inventory of cables provide 59A Charging makeup path zone consist of a consist of the cable reasonable assurance that any fire occurring in the zone will be minimal valve(s) HCV-142/227 small quantity of tray run and a in scope of damage incurred cables in trays and junction box, The smoke detection system provides assurance of early warning of a incidental materials, presenting a minimal fire condition, enabling brigade response prior to significant fire The cables of potential for fire development concern are routed initiation in or adjacent to the trays in the zone.

NL-10-043 Docket No. 50-286 Attachment 1 Page 29 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / Proximity to Proximity to Ignition FreASSD Feature Significant Fixed Sources Comments Zone Combustibles PAB-2{5} / Cables associated with Combustibles in the The sole ignition The minimal ignition sources and small inventory of cables provide 62A Charging makeup path zone consist of a source is the cable reasonable assurance that any fire occurring in the zone will be minimal valve(s) HCV-142/227 small quantity of tray run, presenting a in scope of damage incurred cables in trays and minimal potential for incidental materials, fire initiation. The cables of concern are routed in or adjacent to the trays in the zone. TBL-5 / Cables associated with Combustibles in the Ignition sources This zone contains 6.9kV switchgear, presenting the potential for a 37A all (31 through 36) zone include cables include cable runs, HEAF concern, if circuit breaker operational failures are postulated Service strainersWater pump in trays, lube oil, electrical cabinets and switchgear, transformers,MCCs, and Fire detection provided in the 6.9kV switchgear area and above an distributed electrical cabinets. tMCC, as well as in battery and charger rooms, provides assurance of throughout the zone. The cables of prompt notification of a developing fire at these locations. The general A flammable liquids concern are in area coverage sprinkler system provides assurance of control of the storage cabinet is proximity to one or likely fire scenario involving transient materials, minimizing the scope located at the south more ignition sources and severity of any fire damage. end of the zone. The in the zone. cables of concern are routed in the overhead, above one or more of the combustible elements in the zone.

NL-10-043 Docket No. 50-286 Attachment 1 Page 30 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proximity to Proximity to Ignition Comments SSD Feature Significant Fixed Sources Zone Combustibles TBL-5 / Cables associated with Combustibles in the Ignition sources The minimal ignition sources and spatial separation of combustibles 38A all (31 through 36, 38) zone include cables include the MCC and provide reasonable assurance that any fire occurring in the zone will be Service Water pump in trays, electrical electrical cabinet, minimal in scope of damage incurred strainers cabinet, MCC, and The cables of The sprinkler system in the chemical storage area and the smoke flammable liquids concern are in detection provided above the MCC located in the zone, provide storage cabinets, proximity to one or reasonable assurance of annunciation and control of any fire distributed dthroughutted more ignition sources zon e zgnitione throughout the zone, in the zone. sourc development at either of these hazards as well as a range of chemicals in the chemical storage area. The cables of concern are routed in the overhead, above one or more of the combustible elements in the zone.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 31 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proximity to Proximity to Ignition Significant Fixed Sources Comments Zone SSD Feature Combustibles TBL-5 / Cables associated with Combustibles in the Ignition sources This zone is provided with a full-area wet-pipe sprinkler system, 43A all (31 through 36, 38) zone include cables include the cable providing assurance of effective control of any fire that may occur in the Service Water pump in trays, electrical runs, switchgear, area. Water flow alarms received in the CCR upon actuation of the strainers cabinets, MCC, MCC, electrical sprinkler system provide effective notification to enable deployment of switchgear, and cabinets, and the fire brigade. Given the broad distribution of combustibles in the flammable liquids transformer, which area, there is reasonable assurance that a fire would be constrained to storage cabinets, are distributed a limited fire damage footprint within the zone. distributed throughout the zone. throughout the zone, The cables of as well as a range of concern are in chemicals in the proximity to one or chemical storage more ignition sources area. The cables of in the zone. concern are routed in the overhead, above one or more of the combustible elements in the zone.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 32 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Proximity to Proximity to Ignition Area / FireZone SSD Feature Significant Fixed Sources Comments Combustibles TBL-5 / Cables associated with Combustibles in the Ignition sources The minimal combustibles in the zone, and the distribution of the 44A all (31 through 36, 38) zone include cables include the cable combustibles and ignition sources throughout the zone, provide Service Water pump in trays, electrical runs, electrical reasonable assurance that a credible fire scenario would be limited in strainers cabinets, one dry- cabinets, and scope and severity of fire damage type transformer, transformer, which and incidental are distributed combustibles. The throughout the zone. cables of concern The cables of are routed in the concern are in overhead, above proximity to one or one or more of the more ignition sources combustible in the zone. elements in the zone. TBL-5 / Cables associated The zone contains Motors on two This area is devoid of significant fixed combustibles, and a substantial 52A with: 31 AFW Pump negligible fixed penetration blowers, fire capable of challenging the integrity of the cables of concern is not recirculation valve combustibles and two electrical considered a credible event FCV-1121; 31 AFW cabinets, represent Pump flow control the ignition sources in valves FCV-406A, B this zone. The ignition sources are located in the south-end of the zone, as are the SSD cables listed as SSD Features.

NL-10-043 Docket No. 50-286 Attachment 1 Page 33 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Proximity to Proximity to Ignition

    /SSD Feature           Significant Fixed Combustibles                Sources                                            Comments Cables associated with   The zone contains       Ignition sources         The minimal combustibles in the zone, and the distribution of the 31 AFW Pump flow         negligible fixed       consist of a cable run,   combustibles and ignition sources throughout the zone, provide control valves FCV-      combustibles           electrical cabinet, and   reasonable assurance that a credible fire scenario would be limited in 406A, B                                         motors on valve           scope and severity of fire damage operators. The cables of concern are proximate to the cable runs.

Cables associated with The service water Ignition sources Fire detection provided in the zone would annunciate any developing (as well as the pumps and strainers consist of several fire condition, enabling fire brigade response for manual suppression of components are segregated from electrical boxes and the fire. The limited ignition sources and combustibles within the zone themselves): 31-36 the significant the SW pump motors do not present a significant fire challenge capable of rendering all SW SW Pump, 31-36 SW combustibles of the themselves pumps inoperable. Pump Strainer zone by a security barrier enclosure. Combustibles within the enclosure are insignificant.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 34 of 103 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proximity to Proximity to Ignition Comments SSD Feature Significant Fixed Sources Zone Combustibles YARD-7 / Cables associated with This zone contains Ignition sources The fire challenge in the zone is insignificant, and any accumulation of 222 38 SW Pump Strainer only small quantities consist of the BU SW transient combustibles that could present a significant fire challenge of cables, consisting Pump and strainer would not concurrently challenge the redundant SW Pumps 31 through of the cables serving motors. A fire ignited 36, located in Zone 22 the backup SW by one of these pump and strainer, components would The required cables simply result in the for BU SW use of one of the Pump/SW System redundant operation are the pump/strainer combustibles in the combinations in the zone. area.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 35 of 103 RAI-07.1 Provide an analysis or technical justification that demonstrates that the ability to detect a fire is sufficient to provide notification of a postulated event before damage to the redundant trains occurs or provide an analysis or technical justification to evaluate scenarios where the redundant components are damaged before a fire has been reported.

RESPONSE

No credit has been taken for immediate and proactive OMA response by plant operators upon the receipt of a fire detection alarm in any of the identified fire areas or fire zones. Rather, the OMA responses are initiated upon the detection of operating abnormalities or failures caused by the postulated fire. The evaluation of the feasibility of the credited OMAs for the fire areas addressed herein was conducted using the presumption that fire damage would occur to the cables/components of concern, and that symptomatic response to mitigate these failures would be required. While a fire was postulated and announced to plant operators at the outset of event simulations, no attempt was made to credit preventive actions; i.e., proactive actions that could be taken immediately upon receipt of a fire alarm. Exercises were conducted using the plant simulator, with a fire condition announced at the outset or a spontaneous reactor trip (caused by the fire) was presented at the outset, followed by the failure of discrete components that are subject to impairment due to fire damage to cables or components resulting from a fire in the area of 'concern. The component failures were selected from the Appendix R Safe-Shutdown Analysis list of component failures for a fire in the selected fire area. Using this evaluation approach, the operating team was observed and as the discrete failures were discovered by the operators the associated time values were recorded. For purposes of the simulator exercises, the plant was assumed to be in Mode 1 (100% power), with no equipment out of service (except for that potentially failed by the postulated fire). The simulator model was modified to impair certain components, prior to starting the exercise. The impairment flags in the simulator model database were applied so as to create no cues or advance warning to the operators that the affected components would be impaired or unavailable. The time values discussed in the response to RAI-08.1 reflect the diagnosis times developed through these exercises. Conversely, the simulated performance of the OMAs, which by definition are actions outside the CCR, was accomplished in a separate set of evolutions, by dispatching operator(s) from the CCR (or where an operator is normally stationed in the Radiologically Controlled Area, dispatched from that location via radio). The operator(s) were dispatched to the OMA locations as directed by procedures, and the total time recorded was the time to travel from the dispatch location, perform the OMA, and communicate to the CCR that the action was completed. The total of simulator-based Time to Diagnose was added to the field-based time to travel to the OMA Location, complete the OMA, and notify the CCR of completion. Note that the time values shown in the Request for Exemption dated March 6, 2009 and in the Revision to the Request for Exemption dated October 1, 2009, were only those associated with the Actual Time

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 36 of 103 to Complete the OMA (travel time + performance time + confirmation/notification time), as shown in Tables RAI-08.1-1 through RAI-08.1-8. Notwithstanding the reasonableness of expectation that a fire in the affected area would be detected and annunciated in the CCR well in advance of the occurrence of substantive cable/component damage, the OMA evaluation approach in all cases presumed that the postulated fire damage did in fact occur, and therefore the implementation of the OMA was required in all cases. No credit was taken for anticipation of the various component failures as the result of early warning fire detection alarms. Instead, the discrete failures were imposed by the simulator on the operating team, and they were challenged to diagnose the failure, determine the appropriate response, and dispatch operators as applicable to perform OMAs in the field to mitigate the equipment maloperation. RAI-08.1 For each of the OMAs contained in the requests, describe the circumstances and criteria needed to enter the OMA procedure and identify:

1) Diagnosis time - the time required for an operator to examine and evaluate data to determine the need for, and to make the decision to implement, an action.

2) Implementation time - the time required by the operator(s) to successfully perform the action including:

    " Obtaining any necessary equipment, procedures, or other devices,
    " Traveling to the necessary location,

Implementing the action, and
Confirming that the action has had its desired effect

RESPONSE

The actions required to implement the subject OMAs are detailed in Tables 2 through 9 of to Entergy letter NL-09-032, dated March 6, 2009 and Entergy letter NL-09-117, dated October 1, 2009. The details of the time required to diagnose each of the failure scenarios requiring the use of the subject OMAs, as well as the time required to implement the OMAs, are herein provided in Tables RAI-08.1-1 through RAI-08.1-8. For each OMA sequence, the Required Time to Complete and the Total Time to Complete are provided, along with the Resultant Margin available for each OMA. Note that in revisiting the timed validation data sets in developing the response to RAI-08.1, it was determined that in several cases the OMA-specific timing data as presented in the Request for Exemption dated March 6, 2009 and in the Revision dated October 1, 2009, required revision to accurately reflect the components of the timing elements and the overall completion times. In addition, the OMA descriptive text has been clarified in several cases from that shown in the referenced submittals. None of these changes impact Entergy's conclusions relative to the feasibility or reliability of the subject OMAs.

NL-10-043 Docket No. 50-286 Attachment 1 Page 37 of 103 Also shown in Tables RAI-08.1-1 through RAI-08.1-8 are the fire area and fire zone(s) that contain cables and/or components presenting the fire vulnerability that may initiate the need to implement the credited OMA, along with the fire area and fire zone(s) in which the OMA is performed. For the few cases in which reentry to the fire-affected area is credited, the constraints of such reentry are described. RAI-08.2 Provide a justification that demonstrates that the proposed OMAs are feasible as well as a technical justification for the times discussed in the response to RAI-08.01 above.

RESPONSE

The credited OMAs have been demonstrated to be feasible through timed evolutions performed using a combination of simulator drills and dispatch of operators to (simulate) performance of the OMAs within the physical plant. In all cases, as shown by Tables RAI-08.1-1 through RAI-08.1-8, the OMAs are completed, with available margin, within the time constraints established by the supporting safe-shutdown thermal-hydraulic analyses. The time values presented in Tables RAI-08.1-1 through RAI-08.1-8 have been shown to be consistently achievable, and the Operations resource demand to support any one of the fire area scenarios is a fraction of the 7-operator complement available to support a post-fire safe-shutdown scenario. Note that the time to diagnose and the resultant total time to complete OMAs were not shown in the Request for Exemption dated March 6, 2009 or in the Revision to the Request for Exemption dated October 1,2009. Tables RAI-08.1-1 through RAI-080.1-8 expand on the timing information presented in the March 6, 2009 and October 1, 2009 submittals. The accomplishment of the small OMA subsets for any of the III.G.2 fire areas for which exemption is sought is fully bounded by the limiting III.G.3 fire scenario, e.g., a Control Building fire. In the case of a III.G.3 scenario, involving CCR evacuation, the guidance of procedure 3-AOP-SSD-1 (Control Room Inaccessibility Safe Shutdown Control) applies, and the ability to accomplish the key time-sensitive action sets in 3-AOP-SSD-1 has been demonstrated repeatedly.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 38 of 103 TABLE RAI-08.1-1 FIRE AREA AFW-6 CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Actual Time Total Time to OMA Time to Time to to Complete and Fire Area/Zonea Comments Required OMA Complete Diagnose Complete Resultant Need for OMA 3 Margin4 OMA Performance (P) OMA 2 Fire Area/Zoneb Locally start 33 AFW 30 m 4.5 m 13 m TTC: 17.5 m I: Area AFW-6, Zone 23 Target: 33 AFW Pump control Pump from breaker on (a) cables Bus 6A Margin: 12.5 m; P: Area CTL-3, Zone 14 41% Locally operate valves - - WITHDRAWN FCV-1 123, FCV-406C, See response to RAI-02.1 FCV-406D (a) The Total Time to Complete is revised to 13 minutes, whereas the previous submittals showed a value of 7 minutes for the Actual Time to Complete These notes apply to Tables RAI-08.1-1 through RAI-08.1- 8:

1. Represents the available time to complete the action to ensure fulfillment of the Appendix R performance goals

2. Elapsed time from start of announced fire event for operators in simulator environment to detect failure

3. Actual Time to Complete = travel time + time to execute OMA + time to report completion/validate action

4. Total Time to Complete (TTC) = Actual Time to Diagnose Need for OMA + Actual Time to Complete OMA Resultant Margin = 100 x (Required Time to Complete - TTC) / Required Time to Complete

5. Fire Area/Zone in which the postulated fire may cause cable or component damage resulting in the need for the OMA to recover the required SSD function

6. Fire Area/Zone in which the OMA is actually performed

NL-10-043 Docket No. 50-286 Attachment 1 Page 39 of 103 TABLE RAI-08.1-1 FIRE AREA AFW-6 CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Actual Time Total Time to OMA (1) Initiator Required OMA Time to Time to to Complete and Fire Area/Zones Comments Complete Diagnose Complete Resultant Need for OMA 3 Margin 4 OMA Performance P OMAý Fire Area/Zone Locally operate PCV- WITHDRAWN 1139, PCV-1310A, PCV- See response to RAI-02.1 1310B, HCV-1118, FCV-405C or FCV-405D (if 32 AFW Pump is used) Locally operate Steam WITHDRAWN Generator Atmospheric See response to RAI-02.1 Dump Valve (SGADV) PCV-1 134, PCV-1 135, PCV-1136, or PCV-1137

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 40 of 103 TABLE RAI-08.1-2 FIRE AREA ETN-4{1} CREDITED III.G.2 OPERATOR MANUAL ACTIONS ctual AOMA Required Time to to Total Time to Initiator (I) Required OMA Time to Diagnose Complete Complete and Fire Area/Zone Comments Complete Need for OMA Resultant Margin OMA Performance (P) OMA Fire Area/Zone Swap 32 CCW Pump to > 1 hour <1 m 34 m TTC: 35 m I:Area ETN-4{1}, Zone 7AS Target: 32 CCW Pump cables alternate power supply (b) OR align city water to Margin: >25 m; P: Area TBL-5, Zone 37A Charging pumps >42% and Area PAB 2{2}, Zone 1; OR Area PAB-2{4}, Zone 17A Operate 480V Bus 3A 30 m 4.5 m 7m TTC: 11.5 m I: Area ETN-4{1 }, Zone Target: 31 AFW Pump control breaker locally to start 31 7AN cable AFW Pump Margin: 18.5 m; 61% P: Area CTL-3, Zone 11 Locally operate FCV- 30 m 4.5 m 8m TTC: 12.5 m I: Area ETN-4{1}, Zone Target: FCV-1121 control cable 1121 in support of use of 7AN 31 AFW Pump, OR Margin: 17.5 m; 58% P: Area AFW-6, Zone 23 Operate HCV-1118 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1}, Zone Target: HCV-1118 control cable manually to control 32 60AS AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 (b) The Total Time to Complete is revised to 34 minutes, whereas the previous submittals showed a value of 10 minutes for the Actual Time to Complete

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 41 of 103 TABLE RAI-08.1-2 FIRE AREA ETN-4{1} CREDITED III.G.2 OPERATOR MANUAL ACTIONS ctual AOMA Required Time to to Total Time to Initiator (I) Required OMA Time to Diagnose Complete Complete and Fire Area/Zone Comments Complete Need for OMA Resultant Margin OMA Performance (P) OMA Fire Area/Zone Align Appendix R Diesel 75 m <1 m 50 m TTC: <51 m I: Area ETN-4{1} Nonmechanistic Loss of Offsite Generator (ARDG) to Power can be postulated at outset 480V Buses 2A, 3A, 5A, Margin: 24 m; P: Area TBL-5, Zone 37A; of scenario, effectively eliminating and 312 (c) 32% Area YARD-7, Zones 131, diagnosis time 131A; Area CTL-3, Zone 11 Swap 31 or 32 Charging 75 m 30 m 8m TTC: 38 m I: Area ETN-4{1}, Zone Target: 31 and 32 Charging Pump Pump to alternate power 7AN, 60AS cables supply Margin: 37 m; 49% P: Area PAB-2-{3} Start ARDG and align - Not a separate OMA power to 480V Buses 2A, 3A, 5A, and 312 (d) Locally operate FCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1 }, Zone Target: FCV-406A-D, FCV-405A-D 405B, FCV-405D, or 7AN, 7AS, 60AS control cables FCV-406B to control Margin: 12.5 m; AFW flow to Steam 37% P: Area AFW-6, Zone 23 Generators (c) Buses 3A and 312 were inadvertently omitted in previous submittals (d) This was a separate OMA in previous submittals but is herein correctly included in the OMA to "Align Appendix R Diesel Generator..."

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 42 of 103 TABLE RAI-08.1-2 FIRE AREA ETN-4{1} CREDITED III.G.2 OPERATOR MANUAL ACTIONS Actual Actual Time OMA Required Time to to Total Time to Initiator (I) Required OMA Time to Diagnose Complete Complete and Fire Area/Zone Comments Complete Need for OMA Resultant Margin OMA Performance (P) OMA Fire Area/Zone Locally open valve 227 to 75 m 30 m 9 m TTC: 39 m I:Area ETN-4{1}, Zone Targets: Cables associated with establish Charging 60AS HCV-142 [previously "CVCS"] Margin: 36 m; makeup flowpath to RCS) 48% P: Area PAB-2{5}, Zone Travel time conservatively taken to 62A be 10 minutes, from CCR to PAB. Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. Locally close valve LCV- 75 m 30 m 11 m TTC: 41 m I: Area ETN-4{1 1, Zone Targets: cables associated with 11 2C; open valve 288 to 60AS valves LCV-1 12B, LCV-1 12C align Charging pump Margin: 34 m; suction to the RWST 45% P: Area PAB-2{3}, Zone 6 Travel time conservatively taken to and Area PAB-2{5}, Zone be 10 minutes, from CCR to PAB. 30A Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. Locally control SGADVs WITHDRAWN PCV-1 135, PCV-1 136 See response to RAI-02.1

NL-10-043 Docket No. 50-286 Attachment 1 Page 43 of 103 TABLE RAI-08.1-2 FIRE AREA ETN-4{1} CREDITED III.G.2 OPERATOR MANUAL ACTIONS Actual Actual Actual Time OMAM Required Time to to Total Time to Initiator (I) Required OMA Time to Diagnose Complete Complete and Fire Area/Zone Comments Complete Need for OMA Resultant Margin OMA Performance (P) OMA Fire Area/Zone Locally operate PCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1}, Zone Target: PCV-1139 control cables 1139 to ensure steam 60AS supply to 32 AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1 }, Zone Target: PCV-1 31 OA, B control 1310A, 1310B to ensure 60AS cables steam supply to 32 AFW Margin: 8.5 m; Pump 28% P: Area TBL-5, Zones 52A and 57A Locally manually perform > 1 hour > 1 hour 15 m TTC: See I: Area ETN-4{1}, Zone The need for periodic manual Service Water (SW) Comments 60AN backwash of the selected SW pump strainer backwash strainer is variable, depending on as required Margin: See P: Area YARD-7, Zone 222 ultimate heat sink conditions and Comments other factors. The Time to Diagnose shown is a nominal figure, and therefore TTC and Margin are not considered critical parameters for this occasional (as-needed) OMA.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 44 of 103 TABLE RAI-08.1-3 FIRE AREA ETN-4{3} CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments R dmeto Need for OMA Resultant OMA Performance Complete OMA Margin (Pl Fire Area/Zone Operate HCV-1118 30 m 4.5 m 17 m TTC: 21.5 rn I: Area ETN-4{3}, Zone Target: HCV-1118 control cables manually to control 32 73A AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{3}, Zone Target PCV-1139 control cables 1139 to ensure steam 73A supply to 32 AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{3}, Zone Target: PCV-1310A, B control 1310A, PCV-1310B to 73A cables ensure steam supply to Margin: 8.5 m; 32 AFW Pump 28% P: Area TBL-5, Zones 52A and 57A Locally operate FCV- 30 m 4.5 m 17 m TTC: 21.5 m 1:Area ETN-4{31, Zone Target: FCV-405 control cables 405C, 405D to control 73A AFW flow to SG Margin: 8.5 m; 28% P: Area AFW-6, Zone 23

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 45 of 103 TABLE RAI-08.1-4 FIRE AREA ETN-4{4} CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments R dmeto Need for o Resultant OMA Performance Complete OMA OMA Margin (21 Fire Area/Zone Locally operate SGADV WITHDRAWN PCV-1 134, PCV-1 135, See response to RAI-02.1 PCV-1 136, or PCV-1 137 to support cooldown to RHR entry conditions

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 46 of 103 TABLE RAI-08.1-5 FIRE AREA PAB-2{3} CREDITED Ill.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time Actual Time Total Time to Initiator (I) Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments OMA RequiredNeed for Resultant OMA Performance Complete OMA OMA Margin (P) Fire Area/Zone Locally close valve LCV- 75 m 30 m 11 m TTC: 41 m I: Area PAB-2{3}, Zone Targets: cables associated with 112C and open valve 288 6 valves LCV-112B, LCV-112C to align Charging pump Margin: 34 m; suction path to Refueling 45% P: Area PAB-2{3}, Travel time conservatively taken to Water Storage Tank Zone 6 and Area PAB- be 10 minutes, from CCR to PAB. (RWST) 2{5}, Zone 30A Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

NL-10-043 Docket No. 50-286 Attachment 1 Page 47 of 103 TABLE RAI-08.1-6 FIRE AREA PAB-2{5} CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments Need for o Resultant OMA Performance Complete OMA OMA Margin (P) Fire Area/Zone Locally close supply 75 m 30 m 7m TTC: 37 m I: Area PAB-2{5}, Zone Target: 32 Charging Pump control breaker for 32 Charging 4A, 18A, 19A, 58A cables [previously "CVCS"] Margin: 38 m; Pump 51% P: Area CTL-3, Zone 11 Locally control 32 75 m 30 m 9m TTC: 39 m I: Area PAB-2{5}, Zone Target: 32 Charging Pump control Charging [previously 4A, 18A, 19A, 58A cables "CVCS"] Pump using Margin: 36 m; scoop tube positioner 48% P: Area PAB-2{3}, Zone 6 Open valve 227 to 75 m 30 m 9m TTC: 39 m I: Area PAB-2{5}, Zone Targets: Cables associated with establish Charging 27A, 30A, 59A, 62A valve HCV-142 flowpath to RCS around Margin: 36 m; potentially failed closed 48% P: Area PAB-2{5}, Travel time conservatively taken to HCV-142 Zone 62A be 10 minutes, from CCR to PAB. Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

NL- 10-043 Docket No. 50-286 Attachment 1 Page 48 of 103 TABLE RAI-08.1-6 FIRE AREA PAB-2{5} CREDITED UIl.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required Comments Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone R dmeto Need for OMA Resultant OMA Performance Complete OMA Margin (P) Fire Area/Zone Locally close valve LCV- 75 m 30 m 11 m TTC: 41 m I: Area PAB-2{5}, Zone Targets: cables associated with 11 2C and open valve 288 21A, 27A, 30A valves LCV-112B, LCV-112C to establish flowpath from Margin: 34 m; RWST to Charging pump 45% P: Area PAB-2{3}, Travel time conservatively taken to suction Zone 6 and Area PAB- be 10 minutes, from CCR to PAB. 2{5}, Zone 30A Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

NL-10-043 Docket No. 50-286 Attachment 1 Page 49 of 103 TABLE RAI-08.1-7 FIRE AREA TBL-5 CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments Need for o Resultant OMA Performance Complete OMA OMA Margin (P) Fire Area/Zone Locally operate [bypass 30 m 4.5 m 8m TTC: 12.5 m 1:Area TBL-5, Zone Target: FCV-1 121 control cables valve for] FCV-1 121 AFW 52A Pump recirculation valve Margin: 17.5 m; during pump startup (e) 58% P: Area AFW-6, Zone 23 Locally operate FCV- 30 m 4.5 m 17 m TTC: 21.5 m 1:Area TBL-5, Zone Target: FCV-406 control cables 406A, 406B to control (d) 52A, 54A AFW flow to SGs Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate SGADV WITHDRAWN PCV-1 134, PCV-1 135, See response to RAI-02.1 PCV-1 136, or PCV-1 137 to control secondary system cooldown (d) The Total Time to Complete is revised to 17 minutes, whereas the referenced submittals showed a value of 8 minutes for the Actual Time to Complete (e) Clarified that the bypass valve for FCV-1 121 is the component that is manually operated

NL-10-043 Docket No. 50-286 Attachment 1 Page 50 of 103 TABLE RAI-08.1-7 FIRE AREA TBL-5 CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Actual Time Actual Time Total Time to Initiator (I) Required Required OMA Time to to Diagnose to Complete Complete and Fire Area/Zone Comments Co e for Need tomplet Resultant OMA Performance Complete OMA Margin (P) Fire Area/Zone Locally/manually > 1 hour > 1 hour 15 m TTC: See I: Area TBL-5, Zone The need for periodic manual backwash SW pump Comments 37A, 38A, 43A, 44A backwash of the selected SW strainer as required if strainer is variable, depending on power to strainer Margin: See P: Area YARD-7, Zone ultimate heat sink conditions and associated with selected Comments 222 other factors. The Time to SW pump is lost (use Diagnose shown is a nominal one of STR PMP-31 figure, and therefore TTC and through STR PMP-36) Margin are not considered critical parameters for this occasional (as-needed) OMA,

NL-10-043 Docket No. 50-286 Attachment 1 Page 51 of 103 TABLE RAI-08.1-8 FIRE AREA YARD-7 CREDITED IlI.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time Actual Time Total Time to Initiator (I) Required to Diagnose tu Time Complete and Fire Area/Zone Comments Required OMA Time to Need for to Complete Resultant OMA Performance Complete OMA OMA Margin Fire Area/Zone Locally start ARDG to > 1 hour <1 m 25 m TTC: <26 m I:Area YARD-7, Zone Nonmechanistic Loss of Offsite supply MCC 312A in 22, YARD Power can be postulated at outset support of the use of SW Margin: >34 m; of scenario, effectively eliminating Pump 38 >56% P: Area YARD-7, diagnosis time Zones 131, 131A, Area TBL-5, Zone 37A Locally/manually > 1 hour > 1 hour 15 m TTC: See I: Area TBL-5, Zone The need for periodic manual backwash SW pump Comments 37A, 38A, 43A, 44A backwash of the selected SW strainer as required if strainer is variable, depending on power to strainer Margin: See P: Area YARD-7, Zone ultimate heat sink conditions and associated with selected Comments 222 other factors. The Time to SW pump is lost Diagnose shown is a nominal figure, and therefore TTC and Margin are not considered critical parameters for this occasional (as-needed) OMA.

NL-10-043 Docket No. 50-286 Attachment 1 Page 52 of 103 RAI-09.1 Provide information that demonstrates that the actions are reliable including a justification that various uncertainties are accounted for in the time margins and that the margins are sufficient to ensure that they provide adequate time to cover potential variations in plant conditions and human performance. If a factor of safety or diagnosis time has been included in the stated times to complete the actions, provide an explanation of how it has been incorporated into the timelines. If not, justify why the stated times are sufficient to ensure safety.

RESPONSE

The demonstration of the subject OMAs was accomplished via a two-phased effort, involving fire scenario modeling, failure diagnosis, and operator dispatch to perform the necessary OMAs using the plant simulator. This environment provided a realistic means of assessing operator response to the reported fire and response to the selected fire area-specific equipment failures that were flagged in the simulator model, and the assessment of the time necessary to reach the point at which operators were dispatched to perform the necessary mitigating OMAs. The subject OMAs were separately field-validated, with operators dispatched from the CCR (or other locations, as applicable to normal plant operating stations). The time to travel to the OMA location was recorded, as was the time to complete the (simulated) action. In each case, the operator progressed through the simulation of the action, including appropriate time delays consistent with that required to actually implement the action. For example, time was allocated for the manual opening or closing of designated valves, given the approximate number of handwheel turns necessary to achieve full travel of the valve. Note that the "diagnosis" times as presented on Tables RAI-08.1-1 through RAI-08.1-8 are based on actual operator response in simulator exercises as described in the response to RAI-07.1. Arbitrary estimates of time required for failure diagnosis were not used, nor were arbitrary factors of safety applied. The fact that the aggregate time to complete each OMA, as shown on Tables RAI-08.1 -1 through RAI-08.1-8, is consistently bounded by the analytically-based "Required time to complete," with margin, is considered to adequately bound the range of uncertainties that could reasonably be postulated. None of the OMA operating locations are difficult to access, and the required operations are simple manual actions that do not require any special tools, processes, or unique personal capabilities. The OMAs involve:

Manual operation of valves (manual valves, as well as operation of AOVs and MOVs via handwheels or installed jacking devices)
Local manual trip or closure of circuit breakers
Manual control of turbine-driven AFW pump None of the OMAs involve complex instruction sets, the installation or removal of jumpers, the installation or removal of fuses, or any actions requiring uniquely specialized knowledge or fine motor skills. The OMA task assignments are within the capability of any licensed operator or nuclear plant operator, as applicable to his/her responsibility set. As such, the challenge presented for completion of these basic tasks within the prescribed time limits is within the

NL-10-043 Docket No. 50-286 Attachment 1 Page 53 of 103 capability of the standard IP3 operating crew. Uncertainties that would be introduced by smoke obscuration or fire suppression activities are also expected to be minimal, given the minimal fire challenge in the affected plant areas, and the nature of the combustibles. The data presented in Tables RAI-08.1-1 through RAI-08.1-8 include the time required for diagnosis of the failure that initiates the need for the respective OMAs, the time to accomplish the OMA (dispatch, travel to the OMA location, perform the OMA, and confirm), and the resultant remaining time margin. The data originally provided in the Request for Exemption dated March 6, 2009 and in the Revision to the Request for Exemption dated October 1, 2009, only included the time-to-perform the OMAs, hence the available time margin could not be readily discerned from the data originally provided. RAI-1 0.1 State whether operators are procedurally directed to don SCBAs [Self Contained Breathing Apparatus] and whether the time needed to don the SCBAs was included in the analysis of the time available to perform the action.

RESPONSE

The post-fire safe-shutdown procedures do not include explicit instructions for operators to don -SCBAs if post-fire entry into affected plant areas is required. However, plant operator qualifications include the use of SCBAs for purposes of fire brigade response, licensed operator qualification, and radiation worker qualification. All operators retain at least one of these SCBA qualifications. Successful SCBA qualification, per Entergy Instructor Lesson Plan IOLP-SAF-SCB01 (Self Contained Breathing Apparatus), requires an operator to demonstrate that they can don a SCBA within two minutes. As such, any operator that may be dispatched to perform local OMAs in fire-affected areas is prepared by training to don an SCBA, as appropriate, for entry into the affected plant area. Supplies of SCBAs for use by operators not dedicated to the fire brigade are located in the CCR and at a number of strategic locations throughout the plant. These SCBAs are dedicated for operator use, and are separate and distinct from the SCBAs designated and staged for use only by the fire brigade. There is a sufficient number of SCBAs available at all times to equip all operators that may need to be dispatched from the CCR to perform OMAs. Supplies of spare air bottles are also available at several plant locations. The inventory of SCBAs and spare bottles is verified monthly. Given the relatively minimal OMAs that are required for response to fires in the III.G.2 areas discussed herein, the need for reentry to the fire-affected area typically involves only a small number of operators. The maintained supplies of SCBAs in the CCR and other strategic locations provides assurance that operators will not be impeded from performing necessary post-fire OMAs as the result of smoke or toxic gas conditions resulting from the postulated fire. Based on the ready availability of an adequate supply of SCBAs to operators who may be dispatched to perform OMAs, and also recognizing that none of the OMA travel paths or access locations present unusually difficult access conditions (i.e., that would be exacerbated significantly by wearing an SCBA), the field evaluations of OMA performance did not include the use of SCBAs.

NL-10-043 Docket No. 50-286 Attachment 1 Page 54 of 103 RAI-11.1 Provide critical details or assumption of the analysis that demonstrates that the required safe shut down equipment or component located within the area is maintained free of fire damage and remains accessible and operable following the fire event.

RESPONSE

The equipment to be operated via OMA following fire area reentry is as follows: Fire Area PAB-2{3} Valve 288: Valve 288 is a manually-operated valve located in Fire Zone 6, which also contains 22 Charging Pump. This valve is required to be opened to support alignment of Charging pump suction to the alternate source (RWST). The combustible load in this zone is low, and the credible ignition source is the 32 Charging Pump motor. Valve 288 is located at the south end of this zone adjacent to the doorway, and is not immediately adjacent to the pump motor. Given the fire detection features in the room and the location of valve 288, there is reasonable assurance that this mechanical-only valve will remain operable following post-fire reentry. It should also be recognized that for a fire in Fire Zone 6 involving 32 Charging Pump, fire damage can be expected to be confined to the zone of origin, despite the lack of a door enclosing the room fully at the south end. As the El. 55' corridor communicating with Fire Area PAB-2{3} is large and generally free of credible combustibles (with the exception of cables in overhead trays), there is reasonable assurance that access to valve 288, at 60 minutes following the start of the fire event, will remain sufficiently unencumbered, with the conditional use of SCBA by the operator(s), in the event that smoke venting throughout the area is incomplete at the time access to the area is needed. Fire Area PAB-2f5} Motor-operated valve 227: This valve is required to be manually opened to support establishment of a makeup path to the RCS, by bypassing a spuriously closed normal makeup path control valve HCV-142. The combustible loading in the zone (Fire Zone 62A) containing this valve, as well as the adjacent zones, is insignificant, and Fire Zone 62A is devoid of any ignition sources other than a cable tray run, and does not present a substantive fire challenge to the integrity of the valve. Moreover, motor-operated valve 227 has been evaluated for potential vulnerability to the fire-induced failure mode postulated by IN 92-18 (Potential for Loss of Remote Shutdown Capability During a Control Room Fire), and the associated "weak link" analysis confirms that despite postulation of limit and torque switch failures as considered by IN 92-18, the valve actuator is incapable of causing damage that would render valve 227 inoperable by hand following the fire event. There is adequate assurance that valve 227 will remain manually operable, following the credible fire scenario that may be encountered in Fire Zone 6 or any of the adjoining zones.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 55 of 103 Motor-operated valve LCV-1 12C: This valve is required to be manually closed to support alignment of Charging pump suction to the alternate source (RWST). The combustible loading in the zone (Fire Zone 29A) containing this valve, as well as the adjacent zones, is insignificant, and Fire Zone 29A is devoid of any ignition sources and does not present a substantive fire challenge to the integrity of the valve. Moreover, motor-operated valve LCV-1 12C has been evaluated for potential vulnerability to the fire-induced failure mode postulated by IN 92-18, and the associated "weak link" analysis confirms that despite postulation of limit and torque switch failures as considered by IN 92-18, the valve actuator is incapable of causing damage that would render LCV-1 12C inoperable by hand following the fire event. There is adequate assurance that LCV-1 12C will remain manually operable, following the credible fire scenario that may be encountered in Fire Zone 29A or any of the adjoining zones. Fire Area YARD-7 OMAs credited to be performed through post-fire reentry to Fire Area YARD-7 consist of the conditional starting of the Appendix R Diesel Generator and periodic local/manual backwash of the 38 SW Pump strainer. Given the time available to perform these actions, the widely spaced combustibles in the area, and the recognition that this is an outdoor area, prompt dispersion of any smoke generated can be expected, and the unencumbered travel paths, save for traversing security delay gates, present minimal concern for impact on the ability of the operators to successfully perform the OMAs in a timely manner. RAI-1 1.2 Provide a technical justification for why the assumed 60-minute reentry period is appropriate and an explanation for what is assumed to be included in this time.

RESPONSE

The stipulation for a 60-minute exclusion period for post-fire reentry to fire-affected areas PAB-2{3} and PAB-2{5} to perform OMAs is based in part on NRC guidance provided in response to a Con Edison letter dated September 11, 1985, specific to IP2 Fire Area C (the AFW Pump Room), and an exemption from the requirements of Paragraph III.G.2 granted for that room in an SER dated October 16, 1984 with subsequent clarifications as established in an NRC-Con Edison telephone conference of August 12, 1988, a Con Edison letter to NRC dated September 14, 1988, and ultimately an SER dated January 12, 1989. The potential need for post-fire reentry to this room was acknowledged, to allow local manual repositioning of AFW flow control valves that may be spuriously repositioned due to fire-induced circuit faults. However, the Staff determined that crediting of immediate reentry to this room was non-conservative, despite the insignificant fire hazard and minimal credible fire scenario, and established guidance in a follow-up telecon relative to the referenced SER that reentry to the room could not be credited for one hour following the initiation of the fire event. The NRC rationale appears to have been that there was insufficient basis to conclude that operators could safely reenter a fire-impacted zone until after one hour had elapsed, to allow reasonable time for a fire in the zone to be extinguished and smoke sufficiently vented. It should be noted that the significant delta between

NL-10-043 Docket No. 50-286 Attachment 1 Page 56 of 103 IP2 and IP3 Auxiliary Feedwater Pump rooms is the absence of an automatic fire suppression system in the IP2 AFW Pump room. The same guidance relative to reentry to the affected fire area has also been applied by Entergy in consideration of the credible fire scenarios in Fire Areas PAB-2{3} and PAB-2{5}, as discussed in Attachment 2 to Entergy letter NL-09-032, dated March 6, 2009 and Entergy letter NL-09-117 dated October 1, 2009. The low combustible loading and minimal ignition sources in the fire zones of concern within Fire Areas PAB-2{3}, Fire Zone 6 and PAB-2{5}, Fire Zones 30A and 62A, and the minimal combustible loading and ignition sources in the adjoining zones of Fire Areas PAB-2{31 and PAB-2{5} provide reasonable assurance that reentry to the area after one hour following the postulated fire provides ample time for securing from the fire condition and allowing operators unencumbered access to the area. Note that none of the credited OMAs is reliant upon reentry to an affected fire area within one hour of initiation of the postulated fire event. Moreover, for those actions requiring reentry to the affected fire area after one hour has elapsed, the demonstrated time necessary to perform these actions is approximately 50% or less of the time available to complete the action. The affected OMAs are in Fire Areas PAB-2{3}, and PAB-2{5}, and are described in Tables RAI-08.1-5 and RAI-08.1-6, respectively.

NL- 10-043 Docket No. 50-286 Attachment 1 Page 57 of 103 TABLES RAI-GEN-1 through RAI-GEN-23 Characteristics of Fire Areas

NL-10-043 Docket No. 50-286 Attachment 1 Page 58 of 103 TABLE RAI-GEN-1 CHARACTERISTICS OF FIRE AREA AFW-6 1 FIRE ZONE 23 Fire Area / Description AFW-6 / Auxiliary Boiler Feed Pump Room, Elevation 18'-6" of the Auxiliary Feed Pump Building Fire Zone / Description 23 / Auxiliary Boiler Feed Pump Room, Elevation 18'-6" Fire Zone Dimensions 1,254 sqft w/ 13 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                   -- Detection:             Yes
                                                   -- Suppression:           Yes App R III.G.2 Exemptions                            Yes - SER dated January 7, 1987 Fixed Combustible Materials                         Cable, lube oil, electrical panels, incidental materials Cable Insulation Quantity in BTU                    2.2E+07 BTU Total Fixed Combustible Loading /Fire Severity      17,950 BTU/sqft, / 13.5 minutes Transient Combustible Materials                     Lube oil, Solvent, Grease, Cleaning Materials, Wood Transient Combustible Loading / Fire Severity       7400 BTU/sqft / 5.5 minute Combustible Loading - Rating                        Low (Fixed + Transient loads    =  < 100,000 BTU/sqft)

Ignition Sources Cable run, Junction boxes, 2- Motors & Pumps, 1 - Electrical Cabinet

NL-10-043 Docket No. 50-286 Attachment 1 Page 59 of 103 TABLE RAI-GEN-1 CHARACTERISTICS OF FIRE AREA AFW-6 / FIRE ZONE 23 Detection Type / Coverage Ionization / Area Wide Code of Record NFPA 72E-1974 Fixed Suppression Type Wet Pipe Sprinkler / Area Wide Code of Record NFPA 13-1983 Manual Suppression Type C02 and DC (Dry Chemical) extinguishers Adjacent Zone Manual Suppression Yard hydrants Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Fire Barrier Analysis: Auxiliary Feedwater Building AFW-6 to Turbine Building TBL-5 (IP3-ANAL-FP-01 052) Other Evaluations (i.e., 86-10) Exterior Fire Area Boundary Analysis for the Auxiliary Feedwater Pump Room to the Yard Area (IP3-ANAL-FP-D1048)

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 60 of 103 TABLE RAI-GEN-2 CHARACTERISTICS OF ETN-4 / FIRE ZONE 60A Fire Area / Description ETN-4 / Electrical Tunnels Fire Zone / Description 60A / Upper Electrical Tunnel, Elevation 43'-0" Fire Zone Dimensions 3,200 sqft w/10 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:            Yes
                                                  -- Suppression:          Yes App R III.G.2 Exemptions                           Yes - SERs dated February 2, 1984, January 7, 1987, and September 28, 2007 Fixed Combustible Materials                        Cable, Incidental materials Cable Insulation Quantity in BTU                   2.89E+08 BTU Total Fixed Combustible Loading / Fire Severity    90,991 sqft / 68 minutes Transient Combustible Materials                    None Transient Combustible Loading / Fire Severity      NA Combustible Loading - Rating                       Low (Fixed + Transient loads  = <  100,000 BTU/sqft)

Ignition Sources Cable run Detection Type / Coverage Ionization / Area Wide, Thermal Detection / In Cable Trays Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage Dry Pipe Pre-action Sprinkler / In Cable Trays Code of Record NFPA 13-1978 and NFPA 15-1977

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 61 of 103 TABLE RAI-GEN-2 CHARACTERISTICS OF ETN-4 / FIRE ZONE 60A Manual Suppression Type C02 and DC extinguishers Adjacent Zone Manual Suppression C02 and DC extinguishers Additional FP Features Conduit 1VA/JA (source range flux N31 instrumentation) is protected with fire barrier wrap from penetration H-20 in Fire Zone 73A through the upper electrical tunnel. Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The west wall separating Zone 60A from Fire Area CTL-3 is a controlled barrier constructed of 3/16 inch steel plate bolted on a steel channel frame with fireproofing applied to both sides. The barrier is credited as providing an adequate level of protection to withstand the hazards present. The floor between Zones 60A and 7A has not been assigned a fire rating; however, it does provide an adequate level of protection given the fire hazards present and the electrical and mechanical penetrations of the barrier have been sealed to maintain a 3-hour fire rating.

NL-10-043 Docket No. 50-286 Attachment 1 Page 62 of 103 TABLE RAI-GEN-3 CHARACTERISTICS OF ETN-4 / FIRE ZONE 73A Fire Area I Description ETN-4 / Electrical Tunnels Fire Zone I Description 73A / Upper Electrical Penetration Area, Elevation 46'-0" Fire Zone Dimensions 1,350 sqft w/ 17 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:             Yes
                                                 -- Suppression:           Yes App R III.G.2 Exemptions                          Yes - SERs dated February 2, 1984, January 7, 1987, and September 28, 2007 Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  1.72E+07 BTU Total Fixed Combustible Loading /Fire Severity    127,239 BTU/sqft / 95 minutes Transient Combustible Materials                   None Transient Combustible Loading / Fire Severity     NA Combustible Loading - Rating                      Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sqft)

Ignition Sources Cable run, Junction box, 12 - Electrical Cabinets, 1 - Transformer, Detection Type / Coverage Ionization / Area Wide, Thermal Detection / In Cable Trays Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage Dry Pipe Pre-action Sprinkler / In Cable Trays

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 63 of 103 TABLE RAI-GEN-3 CHARACTERISTICS OF ETN-4 / FIRE ZONE 73A Code of Record NFPA 13-1978 and NFPA 15-1977 Manual Suppression Type C02 and DC extinguishers Adjacent Zone Manual Suppression C02 and DC extinguishers Conduit 1VA/JA (source range flux N31 instrumentation) is protected with fire barrier wrap from the penetration box at penetration H-20 through the upper electrical tunnel FZ-60A. Additional FP Features Cable trays 68J, 69J, 71J, 72J and part of 67J and 70J, and the cable bundles from penetrations H-28 and H-42 to the tray system are protected with a fire barrier wrap system (Channel IV instrumentation). Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The vertical stairwell separating Zones 73A and 74A is protected by a controlled barrier constructed of a 1/8 inch thick steel plate. Other Evaluations (i.e., 86-10) The floor between Zones 73A and 74A has not been assigned a fire rating; however, it does provide an adequate level of protection given the fire hazards present and the electrical and mechanical penetrations of the barrier have been sealed to maintain a 3- hour fire rating.

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 64 of 103 TABLE RAI-GEN-4 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{3 1 FIRE ZONE 5 Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 5 / Charging Pump Room 31, Elevation 55-0" Fire Zone Dimensions 288 sqft w/ 16 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                -- Detection:             Yes
                                                -- Suppression:           No App R III.G.2 Exemptions                         Yes - SER dated January 7, 1987 Fixed Combustible Materials                      Cable, Lube Oil, Incidental materials Cable Insulation Quantity in BTU                 1.57E+06 BTU Total Fixed Combustible Loading   Fire Severity  28,946 BTU/sqft / 22 minutes Transient Combustible Materials                  Lube oil, Solvent, Grease, Cleaning Materials, Wood, Anti-C's, Plastic Transient Combustible Loading / Fire Severity    84,151 BTU/sqft / 63 minutes Combustible Loading - Rating                     Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sqft)

Ignition Sources Cable run, Junction Box, 1 - Electrical Cabinet, Motor & Pump Detection Type / Coverage Ionization / Area-wide Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 65 of 103 TABLE RAI-GEN-4 CHARACTERISTICS OF PAB-2 I SSA FIRE/ANALYSIS AREA PAB-2{3 }f FIRE ZONE 5 Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (water), 002 extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The boundaries of Fire Zone 5 are not fire rated; however, the east wall of the fire zone is a Other Evaluations (i.e., 86-10) controlled barrier maintained to provide the necessary separation of redundant Charging Pumps 31, 32 and 33 given the hazards present

NL-10-043 Docket No. 50-286 Attachment 1 Page 66 of 103 TABLE RAI-GEN-5 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{3} / FIRE ZONE 6 Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 6 / Charging Pump Room 32, Elevation 55-0" Fire Zone Dimensions 288 sqft w/ 16 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:            Yes
                                                 -- Suppression:         'No App R III.G.2 Exemptions                         Yes - SER dated January 7, 1987 Fixed Combustible Materials                       Cable, Lube Oil, Incidental materials Cable Insulation Quantity in BTU                  1.39E+06 BTU Total Fixed Combustible Loading / Fire Severity  28,323 BTU/sqft / 21 minutes Transient Combustible Materials                   Lube oil, Solvent, Grease, Cleaning Materials, Wood, Anti-C's, Plastic Transient Combustible Loading/ Fire Severity     84,151 BTU/sqft / 63 minutes Combustible Loading - Rating                      Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sqft)

Ignition Sources Cable run, Junction Box, 1 - Electrical cabinet, Motor, Pump Detection Type / Coverage Ionization/ Area-wide Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 67 of 103 TABLE RAI-GEN-5 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{3} / FIRE ZONE 6 Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (water), C02 extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The boundaries of Fire Zone 5 are not fire rated; however, the east wall of the fire zone is a Other Evaluations (i.e., 86-10) controlled barrier maintained to provide the necessary separation of redundant Charging Pumps 31, 32 and 33 given the hazards present.

NL-10-043 Docket No. 50-286 Attachment 1 Page 68 of 103 TABLE RAI-GEN-6 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{3} / FIRE ZONE 7 Fire Area I Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 7 / Charging Pump Room 33, Elevation 55-0" Fire Zone Dimensions 303 sqft w/ 16 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                -- Detection:             Yes
                                                -- Suppression:           No App R III.G.2 Exemptions                         Yes - SER dated January 7, 1987 Fixed Combustible Materials                      Lube Oil, Incidental materials Cable Insulation Quantity in BTU                 None Total Fixed Combustible Loading / Fire Severity  2.23E+04 BTU/sqft I 17 minutes Transient Combustible Materials                  Lube oil, Solvent, Grease, Cleaning Materials, Wood, Anti-C's, Plastic Transient Combustible Loading / Fire Severity    79,985 BTU/sqft / 60 minutes Combustible Loading - Rating                     Moderate (Fixed + Transient loads = 100,000- 200,000 BTU/sqft)

Ignition Sources Junction Box, Motor, Pump Detection Type / Coverage Ionization / Area-wide Code of Record NFPA 72E-1974 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 69 of 103 TABLE RAI-GEN-6 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{3} / FIRE ZONE 7 Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (water). C02 extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The boundaries of Fire Zone 7 are not fire rated; however, the west wall of the fire zone is a Other Evaluations (i.e., 86-10) controlled barrier maintained to provide the necessary separation of redundant Charging Pumps 31, 32 and 33 given the hazards present.

NL-10-043 Docket No. 50-286 Attachment 1 Page 70 of 103 TABLE RAI-GEN-7 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5 } / FIRE ZONE 4A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 4A / Corridor at elevation 34'-0" Fire Zone Dimensions 477 sqft w/ 17 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

                                                 -- Detection:             No
                                                 -- Suppression:           No App R III.G.2 Exemptions                          None Fixed Combustible Materials                      Cable, Incidental materials, Cellulose, Plastic Cable Insulation Quantity in BTU                 5.8E+06 BTU Total Fixed Combustible Loading Fire Severity    26,915 BTU/sqft / 20 minutes Transient Combustible Materials                   Lube oil, Cleaning materials, Plastic, Paper, Wood, Anti-Cs

.Transient Combustible Loading / Fire Severity 89,000 BTU/sqft / 67 minutes Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sqft) Ignition Sources Cable run, Junction Box, 1 Transformer (dry), 16 Electrical Cabinets Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 71 of 103 TABLE RAI-GEN-7 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5 } I FIRE ZONE 4A Code of Record NA Manual Suppression Type Hose station (water), DC extinguisher Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Maximum Permissible Combustible Loading 240,000 BTU/sqft Other Evaluations (i.e., 86-10) None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 72 of 103 TABLE RAI-GEN-8 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 18A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 18A / Waste Gas Compressor Room, Elevation 55'-0" Fire Zone Dimensions 250 sqft w/1 6 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:             No
                                                 -- Suppression:           No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  6.74E+06 BTU Total Fixed Combustible Loading I Fire Severity    27,363 BTU/sqft / 21 minutes Transient Combustible Materials                   Grease, Cleaning Materials, Anti-Cs, Plastic, Wood Transient Combustible Loading / Fire Severity     59,800 BTU/sqft / 45 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Compressor, Motor, Cable run, Junction Boxes Detection Type / Coverage None Code of Record NA

NL-10-043 Docket No. 50-286 Attachment 1 Page 73 of 103 TABLE RAI-GEN-8 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 18A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02 & DC extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 74 of 103 TABLE RAI-GEN-9 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 19A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 19A / Waste Evaporator Room, Elevation 55'-0" Fire Zone Dimensions 602 sqft w/ 16 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:             No
                                                 -- Suppression:           No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  5.58E+06 BTU Total Fixed Combustible Loading /Fire Severity    9,666 BTU/sqft / 7 minutes Transient Combustible Materials                   Anti-C, Plastic, Wood Transient Combustible Loading Fire Severity       24,834 BTU/sqft / 19 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads  =  <100,000 BTU/sqft)

Ignition Sources Cable run, Junction Box, 19 - Electrical Cabinets, 2- Transformers (dry) Detection Type / Coverage None Code of Record NA Fixed Suppression Type Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 75 of 103 TABLE RAI-GEN-9 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 19A Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02 & DC extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 76 of 103 TABLE RAI-GEN-10 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 27A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 27A / Elevation 73'-0" PAB Corridor Fire Zone Dimensions 5,532 sqft w/ 15 1/22 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:            No
                                                 -- Suppression:          No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental material, Cellulose, Plastic, Flammable Liquid Locker Cable Insulation Quantity in BTU                  7.4E+06 BTU Total Fixed Combustible Loading / Fire Severity   8,095 BTU/sqft / 6 minutes Transient Combustible Materials                   Solvent, Cleaning materials, lube oil, grease, Wood, Plastic, Paper, Anti-Cs Transient Combustible Loading / Fire Severity     12,092 BTU/sqft / 9 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads   = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction Boxes, 1 - Transformer, Water heater Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 77 of 103 TABLE RAI-GEN-10 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} I FIRE ZONE 27A Code of Record NA Manual Suppression Type Hose stations (water), C02 extinguishers Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Fire Barrier Analysis: Primary Auxiliary Building to Radioactive Machine Shop (IP3-ANAL-FP-Other Evaluations (i.e., 86-10) 01047)

NL-10-043 Docket No. 50-286 Attachment 1 Page 78 of 103 TABLE RAI-GEN-1 1 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 30A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 30A / Valve Corridor, Elevation 73-0" Fire Zone Dimensions 171 sqft w/ 17 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:             No
                                                 -- Suppression:           No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  3.74E+05 BTU Total Fixed Combustible Loading / Fire Severity   2,591 BTU/sqft I 2 minutes Transient Combustible Materials                   Lube oil, Solvent, Grease, Cleaning materials, Wood, Anti-Cs, Plastic Transient Combustible Loading Fire Severity       141,728 BTU/sqft / 106 minutes Combustible Loading - Rating                      Moderate (Fixed + Transient loads  = 100,000- 200,000 BTU/sqft)

Ignition Sources Cable run Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 79 of 103 TABLE RAI-GEN-1 1 CHARACTERISTICS OF PAB-2 I SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 30A Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02 & DC extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 80 of 103 TABLE RAI-GEN-12 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 58A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone I Description 58A / Piping Tunnel, Elevation 41'-0" Fire Zone Dimensions 1400 sqft w/ 10 to 12 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:           Yes
                                                 -- Suppression:         No App R III.G.2 Exemptions                          Yes - SER dated January 7,1987 (FZ-1 & 58A CCW Pump Area)

Fixed Combustible Materials Cable, Incidental materials Cable Insulation Quantity in BTU 4.31 E+06 BTU Total Fixed Combustible Loading / Fire Severity 3,477 BTU/sqft / 3 minutes Transient Combustible Materials Lube oil, Solvent, Grease, Cleaning materials, Wood, Anti-Cs, Plastic Transient Combustible Loading / Fire Severity 17,311 BTU/sqft / 13 minutes Combustible Loading - Rating Low (Fixed + Transient loads = <100,000 BTU/sqft) Ignition Sources Cable run Detection Type / Coverage. Ionization / Area wide Code of Record NFPA 72E-1974 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 81 of 103 TABLE RAI-GEN-12 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 58A Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (water), C02, DC extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and lgnition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 82 of 103 TABLE RAI-GEN-13 CHARACTERISTICS OF PAB-2 / SSA FIREIANALYSIS AREA PAB-2{5} I FIRE ZONE 59A Fire Area Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 59A / Pipe Penetration Area, Elevations 41'-0" and 51'-0" of the Fan House Fire Zone Dimensions 3782 sqft w/ 8 to 26 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:            Yes
                                                 -- Suppression:          No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  1.07E+07 BTU Total Fixed Combustible Loading / Fire Severity   3,223 BTU/sqft / 2 minutes Transient Combustible Materials                   Grease, Cleaning materials, Anti-Cs, Plastic, Wood Transient Combustible Loading / Fire Severity     3,967 BTU/sqft / 3 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads = <1 00,000 BTU/sqft)

Ignition Sources Cable run, Junction box Detection Type I Coverage Ionization / Area wide Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 83 of 103 TABLE RAI-GEN-13 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 59A Code of Record NA Manual Suppression Type Hose stations (water), C02 extinguishers Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 84 of 103 TABLE RAI-GEN-14 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 62A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 62A / Pipe Tunnel, Elevation 35-0" of the Fan House Fire Zone Dimensions 792 sqft w/ 8 -14 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R IIl.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:             No
                                                 -- Suppression:           No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials Cable Insulation Quantity in BTU                  7.35E+05 BTU Total Fixed Combustible Loading / Fire Severity   1,328 BTU/sqft / 1 minutes Transient Combustible Materials                   Grease, Cleaning materials, Anti-Cs, Plastic, Wood Transient Combustible Loading Fire Severity       18,944 BTU/sqft / 14 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment I Page 85 of 103 TABLE RAI-GEN-14 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 62A Code of Record NA Manual Suppression Type DC extinguisher Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 86 of 103 TABLE RAI-GEN-15 CHARACTERISTICS OF TBL-5 / FIRE ZONE 37A Fire Area / Description TBL-5 / Turbine Building Fire Zone I Description 37A /Ground Floor South, elevation 15'-0" Fire Zone Dimensions 5,838 sqft w/ 119 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:            Yes (Partial)
                                                  -- Suppression:          Yes (Full area sprinkler)

App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Incidental material, MCC-Switchgear, Cellulose, Plastic, Lube oil, Flammable Liquid Cab Cable Insulation Quantity in BTU 1.99E+08 BTU Total Fixed Combustible Loading I Fire Severity 70,064 BTU/sqft / 53 minutes Transient Combustible Materials None Transient Combustible Loading I Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads = <100,000 BTU/sqft) Cable run, Junction Box, Battery & Charger, 12 - Electrical Cabinet, 4 - Transformer, 33; 6.9 KV Ignition Sources Switchgear vertical panels (HEAF potential source), 7 - MCC vertical panels, 1 - Dryer Ionization detectors over MCC 34 and 6.9 KV switchgear Detection Type I Coverage Thermal detection in battery and charger room Code of Record NFPA 72E-1 974

NL-10-043 Docket No. 50-286 Attachment 1 Page 87 of 103 TABLE RAI-GEN-15 CHARACTERISTICS OF TBL-5 / FIRE ZONE 37A Wet pipe sprinkler system, area wide except over switchgear Fixed Suppression Type / Coverage Wet pipe sprinkler system area wide, battery and charger room Water spray curtain separating TBL-5 and transformer yard Code of Record Wet pipe sprinkler - NFPA 13-1983 Water spray curtain - NFPA 15-1977 Manual Suppression Type Hose stations (water and foam), C02 and DC extinguishers Adjacent Zone Manual Suppression Hose stations (water and foam), C02 and DC extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Evaluation of Fire Doors in Accordance with Generic Letter 86-10 (IP3-ANAL-FP-01050) Fire Barrier Analysis: Fire Door Nos. 201, 203 and 205 Separating the Turbine Building from the Other Evaluations (i.e., 86-10) Control Building (IP3-ANAL-FP-01264) Fire Damper Assembly Analysis: Fire Dampers 4 and 9 Separating the Control Building from the Electrical Tunnel and the Turbine Building (IP3-ANAL-FP-01 325)

NL-10-043 Docket No. 50-286 Attachment 1 Page 88 of 103 TABLE RAI-GEN-16 CHARACTERISTICS OF TBL-5 / FIRE ZONE 38A Fire Area / Description TBL-5 / Turbine Building Fire Zone Description 38A / Chemical Laboratory, elevation 15"' Fire Zone Dimensions 4,500 sqft w/ 8 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                -- Detection:             Yes (Partial)
                                                -- Suppression:           Yes (Full area sprinkler)

App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Cellulose, Plastic, Flammable Liquid Cab, Hydrogen, Chemicals, Incidental materials, MCC Cable Insulation Quantity in BTU 3.23E+07 BTU Total Fixed Combustible Loading Fire Severity 19,639 BTU/sqft / 15 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads = <100,000 BTU/sqft) Ignition Sources 1 - Electrical Cabinet, MCC Detection Type / Coverage Ionization detector / Over MCC 32 Code of Record NFPA 72E-1 974

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 89 of 103 TABLE RAI-GEN-16 CHARACTERISTICS OF TBL-5 / FIRE ZONE 38A Fixed Suppression Type / Coverage Wet pipe sprinkler system in chemical storage area Code of Record NFPA 13-1983 Manual Suppression Type Hose stations (water and foam), C02 and DC extinguishers Adjacent Zone Manual Suppression Hose stations (water and foam), C02 and DC extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 90 of 103 TABLE RAI-GEN-17 CHARACTERISTICS OF TBL-5 / FIRE ZONE 43A Fire Area / Description TBL-5 / Turbine Building Fire Zone / Description 43A / South end. elevation 36'-9" Fire Zone Dimensions 7,725 sqft w/ 97 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:             No
                                                  -- Suppression:           Yes (Full area sprinkler)

App R III.G.2 Exemptions None Fixed Combustible Materials Plastic, Wood, Paper, Rubber, Cable, Incidental materials, MCC - Switchgear Cable Insulation Quantity in BTU 1.63E+08 BTU Total Fixed Combustible Loading / Fire Severity 42,758 BTU/sqft / 32 minutes Transient Combustible Materials Lube oil, Solvent, Grease, Cleaning Material, Wood Transient Combustible Loading / Fire Severity 1,202 BTU/sqft / 1 minutes Combustible Loading - Rating Low (Fixed + Transient loads = <100,000 BTU/sqft) Ignition Sources Cable run, Junction boxes, Exciter Switchgear, 2 - Transformer, 10 - Electrical Cabinets Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage Wet pipe sprinkler system / Area Wide

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 91 of 103 TABLE RAI-GEN-17 CHARACTERISTICS OF TBL-5 / FIRE ZONE 43A Code of Record NFPA 13-1983 Manual Suppression Type Hose stations (water), C02, pressurized water, and Halon extinguishers Adjacent Zone Manual Suppression Hose stations (water and foam), C02 and DC extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Evaluation of Fire Doors in Accordance with Generic Letter 86-10 (1P3-ANAL-FP-01 050) Evaluation of Supports Penetrating Barriers between Turbine Building and Cable Spreading Room and between Cable Spreading Room and Electrical Tunnels (IP3-ANAL-FP-01053) Other Evaluations (i.e., 86-10) Fire Door Assembly Analysis: Cable Spreading Room to Turbine Building (IP3-ANAL-FP-01 051) Fire Barrier Analysis: Fire Door Nos. 201, 203 and 205 Separating the Turbine Building from the Control Building (IP3-ANAL-FP-01264)

NL-10-043 Docket No. 50-286 Attachment 1 Page 92 of 103 TABLE RAI-GEN-18 CHARACTERISTICS OF TBL-5 / FIRE ZONE 44A Fire Area / Description TBL-5 / Turbine Building Fire Zone / Description 44A / South End of Heater Bay, elevation 36'-9" Fire Zone Dimensions 5,625 sqft w/ 29 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

                                                 -- Detection:               No
                                                 -- Suppression:             No App R III.G.2 Exemptions                          None Fixed Combustible Materials                       Cable, Incidental materials, Flammable Liquid Cab, Cellulose, Plastic, Wood, Rubber Cable Insulation Quantity in BTU                  8.41 E+06 BTU Total Fixed Combustible Loading /Fire Severity    15,512 BTU/sqft / 12 minutes Transient Combustible Materials                   Lube oil, Solvent, Grease, Cleaning materials, Wood Transient Combustible Loading / Fire Severity     1,651 BTU/sqft / 1 minute Combustible Loading - Rating                      Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction boxes, 3-Electrical Cabinets, 1-Transformer (dry) Detection Type / Coverage None Code of Record NA

NL-10-043 Docket No. 50-286 Attachment 1 Page 93 of 103 TABLE RAI-GEN-18 CHARACTERISTICS OF TBL-5 / FIRE ZONE 44A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Pressurized water and C02 Extinguishers Adjacent Zone Manual Suppression Hose stations (water), Pressurized water, Halon extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 94 of 103 TABLE RAI-GEN-19 CHARACTERISTICS OF TBL-5 / FIRE ZONE 52A Fire Area / Description TBL-5 / Turbine Building Fire Zone / Description 52A / Chemical Addition Area, elevation 32'-6" of AFW Bldg Fire Zone Dimensions 1,254 sqft w/ 8 1/2 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:               No
                                                  -- Suppression:             No App R III.G.2 Exemptions                           None Fixed Combustible Materials                        Cable, Cellulose barrels, Rubber hose Cable Insulation Quantity in BTU                   4.47E+06 BTU Total Fixed Combustible Loading   Fire Severity    6,161 BTU/sqft / 5 minutes Transient Combustible Materials                    Lube oil, Solvent, Grease, Cleaning Material, Wood Transient-Combustible Loading / Fire Severity      7,405 BTU/sqft / 6 minutes Combustible Loading - Rating                       Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources 2 - Motors & Compressors, Water heater Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 95 of 103 TABLE RAI-GEN-19 CHARACTERISTICS OF TBL-5 / FIRE ZONE 52A Code of Record NA Manual Suppression Type DC extinguisher Adjacent Zone Manual Suppression None Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 96 of 103 TABLE RAI-GEN-20 CHARACTERISTICS OF TBL-5 / FIRE ZONE 54A Fire Area / Description TBL-5 / Turbine Building Fire Zone / Description Main Boiler Feedwater Regulator Area, elevation 18'-6" AFW Bldg Fire Zone Dimensions 1,088 sqft w/ 70 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:             No
                                                  -- Suppression:           No App R III.G.2 Exemptions                           None Fixed Combustible Materials                        Cable, Incidental material, Flammable Liquid Cab Cable Insulation Quantity in BTU                   1.61 E+06 BTU Total Fixed Combustible Loading / Fire Severity    9,851 BTU/sqft / 7 minutes Transient Combustible Materials                    Lube oil, Solvent, Grease, Cleaning Material, Wood Transient Combustible Loading /Fire Severity       8,534 BTU/sqft /6 minutes Combustible Loading - Rating                       Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction boxes, 1-Electrical Cabinet, 4 - MOV Motors Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 97 of 103 TABLE RAI-GEN-20 CHARACTERISTICS OF TBL-5 / FIRE ZONE 54A Code of Record NA Manual Suppression Type Hose station (water) Adjacent Zone Manual Suppression C02 and DC extinguisher Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) Fire Barrier Analysis: Auxiliary Boiler Feedwater Area AFW-6 to Turbine Building TBL-5 (IP3-ANAL-FP-01 052)

NL-10-043 Docket No. 50-286 Attachment 1 Page 98 of 103 TABLE RAI-GEN-21 CHARACTERISTICS OF TBL-5 / FIRE ZONE 57A Fire Area / Description TBL-5 / Turbine Building Fire Zone / Description 57A / Main Steam and Feedwater Valve Area, elevation 43'-0" AFW Bldg Fire Zone Dimensions 1254 sqft w/ 45 ft ceiling a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                  -- Detection:            Partial-coverage; detectors to actuate suppression system only
                                                  -- Suppression:          Water spray curtain for separation from adjacent Fire Area TBL-5 App R III.G.2 Exemptions                           None Fixed Combustible Materials                        Cable, Incidental material Cable Insulation Quantity in BTU                   5.24E+07 BTU Total Fixed Combustible Loading / Fire Severity    42,187 BTU/sqft / 32 minutes Transient Combustible Materials                    Lube oil, Solvent, Grease, Cleaning Material, Wood Transient Combustible Loading / Fire Severity      7,405 BTU/sqft / 6 minutes Combustible Loading - Rating                       Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction boxes, 2 - Electrical Cabinets, 2 - MCC vertical panels, 1 - Transformer Detection Type / Coverage Local thermal detectors to actuate water spray curtain Code of Record NFPA 72E-1974

NL-1 0-043 Docket No. 50-286 Attachment 1 Page 99 of 103 TABLE RAI-GEN-21 CHARACTERISTICS OF TBL-5 / FIRE ZONE 57A Fixed Suppression Type / Coverage Water spray curtain separates Turbine Building (Fire Zone 51A) from Auxiliary Boiler Feed Pump Building at pipe bridge Code of Record NFPA 15-1977 Manual Suppression Type DC extinguisher Adjacent Zone Manual Suppression None Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-043 Docket No. 50-286 Attachment 1 Page 100 of 103 TABLE RAI-GEN-22 CHARACTERISTICS OF YARD-7 / FIRE ZONE 22 Fire Area Description YARD-7 / Exterior Yard Fire Zone / Description 22 / Screenwell Area Fire Zone Dimensions 784 sqft (outside) a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                 -- Detection:          Yes
                                                 -- Suppression:         No App R III.G.2 Exemptions                          Yes - SER dated January 7, 1987 Fixed Combustible Materials                       Cable, MCC - Switchgear, Plastic, Incidental materials Cable Insulation Quantity in BTU                  1.68E+07 BTU Total Fixed Combustible Loading /Fire Severity    23,253 BTU/sqft / 17 minutes Transient Combustible Materials                   Grease, Cleaning materials, Solvent, Lube oil, Wood Transient Combustible Loading / Fire Severity     12,499 BTU/sqft / 9 minutes Combustible Loading - Rating                      Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction box, 1 - Transformer, 6 Motors & Pumps, 1 - Electrical Cabinet Detection Type / Coverage Photoelectric Detection / Area-wide Code of Record NFPA 72E-1 987 Fixed Suppression Type / Coverage None

NL-10-043 Docket No. 50-286 Attachment 1 Page 101 of 103 TABLE RAI-GEN-22 CHARACTERISTICS OF YARD-7 / FIRE ZONE 22 Code of Record NA Manual Suppression Type DC Extinguisher Adjacent Zone Manual Suppression Yard Hydrants Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

N L-10-043 Docket No. 50-286 Attachment 1 Page 102 of 103 TABLE RAI-GEN-23 CHARACTERISTICS OF YARD-7 / FIRE ZONE 222 Fire Area / Description YARD-7 / Exterior Yard Fire Zone / Description 222 / Backup Service Water Pit Fire Zone Dimensions Outside open area a) 3-hr barrier: No b) 20 ft separation: No App R III.G.2 Compliance c) 1-hour enclosure: No

                                                   -- Detection:          No
                                                   -- Suppression:        No App R III.G.2 Exemptions                            None Fixed Combustible Materials                         Cable Cable Insulation Quantity in BTU                    1.69E+06 BTU Total Fixed Combustible Loading / Fire Severity     NA Transient Combustible Materials                     None Transient Combustible Loading / Fire Severity       None Combustible Loading - Rating                        NA Ignition Sources                                    3 - Motor & Pump Detection Type / Coverage                           None Code of Record                                      NA Fixed Suppression Type / Coverage                   None

NL-10-043 Docket No. 50-286 Attachment 1 Page 103 of 103 TABLE RAI-GEN-23 CHARACTERISTICS OF YARD-7 / FIRE ZONE 222 Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Yard hydrants Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None}}

v t e Letter Sequence Request
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Initiation Request, Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval... Other: ML112010672, NL-11-013, Revised Tables from Responses to Requests for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions
MONTHYEAR2011-01-19 [Table View]

NL-10-043, Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit 3

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NL-10-043, Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit 3

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