NL-11-007, Response to December 16, 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

Response to December 16, 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

ML110310242
Person / Time
Site:	Indian Point
Issue date:	01/19/2011
From:	Joseph E Pollock Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-007, TAC ME0799
Download: ML110310242 (64)

Text

'Indian Point Energy Center 450 Broadway, GSB 7 ntergy I(LLI P.O. Box 249

'Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President NL-1 1-007 January 19, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Response to December 16, 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 December 16, 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-10-101, "Response to August 11, 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)," dated September 29, 2010

3. NRC letter dated August 11, 2010, "Indian Point Nuclear Generating Unit Nos. 2 and 3 - Request for Additional Information Regarding Request for Exemption (TAC Nos. ME0798 and ME0799)"

4. Entergy letter 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 No. 3 (TAC No. ME0799)," dated May 4, 2010

NL-1 1-007 Docket No. 50-286 Page 2 of 3

5. 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)"

6. 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

7. 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 7), 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 6). Responses to the Request for Additional Information contained in NRC letter dated January 20, 2010 (Reference 5) were provided by letter dated May 4, 2010 (Reference 4). Responses to the Request for Additional Information contained in NRC letter dated August 11, 2010 (Reference 3) were provided by letter dated September 29, 2010 (Reference 2).The purpose of this letter is to provide responses to the Request for Additional Information (RAI) contained in NRC letter dated December 16, 2010 (Reference 1). Note that Reference 1 indicated that a response was needed within 30 days of the date of the letter - a one-day extension until January 19, 2010 was granted by the NRC Senior Project Manager.

Entergy believes that we have been responsive in References 2 and 4 to the specific requests contained in References 3 and 5, and acknowledges difficulties that may be encountered in collating the quantity of information provided in our submittals as part of the review process. As such, in addition to new information included in this response, we have responded to this RAI by referencing the submittals in which previously supplied information was provided. However, in preparing the response to this RAI, it was identified that changes are required to certain information provided -in previous submittals. The responses to the questions in this RAI contain corrected information, and the specific corrections to the previous submittals will be submitted in a separate letter. New information not previously provided but which is needed to support the response to this RAI is also included in Attachment 2.

At your earliest convenience we request that a telecom or meeting be held with the Staff to review/clarify any of the information provided in our responses to the three RAIs.

NL-11-007 Docket No. 50-286 Page 3 of 3 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 December 16, 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

2. New Material to Support the Response to December 16, 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. William Dean, 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. Francis J. Murray, Jr., President and CEO, NYSERDA

ATTACHMENT 1 TO ENTERGY LETTER NL-1 1-007 Response to December 16, 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-11-007 Docket No. 50-286 Attachment 1 Page 1 of 50 Response to December 16, 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 NOTE: The RAI (Request for Additional Information) questions below are written specifically for Indian Point Unit No. 2 as contained in the December 16, 2010 RAI (Reference 1 in the cover letter). The RAI did not provide questions specific to Indian Point Unit No. 3 (IP3) but indicated that the RAI questions also apply to IP3 and directed that answers specific to IP3 be provided. As such, the equipment designators in the RAI questions have not been changed for IP3 but the responses contain the correct IP3 equipment designators.

RAI-01.1 The September 29, 2010, response states that an intra-cable (conductor-to-conductor) fault within cable CK1 -JB5/1 would cause the volume control tank (VCT) outlet valve (LCV-11 [3]C) to spuriously close. Ifthis failure were to occur at a time when the credited charging pump (21 Charging Pump) is in operation, or if the fire damage to unspecified control cables caused the 21 pump to spuriously start, the credited charging pump would suffer prompt damage due to a loss of suction.

The results of recent cable fire tests conducted by both the NRC and industry show that given cable damage, the occurrence of the type of fault required to cause LCV-1 12C to close (i.e.,

an intra-cable fault) is highly likely. Thus, the potential for a spurious closure of LCV-1 12C with a concurrent spurious start of the charging pump cannot be ignored. However, the September 29, 2010, response does not provide sufficient information to determine the likelihood of fire-induced failures that would be necessary to cause this event. For example, since the response does not provide any information related to the charging pump control cables, a spurious pump start is assumed to occur. In the absence of any discussion of the mitigating circumstances available to reduce the likelihood of this event, it is assumed that LCV-1 12C closes and the pump is promptly damaged.

As another example, the September 29, 2010, response indicates that in addition to a loss of offsite power (which is assumed in the analysis), a fire in Fire Area J could cause a loss of 480 volt power supplied from the emergency diesel generator (EDG) via buses 5 and 6. The response identifies the cables of concern; however, it does not describe the specific number or types of cable faults that are required to cause this event. In addition, the response does not identify the shutdown equipment supplied from buses 5 and 6 or the impact a loss of power to this equipment would have on the ability to achieve and maintain hot shutdown. In addition, although certain cables of concern lack separation from potential ignition sources, the response does not provide any justification why this configuration, when considered in conjunction with other fire safety features, provides an appropriate level of defense-in-depth to minimize the need for implementing the requested OMAs. For example, a high-energy arcing fault (HEAF) emanating from switchgear located in Fire Zone 43 could cause prompt damage

NL-11-007 Docket No. 50-286 Attachment 1 Page 2 of 50 to cables of concern which are routed in close proximity to it. However, in lieu of describing the likelihood or impact of this scenario, the response (Table RAI-06.1-1 Page 28) credits prompt detection of fire by plant personnel. Given the nature of HEAF events and the close proximity of required cables to the switchgear, reliance on plant personnel may not provide an appropriate level of defense in depth.

Therefore, for cases such as the examples cited above, the request should provide a detailed discussion of the plant-specific features which would minimize the likelihood of occurrence.

Such features may include, for example, a combination of features such as: detection, suppression, separation distance between cables of concern, separation of cables from potential sources of ignition and HEAF, the type of raceway (conduit, cable tray), cable type and number and type of circuit faults required to cause the undesired event.

Where a requested OMA is being credited to mitigate the impact of fire-induced failures of required shutdown equipment, additional information is needed to assess the likelihood of a fire to create the need for the requested OMAs. For each of the requested OMAs, ensure that information has been provided to demonstrate how the underlying purpose of the rule (10 CFR 50 Appendix R) is met. For example, identify:

1. all cables that could cause components of concern to spuriously start, stop, change position, become damaged or otherwise fail in an undesired manner for hot shutdown.

2. the routing of these cables within each of the fire areas identified in the request,

3. the proximity of the identified cables of concern to each other (in feet and inches),

4. the type of cable faults required to cause the component(s) to fail in an undesired manner for post-fire safe shutdown,

5. the spatial relationship of each cable to potential ignition sources and/or high energy arcing faults, and

6. any other plant specific features that serve to minimize the likelihood of the undesired event.

RAI 01.1 RESPONSE For items 2 and 5 above, the routing of the cables of concern, within the fire area, and their spatial relationship to potential ignition sources and/or high energy arcing faults, were previously provided as "RAI-02.1 Response" in Entergy's submittal dated September 29, 2010.

For items 1 and 6 above, the enclosed Table RAI-01.1-1 summarizes the requested information, which has been provided previously in Entergy letters dated May 4, 2010 and September 29, 2010. Entergy believes that the likelihood of a fire to create the need for the requested OMAs is mitigated by the layers of fire protection defense-in-depth as detailed for each OMA in the table.

With respect to Item 3 above, Entergy has provided cable routing dimensional details for the circuits of concern in the submittal dated September 29, 2010. However, it should be noted that in most cases, the dimensional data provided does not relate to the separation between

NL-11-007 Docket No. 50-286 Attachment 1 Page 3 of 50 redundant trains, but rather the location and separation from ignition sources for a single train that presents the potential for use of the credited OMA if that train is impacted by fire damage.

The response to Item 4 is provided on Table RAI-01.1-2. Table RAI-01.1-2 provides insights relative to the fire-induced cable failure modes and effects that would be necessary to create the potential need to implement the OMA.

As previously discussed in the Entergy submittal dated March 6, 2009, Entergy believes that the requested "OMAs are unlikely to be required to be implemented given the defense-in-depth features of the fire protection program, and the associated low likelihood of a significant fire in any of the fire areas of concern."

Additionally, in the March 6, 2009 submittal, Entergy discussed that each of the affected fire areas has one or more mitigating fire protection characteristics that provide a level of defense-in-depth protection, thus minimizing the likelihood of need to implement post-fire shutdown procedures for credible fire scenarios in these areas. When these defense-in-depth features are considered in concert with the station fire prevention measures of housekeeping controls, hot work constraints, and transient combustible controls, and the fire brigade manual suppression capabilities, the likelihood of the need to implement the identified OMAs is reduced further.

Further, in the March 6, 2009 submittal, Entergy elaborated the defense-in-depth discussion and concluded that:

• For "The Fire Prevention layer of defense in depth.. .the potential for exposure fires (in transient combustibles) and fires resulting from the introduction of significant ignition sources (hot work) is sharply limited."

• For 'The Fire Detection and Suppression layer of defense in depth.. installed fire detection and automatic suppression systems, in conjunction with fire brigade response and deployment of the available manual fire suppression features, provides assurance that a fire will be precluded from rapidly growing and involving other fire zones or areas."

For those areas not equipped with automatic fire detection and/or suppression systems, the available defense-in-depth features are discussed further in this submittal.

T'he Protection of Safe-Shutdown Capability" layer of defense in depth is represented by the fire barriers enclosing each fire area that provide assurance that a fire that is not promptly detected and/or not promptly controlled and suppressed, will ultimately be contained within the fire area of origination." Additionally, ..."the character of the localization of the hazards and combustibles by fire zone, combined with the separation between fire zones by spatial and barrier separation, provide reasonable assurance that fires that occur within a given zone will be confined to the zone of origination."

NL-11-007 Docket No. 50-286 Attachment 1 Page 4 of 50 The above described OMA characteristics and mitigating features, as previously described in Entergy submittals dated May 4, 2010 and September 29, 2010, are summarized on Table RAI-01.1-1. To facilitate review and minimize the presentation of repetitive information, the OMAs are presented on Table RAI-01.1-1 only once per unique OMA, although that same OMA may be credited in the event of fire scenarios in more than one fire area. With respect to the information requested by RAI-01.1 item 4, the discussion of fire-induced cable failure modes and effects and other mitigating factors is presented on Table RAI-01.1-2.

In response to the question presented in the second paragraph of the RAI: The concerns associated with the charging pump suction path are addressed in the responses to RAI-01.2, RAI-01 .3, and RAI-01.4 herein.

In response to the question presented in the third paragraph of the RAI: The subject OMA explicitly relates to Indian Point 2. A review of the IP3 OMA relevant physical configurations did not identify a comparable arrangement/scenario. However, all IP3 OMA scenarios, with respect to the associated fire-induced cable failure modes and effects, are addressed by Table RAI-01.1-2.

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 5 of 50 Locally start Area AM' AK3-PT2 Exemption granted for App R III.G.2 33 AFW Pump Zone 23 JB1-PT2/2 Area wide smoke detection from breaker JB1-X32/2 Area wide wet pipe sprinklers on Bus 6A LL7-X32 Low Fixed Combustible Loading LQ7-X32 Transient Combustible Controls X32-Y2J Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone Swap 32 CCW Area ETN-4{1} 32CCP AS9-W1D Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Pump to Zone 7A January 7, 1987, and September 28, 2007 alternate Area wide smoke detection power supply Thermal detection in cable trays or align city Dry pipe/pre-action sprinklers in trays water to Low Fixed Combustible Loading Charging Transient Combustible Controls pumps Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Operate 480V Area ETN-4{1} 31AFP A15-PT2 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Bus 3A breaker Zone 7A JB1-PT2/1 January 7, 1987, and September 28, 2007 locally to start JB1-X32/1 Area wide smoke detection 31 AFW Pump Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading

References:

Entergy letter NL-10-043 dated May, 4, 2010, Tables RAI-08.1-1 through RAI-08.1-8; Entergy letter NL-10-101 dated September 29, 2010, Tables RAI-08.1-6 and RAI-08.1-7 2

Reference:

Entergy letter NL-10-101 dated September 29, 2010, RAI-02.1 response 3

References:

Entergy letter NL-10-043 dated May, 4, 2010, Tables RAI-GEN-1 through GEN-23; Entergy letter NL-10-101 dated September 29, 2010, Tables RAI-GEN-8, RAI-GEN-10, RAI-GEN-15, RAI-GEN- 16, and RAI-GEN- 19

NL-11-007 Docket No. 50-286 Attachment 1 Page 6 of 50 I I dl I*W IL L UI I IUUbLIUIC %.UIILI UIZ Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area ETN-4{1} FCV-1121 JB1-X32/1 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-1121 in Zone 7A January 7, 1987, and September 28, 2007 support of use. Area wide smoke detection of 31 AFW Thermal detection in cable trays Pump Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone Area TBL-5 JB1-X32/1 Low Fixed Combustible Loading Zone 52A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in zone Operate HCV- Area ETN-4{1} HCV-1118 JB1-TA5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, 1118 manually Zone 60A January 7, 1987, and September 28, 2007 to control 32 Area wide smoke detection AFW Pump Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 7 of 50 Area ETN-4{3} Exemption granted for App R III.G.2 - SERs dated February 2, 1 Zone 73A January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Align Appendix Area ETN-4{1} 480V Bus 2A Cables of Exemption granted for App R III.G.2 - SERs dated February 2, 1984, R Diesel Zones 7A and 480V Bus 5A concern are January 7, 1987, and September 28, 2007 Generator 60A not explicitly Area wide smoke detection (ARDG) to identified by Thermal detection in cable trays 480V Buses 2A the IP3 Safe- Dry pipe/pre-action sprinklers in trays and 5A, Shutdown Low Fixed Combustible Loading through 6.9kV Analysis Transient Combustible Controls Buses 2 and 5 Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zones Locally start Area YARD-7 SWS PMP-31 AQ8-M59 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Appendix R Zone 22 SWS PMP-32 AT6-M61 Area wide smoke detection Diesel SWS PMP-33 AJ8-M62 Low Fixed Combustible Loading Generator SWS PMP-34 AQ7-M63 Transient Combustible Controls (ARDG) to SWS PMP-35 AH2-M64 Minimal Ignition Sources supply Bus SWS PMP-36 AJ7-M65 Hot Work & Ignition Source Controls 312, to Portable Extinguishers in zone support use of Hydrants in adjacent yard 38SWP

NL-11-007 Docket No. 50-286 Attachment 1 Page 8 of 50 swap ji or .z Area :L j-'+/-i jz tnarging Mr1 I -r1lD Exemption granted for App R III.G.2 - SEP Charging Pump Zone 7A Pump AH9-PL2 January 7, 1987, and September 28, 2007 to alternate JA4-PL2/2 Area wide smoke detection power supply Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area PAB-2{5} AH9-PL2 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A JA4-PL2/2 Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area ETN-4{1} 31 Charging AQ3-KIC Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 60A Pump AQ3-PL2 January 7, 1987, and September 28, 2007 JA2-PL2/1 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 9 of 50 LULdIIIY UPICIdLC MId EI II J D .L-)AI/ L-A:IIII.LIUII yiCHlILtU IUIl M/PJ IM 1i1.U,, - aL-I FCV-405B, Zone 7A JF5-KV4 January 7, 1987, and September 28, 2007 FCV-405D, or JF5-LL8 Area wide smoke detection FCV-406B to K45-YM3 Thermal detection in cable trays control AFW K47-YM3 Dry pipe/pre-action sprinklers in trays flow to Steam Low Fixed Combustible Loading Generators Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone Area ETN-4{1} FCV-405B JB1-KV6 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 60A January 7, 1987, and September 28, 2007 FCV-405D JB1-KV8 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area ETN-4{3} FCV-405C JB1-KV8 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A FCV-405D JB1-KV7 January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 10 of 50 Locally open Area t I N- txemption grantea ror App K ni.U.Z - *-KS aatea reDruary z, i.p+4, valve 227 to Zone 60A January 7, 1987, and September 28, 2007 establish Area wide smoke detection charging Thermal detection in cable trays makeup flow Dry pipe/pre-action sprinklers in trays to RCS Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area PAB-2{5} JB5-X1J Area wide smoke detection Zone 59A VK4-X1J Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Locally close Area ETN-4{1} LCV-112B DD4-JB5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, valve LCV- Zone 60A LCV-112C DK7-JB5 January 7, 1987, and September 28, 2007 112C; open Area wide smoke detection valve 288 to Thermal detection in cable trays align Charging Dry pipe/pre-action sprinklers in trays pump suction Low Fixed Combustible Loading to the RWST Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 11 of 50

-Xeii iJ"Uii rCIdIILUU ,u1 /JIJ. K L .1A3.L-Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{3} DD4-VN3 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 6 Area wide smoke detection Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adjacent zone Area PAB-2{5} DD4-VN3 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} DD4-VN5/1 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A DD4-VN5/2 Area wide smoke detection DK7-VN5 Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 12 of 50 MZed rAD-LjJ vIlUUC[dLC rIA.CU LkUIIUUULIUIU LUdUIIIJ Zone 20A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adiacent zone Area PAB-2{5} DK7-VN5 Low Fixed Combustible Loading Zone 27A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} Moderate Fixed Combustible Loading Zone 30A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adjacent zone Locally operate Area ETN-4{1} PCV-1139 JB1-PT2/3 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, PCV-1139 to Zone 60A January 7, 1987, and September 28, 2007 ensure steam Area wide smoke detection supply to 32 Thermal detection in cable trays AFW Pump Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 13 of 50 Area t I N-, t-xemption grantea Tor App K ni.U.Z - 51=l Zone 73A January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinquishers in the zone Locally operate Area ETN-4{1} PCV-1310A JB1-SZ6 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, PCV-1310A, Zone 60A PCV-1310B JB1-S99 January 7, 1987, and September 28, 2007 1310B to JB1-X02 Area wide smoke detection ensure steam JB1-X02/1 Thermal detection in cable trays supply to 32 Dry pipe/pre-action sprinklers in trays AFW Pump Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area ETN-4{3} JB1-X02 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A JB11-S99 January 7, 1987, and September 28, 2007 JBI-X02/1 Area wide smoke detection JBI-SZ6 Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 14 of 50 LLUL~dIy STR PMP-31 %LVVO-AV- CAUI1,lIUUI UIdIIILtU 1u1 %IJpK i1..j.L - Zr, manually Zone 60A STR PMP-32 DE1-XV2 January 7, 1987, and September 28, 2007 perform STR PMP-33 Area wide smoke detection Service Water STR PMP-34 Thermal detection in cable trays (SW) pump STR PMP-35 Dry pipe/pre-action sprinklers in trays strainer STR PMP-36 Low Fixed Combustible Loading backwash as STR PMP-37 transient Combustible Controls required STR PMP-38 Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 15 of 50 1 222 Tim riPr-32 /one zzz:

Zone 222 STR PMP-32 AJ7-WF6 Outside Zone 22 STR PMP-33 AQ7-WF6 Transient Combustible Controls STR PMP-34 AT6-WF6/2 Minimal Ignition Sources STR PMP-35 MW6-P2K Hot Work & Ignition Source Controls STR PMP-36 MW7-P2L Portable Extinguishers in the zone STR PMP-38 MW8-P2M Hydrants in adjacent yard MW9-P2N MX7-P2P Zone 22:

MX8-P2Q Exemption granted for App R III.G.2 - SER dated January 7, 1987 MY1-PY1 Area wide smoke detection P2K-P2M/1 Low Fixed Combustible Loading P2K-WQ9 Transient Combustible Controls P2K-XL1 Minimal Ignition Sources P2K-Z99 Hot Work & Ignition Source Controls P2K-P2M/1 Portable Extinguishers in zone P2L-P2N/1 Hydrants in adjacent yard P2L-W14 P2L-XL1 P2L-Z99 P2L-P2N/1 P2M-P2P/1 P2M-XL2 P2M-Z99 P2N-P2Q/1 P2N-XL2 P2N-Z99 P2P-XL3 P2P-Z99 P2Q-XL3 P2Q-Z99

NL-11-007 Docket No. 50-286 Attachment 1 Page 16 of 50 rT I-AvZ/J WF6-Z99 WK9-W14 WK9-XV8 WQ9-XV2 XL1-YW2 XL1-YW3 XL2-YW5 XL3-YW6 XL3-YW7 XV2-XV8 Area TBL-5 STR PMP-31 AH2-WF6/2 Smoke detection over MCC 34 and 6.9KV Swgr Zone 37A STR PMP-32 AJ7-WF6 Thermal detection in battery and charger room STR PMP-33 AQ7-WF6 Area wide wet pipe sprinkler STR PMP-34 AT6-WF6/2 Wet pipe sprinkler in battery and charger room STR PMP-35 WF6-Z99 Low Fixed Combustible Loading STR PMP-36 WK9-XV8 Transient Combustible Controls WQ9-XV2 Minimal Ignition Sources XV2-XV8 Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone Area TBL-5 Smoke detection over MCC 32 Zone 38A Area wide wet pipe sprinkler Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 17 of 50 Area I tL-D A[ed wIuc we.t p-ip i priIKir Zone 43A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone Area TBL-5 Low Fixed Combustible Loading Zone 44A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in adjacent zone Locally operate Area ETN-4{3} FCV-405C JB1-KV8 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-405C, Zone 73A FCV-405D JB1-KV7 January 7, 1987, and September 28, 2007 FCV-405D to Area wide smoke detection control AFW Thermal detection in trays flow to steam Dry pipe/pre-action sprinklers in trays generators Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area TBL-5 FCV-406A JB1-SX1/1 Low Fixed Combustible Loading FCV-406A, Zone 52A FCV-406B JF5-KV3 Transient Combustible Controls 406B to JF5- KV4 Minimal Ignition Sources control JF5-LL8 Hot Work & Ignition Source Controls AFW flow to K45-YM3 Portable Extinguishers in zone Steam Generators

NL-11-007 Docket No. 50-286 Attachment 1 Page 18 of 50 LOcally ciose Aorea 5z Ltr11 /nt,-rL-L Low Fixed Combustible Loading supply breaker Zone 19A Pump JA4-PL2/2 Transient Combustible Controls for 32 K1B-WIB Minimal Ignition Sources Charging Hot Work & Ignition Source Controls Pump Portable Extinguishers in adjacent zone Hose station in adiacent zone Area PAB-2{5} Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} Area wide smoke detection Zone 58A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adiacent zone Locally control Area PAB-2{5} 32 Charging AH9-PL2 Low Fixed Combustible Loading 32 Charging Zone 19A Pump JA4-PL2/2 Transient Combustible Controls Pump using KZB-WAB Minimal Ignition Sources scoop tube Hot Work & Ignition Source Controls positioner Portable Extinguishers in adjacent zone I Hose station in adjacent zone

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 19 of 50 Area PAB- Exemption granted for App R III.G.2 Zone 17A Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} Area wide smoke detection Zone 58A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adiacent zone

NL-11-007 Docket No. 50-286 Attachment 1 Page 20 of 50 of the Credited OMAs Coment /Concluion Locally start 33 33 AFW Pump AK3-PT2 Intra-cable fault, Remote The exemption granted for this area AFW Pump from JB1-PT2/2 ground fault, open control (see Table RAI-01.1-1) acknowledges breaker on Bus JB1-X32/2 circuit capability for the minimal fire hazards of the area, 6A LL7-X32 the 33AFP and the effectiveness of the fire LQ7-X32 circuit breaker detection system and automatic X32-Y2J may be lost. sprinkler system, to minimize fire Pump may not damage in this area. The occurrence autostart or of a fire of sufficient severity and respond to scope to damage redundant AFW CCR controls. pump control cables and require implementation of this OMA is a low-likelihood event.

NL-11-007 Docket No. 50-286 Attachment 1 Page 21 of 50 Swap 32 CCW 32 CCW Pump Ab-WIU intra-caDle rauit, -resumes i nis area is equippea witn rtire Pump to alternate ground fault, open failures of detection and automatic sprinkler power supply or circuit cables serving systems as discussed in Table 01.1-1.

align city water redundant The occurrence of a fire of sufficient to Charging pumps CCW pumps severity and scope to damage all 31 and 33 due redundant CCW pump power cables, to fire damage and thereby require implementation of to power this OMA, is a low likelihood event.

cables in this area.

Operate 480V 31 AFW Pump A15-PT2 Intra-cable fault, Presumes This area is equipped with fire Bus 3A breaker JB1-PT2/1 ground fault, open concurrent detection and automatic sprinkler locally to start 31 JB1-X32/1 circuit failures of systems as discussed in Table 01.1-1.

AFW Pump cables serving The occurrence of a fire of sufficient redundant severity and scope to damage all AFW pumps redundant AFW pump power cables, 32 and 33 due and thereby require implementation of to fire damage this OMA, is a low likelihood event.

to cables in this area.

Locally operate FCV-1121 JB1-X32/1 Intra-cable fault, Miniflow This OMA is required only if a FCV-1121 in ground fault, open recirculation concurrent failure is sustained to all support of use of circuit, inter-cable flow may be AFW flow control valves FCV-406A 31 AFW Pump fault insufficient to through FCV-406D, resulting in 31AFW prevent pump pump potentially being operated under overheating minimum flow conditions. The

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 22 of 50 multiple concurrent failures necessary to render all AFW flow control valves failed closed is considered a low likelihood event, given the active fire protection features of the area, as described on Table RAI-01.1-1.

Operate HCV- HCV-1118 JB1-TA5 Intra-cable fault, HCV-1118 loss This OMA is only required if 32 AFW 1118 manually to ground fault, open of control from pump is selected as the credited control 32 AFW circuit, inter-cable CCR controls pump. If the above listed OMAs Pump fault associated with 31 AFW pump are implemented, this OMA is unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump.

Align Appendix 480V Bus 2A Cables of concern Intra-cable fault, Potential The use of the ARDG is credited for R Diesel 480V Bus 5A are not explicitly ground fault, open inability to supplying power to the 480V buses in Generator to identified by the circuit, inter-cable control offsite the event of a fire in Fire Area ETN-480V Buses 2A IP3 Safe- fault power supply 4{1} The need for implementation of 48V Be 2Shutdown and 5A Analysis breakers to this OMA would require loss of function emergency of 31 through 33 EDGs and a 480V concurrent loss of offsite power.

switchgear and tie This area is equipped with fire breakers detection and automatic sprinkler between systems as discussed in Table RAI-emergency 01.1-1. The occurrence of a fire of

NL-11-007 Docket No. 50-286 Attachment 1 Page 23 of 50 sufficient severity and scope to impair all redundant onsite power sources (other than the ARDG) and thereby require implementation of this OMA, is a low likelihood event.

Swap 31 or 32 31 Charging AQ3-K1C Intra-cable fault, Damage to In accordance with the IP3 fire Charging Pump Pump AQ3-PL2 ground fault, open control and/or response procedure (3-ONOP-FP-1),

to alternate 32 Charging JA2-PL2/1 circuit power cables 31 and 32 Charging Pumps are placed power supply Pump AH9-K1B for both in OFF/pullout upon detection of a fire AH9-PL2 charging in Fire Area ETN-4. This action can be JA4-PL2/2 pumps-may expected to preclude spurious pump render both starting, pending suppression of the charging fire and alignment of the selected pumps 31 and pump to an alternate power supply.

32 inoperable Given the active fire protection features of the area (smoke detection and automatic sprinkler protection for all cable trays) and absence of combustibles other than cables in cable trays, the occurrence of a fire of sufficient severity and scope to cause the described cable damage is considered to be of low likelihood. It is therefore expected that this OMA is unlikely to be required, for any credible fire scenario in Fire Area ETN-4{1}.

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 24 of 50 Locally operate FCV-4Ub[3 J 31-KVb intra-camle tault, I 1l7s UMA is only required it tire FCV-405B, FCV- FCV-405D JB1-KV8 ground fault, open fail closed, or damage occurs to cables serving ALL 405D, or FCV- FCV-406B JB1-SX1/1 circuit, inter-cable exhibit erratic AFW FCVs routed through this area.

406B to control JF5-KV4 fault operation. This area contains cables for FCV-405A AFW flow to JF5-LL8 through D and FCV-406A through D.

steam K45-YM3 The multiple concurrent failures generators K47-YM3 necessary to render all AFW flow control valves inoperable is considered a low likelihood event, given the active fire protection features of the area, as

- 4 4 .4- 4 described on Table RAI-01.1-1.

Locally open HCV-142 JB5-X1J Intra-cable fault, HCV-142 may If normally-open/throttled flow control valve 227 to ground fault, open spuriously valve HCV-142 is failed closed, the establish circuit, inter-cable close / fail normal makeup path to the RCS is charging fault closed, restored by locally opening manual makeup flow to isolating the valve 227.

RCS normal charging In light of the above described minimal makeup path hazards of the area and the active fire to the RCS protection features, fire-induced failure of this cable - and the need to implement this OMA -- is considered a low-likelihood event.

Locally close LCV-112B DK7-JB5 Intra-cable fault, Valves may In the event of damage to one of these valve LCV- LCV-112C DD4-JB5 ground fault, open spuriously cables, it can be reasonably be 112C; open circuit, inter-cable open or close, expected that the redundant (VCT valve 288 to fault or fail open or outlet or RWST outlet) valve would

NL-11-007 Docket No. 50-286 Attachment 1 Page 25 of 50 align charging ciosea remain operaDle, to proviae a pump suction to continued suction supply to the the RWST charging pumps. If both cables are damaged, causing maloperation of both valves, the OMA would require implementation.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of this cable - and the need to implement this OMA -- is considered a low-likelihood event.

Locally operate PCV-1139 JB1-PT2/3 Intra-cable fault, PCV-1139 loss This OMA is only required if 32 AFW PCV-1139 to ground fault, open of control from pump is selected as the credited ensure steam circuit, inter-cable CCR controls pump. If the above listed OMAs supply to 32 fault associated with 31 AFW pump are AFW pump implemented, this OMA is unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump.

Locally operate PCV-1310A JB1-S99 Intra-cable fault, Valves This OMA is only required if 32 AFW PCV-1310A, PCV-1310B JB1-X02 ground fault, open spuriously pump is selected as the credited 1310B to JB1-SZ6 circuit close or fail pump. If the above listed OMAs ensure steam JB1-X02/1 closed associated with 31 AFW pump are supply to 32 implemented, this OMA is

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 26 of 50 AFW pump unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump.

Locally STR PMP-31 CW8-XV2 Intra-cable fault, Loss of normal This OMA, if required, is limited to the manually STR PMP-32 DE1-XV2 ground fault, open power supply manual operation of only the single perform SW STR PMP-33 circuit to all SW SW strainer associated with the pump strainer STR PMP-34 strainer selected/operating SW pump.

backwash as STR PMP-35 control panels required STR PMP-36 The listed cables each provide power STR PMP-38 to three SW pump strainer control panels, and provide redundant feeds, via a throwover switch, for the backup SW control panel. Consequently, both cables must fail as the result of fire damage to render all SW pump strainers inoperable, and requiring the use of the OMA.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of both cables - and the need to-implement this OMA -- is considered a I I I low-likelihood event.

NL-11-007 Docket No. 50-286 Attachment 1 Page 27 of 50

~of the Credited OMAsK Operate HCV- intra-caDle rault, hlV-111I loss This OMA is only required if 32 AFW 1118 manually ground fault, open of control from pump is selected as the credited to control 32 circuit, inter-cable CCR controls pump. The IP3 Safe-Shutdown AFW pump fault Analysis reports no cables associated with the 31 AFW pump, its flow control valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

Locally operate PCV-1139 JB1-PT2/3 Intra-cable fault, PCV-1139 This OMA is only required if 32 AFW PCV-1139 to ground fault, open spuriously pump is selected as the credited ensure steam circuit, inter-cable closes or fails pump. The IP3 Safe-Shutdown supply to 32 fault closed Analysis reports no cables associated

NL-11-007 Docket No. 50-286 Attachment 1 Page 28 of 50 of the-Credited OMAs with the 31 AFW pump, its flow control valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

Locally operate PCV-1310A JB1-S99 Intra-cable fault, PCV-1310A This OMA is only required if 32 AFW PCV-1310A, PCV-1310B JB1-X02 ground fault, open and/or PCV- pump is selected as the credited PCV-1310B to JB1-SZ6 circuit 1310B (series pump. The IP3 Safe-Shutdown ensure steam JB1-X02/1 valves) Analysis reports no cables associated supply to 32 spuriously with the 31 AFW pump, its flow control AFW pump close or fail valves (FCV-406A, FCV-406B), or closed power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 29 of 50 area tor monitoring bu level is triat tot 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage.

In light of-the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

Locally operate FCV-405C JB1-KV7 Intra-cable fault, FCV-405C, This OMA is only required if 32 AFW FCV-405C, FCV- FCV-405D JB1-KV8 ground fault, open FCV-405D pump is selected as the credited 405D to control circuit, inter-cable spuriously pump. The IP3 Safe-Shutdown AFW flow to fault close or open Analysis reports no cables associated steam with the 31 AFW pump, its flow control generators valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire

NL-11-007 Docket No. 50-286 Attachment 1 Page 30 of 50 UdIIld*y.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

I

NL-11-007 Docket No. 50-286 Attachment 1 Page 31 of 50 of the Credited OMAs.

Coments / Conclusio LULdIly LlIUb LCV-112C DK7-VN3/1 Intra-cable fault, Valves may Selective cable failure modes may valve LCV-112C LCV-112B DK7-VN3/2 ground fault, open spuriously result in a sustained functional and open valve DD4-VN3 circuit, inter-cable close or open charging pump suction path, or may 288 to align fault result in isolation of all charging pump charging pump suction. Control room operator action suction path to taken in accordance with fire response Refueling Water procedure 3-ONOP-FP-1 will secure 31 Storage Tank and 32 Charging Pumps in pullout, (RWST) upon detection of a fire in this area, precluding spurious pump starts, and ensuring pumps remain free of fire damage until a reliable suction path can be aligned.

In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is I L considered a low-likelihood event.

NL-11-007 Docket No. 50-286 Attachment 1 Page 32 of 50 LOULdily LlUS .3_ ,-n/-l m-I-rLZ iIILrd-LdUlIe IdUIL,. 32 Charging This OMA is required if a fire in this supply breaker PUMP JA4-PL2/2 ground fault, open Pump is area causes damage to cables serving for 32 charging KIB-WlB circuit rendered both 31 and 32 Charging Pumps, pump inoperable which are both equipped with alternate from remote power source capabilities via transfer electrical switches.

controls The defense in depth fire protection features of this area, in concert with the Locally control 32 Charging AH9-PL2 Intra-cable fault, 32 Charging This OMA is required only if a fire in 32 charging Pump JA4-PL2/2 ground fault, open Pump electro- this area causes damage to cables pump using KIB-WlB circuit, inter-cable pneumatic serving both 31 and 32 Charging scoop tube fault speed Pumps, which are both equipped with positioner controller fails alternate power source capabilities via to maintain transfer switches.

required pump speed Open valve 227 HCV-142 JB5-X1J Intra-cable fault, HCV-142 may If normally-open/throttled flow control to establish VK4-XIJ ground fault, open spuriously valve HCV-142 is failed closed, the charging circuit, inter-cable close / fail normal makeup path to the RCS is flowpath to RCS fault closed, restored by locally opening manual around isolating the valve 227.

potentially normal failed closed charging Despite the potential spurious closure HCV-142 makeup path of HCV-142, isolating the normal

NL-11-007 Docket No. 50-286 Attachment 1 Page 33 of 50 cflarging makeup patl to the RCS, it can be expected that limited makeup to the RCS would continue, via the RCP seal injection flowpath, which is not impacted by the closure of HCV-142.

Locally close LCV-112C DK7-VN5 Intra-cable fault, Valves may Selective cable failure modes may LCV-112C and LCV-112B DD4-VN5/1 ground fault, open spuriously result in a sustained functional open valve 288 DD4-VN5/2 circuit, inter-cable close or open charging pump suction path, or may to establish fault result in isolation of all charging pump flowpath from suction. Control room operator action RWST to taken in accordance with fire response charging pump procedure 3-ONOP-FP-1 will secure 31 suction and 32 Charging Pumps in pullout, upon detection of a fire in this area, precluding spurious pump starts, and ensuring pumps remain free of fire damage until a reliable suction path can be aligned.

NL-11-007 Docket No. 50-286 Attachment 1 Page 34 of 50 Locally operate Intra-cable fault, Valve This OMA is required only it FCV-1121 (bypass valve ground fault, open spuriously fails closed and all AFW flow control for) FCV-1121 circuit, inter-cable closes or fails valves FCV-406A through 406D fail AFW pump fault closed closed, as the result of fire damage to reci rcu lation cables in this fire area. This valve during combination of failures would result in pump startup an inadequate recirculation flowpath to preclude AFW pump overheating, thereby requiring the OMA to be performed. The multiple concurrent failures necessary, and the minimal hazards and ignition sources of the zones traversed by these cables renders the need to implement this OMA a low-likelihood event.

Locally operate FCV-406A JB1-SX1/1 Intra-cable fault, Valves This OMA is required only if all steam FCV-406A, FCV-406B JF5-KV3 ground fault, open spuriously generator level channels associated 406B to control JF5-KV4 circuit, inter-cable open or fail with SG 33 and 34 are rendered AFW flow to JF5-LL8 fault closed inoperable by fire damage, and/or Steam K45-YM3 both 33 AFW pump, its flow control Generators valves (FCV-406C and D), and 32 AFW pump, its steam supply, control valve (PCV-1310A, PCV-1310B, PCV-1139, HCV-1118) and flow control valves (FCV-405A through D) are also rendered inoperable by fire damage in

NL- 11-007 Docket No. 50-286 Attachment 1 Page 35 of 50 tnis area.

Given the minimal fixed combustibles and ignition sources in the impact fire zones of Fire Area TBL-5, as described on Table RAI-01.1-1, a fire of sufficient severity and scope to cause the necessary extent of damage in this zone is considered a low-likelihood event.

Locally STR PMP-31 AH2-WF6/2 Intra-cable fault, Loss of normal This OMA, if required, is limited to the

/manually STR PMP-32 AJ7-WF6 ground fault, open power supply manual operation of only the single backwash SW STR PMP-33 AQ7-WF6 circuit to all SW SW strainer associated with the pump strainer STR PMP-34 AT6-WF6/2 strainer selected/operating SW pump.

as required if STR PMP-35 WF6-Z99 control panels power to STR PMP-36 WK9-XV8 The multiple fire-induced cable failures strainer WQ9-XV2 necessary to disable all SW strainers, associated with XV2-XV8 in consideration of the characteristics selected SW of the fire zones through which the pump is lost cables are routed (reference Table (use one of STR RAI-01.1-1) renders the need to PMP-31 through implement this OMA a low-likelihood STR PMP 36). event.

NL-11-007 Docket No. 50-286 Attachment 1 Page 36 of 50 of the CreditedO s Co ents Conclusion Locally start SWS PMP-31 AQ8-M59 Intra-cable fault, Pump may The use of the 38 Service Water Pump ARDG to supply SWS PMP-32 AT6-M61 ground fault, open rendered is credited in the unlikely event that a MCC312A in SWS PMP-33 AJ8-M62 circuit inoperable fire in this area causes sufficient support of the SWS PMP-34 AQ7-M63 damage to cables and/or components use of SW SWS PMP-35 AH2-M64 to render all normal service water Pump 38 SWS PMP-36 AJ7-M65 pumps (31 through 36) inoperable. As a concurrent loss of offsite power is postulated, the ARDG (which has self-contained cooling) is credited to power 38 SWP, as this pump by design does not provide sufficient capacity for cooling of one of the safety-related diesel generators, 31, 32, or 33EDG.

As this OMA is necessary only in the event of a large fire event that could disable all normal (31 through 36 Service Water Pumps, concurrent with a loss of offsite power, the need to implement this OMA is considered to be a low-likelihood event.

Locally/manuall STR PMP-31 AH2-WF6/2 Intra-cable fault, Loss of normal This OMA, if required, is limited to the y backwash SW STR PMP-32 AJ7-WF6 ground fault, open power supply manual operation of only the single pump strainer if STR PMP-33 AQ7-WF6 circuit to all SW SW strainer associated with the power to STR PMP-34 AT6-WF6/2 strainer selected/operating SW pump.

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 37 of 50 I,P3 Fire Area YARD-'7 MW6-P2K control panels strainer STR PMP-35 MW7-P2L The multiple fire-induced cas associated with STR PMP-36 MW8-P2M necessary to disable all SW s le failures selected SW STR PMP-38 MW9-P2N in consideration of the charaatrainers, pump is lost cteristics MX7-P2P of the fire routedthrough are zones whi (reference MX a-P2Q cables ch the Table MY1-PY1 RAI-01.1-1) renders the nee(d to P2K-P2M/1 Aow-li implement this OMA a P2K-WQ9 event. kelihood P2K-XL1 P2K-Z99 P2K-P2M/1 P2L-P2N/1 P2L-W14 P2L-XL1 P2L-Z99 P2L-P2N/1 P2M-P2P/1 P2M-XL2 P2M-Z99 P2N-P2Q/1 P2N-XL2 P2N-Z99 P2P-XL3 P2P-Z99 P2Q-XL3 P20-Z99 a a u .1. L _______________________________________________

NL-11-007 Docket No. 50-286 Attachment 1 Page 38 of 50 PY1-XV2/1 WF6-Z99 WK9-W14 WK9-XV8 WQ9-XV2 XL1-YW2 XL1-YW3 XL2-YW5 XL3-YW6 XL3-YW7 XV2-XV8

NL-11-007 Docket No. 50-286 Attachment 1 Page 39 of 50 RAI-01.2 The September 29, 2010, response indicates that LCV-1 12C could fail open as a result of fire damage. With continued operation of the charging pump in this scenario, draindown of the VCT could occur resulting in the introduction of hydrogen into the pump suction, damaging the pump. However, it is not clear if potential impact of this failure mode has been fully assessed in the request. Provide information which clearly demonstrates that LCV-1 12C failing in the open position has been fully evaluated for its impact on the ability to achieve and maintain hot shutdown. For fire areas where LCV-1 12C is found to be vulnerable to this failure mode, the response should also include information requested in the RAI above.

RAI 01.2 RESPONSE Failure of LCV-1 12C in the open position (its normal position during plant power operation) could result in unintended drain-down of the VCT (Volume Control Tank) and consequent damage to a running charging pump, if the VCT inventory is exhausted, and cover gas is drawn into the positive-displacement charging pump suction. For this scenario to exist, LCV-112C must fail open, normally-closed alternate suction valve LCV-1 12B must also fail to automatically open in response to a VCT level signal, AND automatic replenishment of VCT level must be terminated, through deliberate or fire-induced isolation of all letdown flow, and fire-induced loss of the VCT automatic makeup function.

The VCT automatic makeup function is an element of the Chemical and Volume Control System (CVCS) that is not credited in the Appendix R post-fire safe-shutdown analysis, and hence the supporting equipment (e.g., primary water pumps, boric acid transfer pumps, boric acid blender, etc.) is conservatively assumed to be rendered inoperable as the result of nonspecific fire damage to cables and/or components. The VCT is also replenished through recycling of the CVCS letdown flow, and additional fire-induced cable failures would be necessary to also spuriously close the letdown isolation and/or letdown orifice valves, thereby terminating this source of continual VCT replenishment. Under these conditions of concurrent or sequential multiple spurious operations, combined with fire-induced failure of LCV-1 12C in the open position, the running charging pump could conceivably be exposed to a condition wherein the VCT inventory is drawn down and hydrogen cover gas is introduced into the pump suction, resulting in gas binding and potential pump damage. However, the number of multiple concurrent fire-induced failures necessary to create this condition is substantial, and the occurrence of all of the necessary failures simultaneously, or in succession, for the credible fire scenarios in the fire area of concern, is a low-likelihood event.

As described in the September 29, 2010 response, plant operating procedures have been revised to include direction to promptly secure the credited charging pump upon detection of a fire in plant areas containing cables associated with charging pump controls and charging suction valves LCV-1 12C and LCV-1 12B. By promptly securing the designated charging pump for the specific fire area of concern, the failure of LCV-1 12C in the open position -

concurrent with loss of all VCT auto makeup function - would not challenge the credited charging pump.

NL-11-007 Docket No. 50-286 Attachment 1 Page 40 of 50 As also noted in the September 29, 2010 response, notwithstanding securing the credited charging pump by placing the central control room (CCR) switch in "pullout," the charging pump control cable, downstream of the CCR switch, presents a limited potential for fire damage to that cable to cause a spurious start of the charging pump, thereby presenting a potential damage concern, if LCV-1 12C has failed closed and LCV-1 12B has failed to automatically open as designed. However, following further review, it has been determined that the previously provided information relative to a spurious restart of the charging pump was unduly conservative, in light of the protective features integral to the charging pump circuit breaker. Therefore, clarification is provided relative to the potential fire-induced initiation of a spurious charging pump start signal, in the response to RAI-01.3.

In light of the above, and the charging pump circuit breaker protective features described in the response to RAI-01.3, the control room operator action to place the credited charging pump in pullout will provide an effective means of protection for the charging pump, by ensuring that it will remain deenergized and "locked out' until it is restored to service in accordance with the post-fire safe-shutdown procedural guidance. Thus, any spurious isolation, or failing open, of the charging pump suction path will have no impact on the credited charging pump, following securing the pump in response to detection of a fire in the associated plant area.

In response to the six elements identified in RAI-01 -1 and their applicability to the potential fire-induced failure mode of LCV-1 12C wherein the valve could be failed in the open position:

1. all cables that could cause components of concern to spuriouslystart, stop, change position, become damaged or otherwise fail in an undesiredmanner for hot shutdown.

The cables associated with LCV-1 12C and routed through the fire area of concern that could result in a failed-open valve condition, if these cables are subject to fire damage are listed on Table RAI-01.1-1 and are summarized below:

" DD4-VN5/1: For the range of potential fire-induced failure modes of this cable, which is the three-phase power cable to the valve operator, the credible potential effect on LCV-1 12C is to fail the valve open (its normal position), and unable to be repositioned by remote electrical controls.

" DD4-VN5/2: For the range of potential fire-induced failure modes, the potential effect on LCV-1 12C is to fail the valve open or closed, and unable to be repositioned by remote electrical controls.

" DD4-VN3: For the range of potential fire-induced failure modes, this interlock cable from redundant charging pump suction valve LCV-1 12B may fail LCV-1 12C closed and unable to be opened electrically.

• DD4-JB5: For the range of potential fire-induced failure modes, the potential effect on LCV-1 12C is to fail the valve open or closed, and unable to be operated electrically.

The potential effects of fire-induced failures of the above listed cables are discussed in detail in the response to RAI 01.1 of Entergy's September 29, 2010 submittal.

NL-11-007 Docket No. 50-286 Attachment 1 Page 41 of 50

2. the routing of these cables within each of the fire areas identified in the request, The physical routing of the above listed cables in the fire areas of concern is provided in the response to RAI 02.1 in Entergy's September 29, 2010 submittal.

3. the proximity of the identified cables of concern to each other (in feet and inches),

LCV-1 12C is the sole VCT outlet valve, but a redundant charging pump suction capability is provided by RWST suction path valve LCV-1 12B. Cables associated with both LCV-1 12C and LCV-1 12B are routed Fire Areas ETN-4{1}, PAB-2{3}, and PAB-2{5}. Details of the routing of the LCV-1 12C circuits in the listed fire areas are provided in Entergy's September 29, 2010 submittal. However, as described in the response to Question (6) below, not all potential fire-induced failures of these, and additional LCV-1 12B cables as listed below, can be expected to result in the disabling of both LCV-112C and LCV-112B.

4. the type of cable faults requiredto cause the component(s) to fail in an undesired manner for post-fire safe shutdown, The potential effects of fire-induced failures of the above listed cables are discussed in detail in the response to RAI 01.1 of Entergy's September 29, 2010 submittal. Failure modes considered include open circuit, intra-cable short circuit, ground faults, and inter-cable hot shorts. As discussed in the referenced September 29, 2010 response, each of the postulated failure modes for the above listed cables presents the potential for causing LCV-1 12C to fail in a potentially undesired condition.

5. the spatial relationshipof each cable to potential ignition sources and/or high energy arcing faults, and As described in the response to RAI-02.1 in Entergy's September 29, 2010 submittal, in the fire area of concern, the above listed cables are routed through fire zones containing ignition sources consisting of electrical cabinets, which in turn consist primarily of control cabinets, small dry-type transformers, and a charging pump motor.

Separation distances to these electrical cabinets are described in the response to RAI-02.1 in Entergy's September 29, 2010 submittal. There are no ignition sources in the fire zones through which these cables are routed that present the potential for high-energy arcing faults (HEAF), consistent with the HEAF binning criteria of NUREG-6850, Vol. II, Appendix M, and FAQ 06-0017.

6. any otherplant specific features that serve to minimize the likelihood of the undesired event.

As discussed above, the minimal fire hazards and smoke detection system in the fire zones of concern, with the exception of Fire Zone 27A, provide reasonable assurance that a fire of sufficient severity to cause damage to the multiple cables that could

NL-11-007 Docket No. 50-286 Attachment 1 Page 42 of 50 isolate both charging suction paths, disable all VCT replenishment functions, and spuriously restart the credited charging pump is an unlikely event. A fire event that simply causes LCV-1 12C to fail open and LCV-1 12B to fail closed - but does not disable all VCT inventory replenishment means - does not present a prompt damage concern for the credited charging pump. The proactive control room operator action to secure the credited charging pump upon receipt of an alarm from the smoke detection system, combined with the circuit breaker protective features described in the response to RAI-01.3, provide reasonable assurance that the credited charging pump will remain free of fire-induced damage until a reliable suction source can be aligned (via the requested OMA) and the charging pump returned to service, in accordance with established post-fire safe-shutdown procedures.

As summarized on Table RAI-01.1-1, with the exception of Fire Zone 27A, the fire zones within Fire Areas ETN-4{1}, PAB-2{3}, and PAB-2{5} which the above listed LCV-1 12C and LCV-1 12B cables are routed are all equipped with smoke detection systems, providing assurance of prompt notification to the control room operators of a fire condition, and enabling the timely securing of the credited charging pump. Fire Zone 27A, the PAB corridor area containing LCV-1 12C, is not equipped with smoke detectors, but contains minimal fixed combustibles and ignition sources.

Therefore, a fire in this zone capable of causing damage to the LCV-1 12C cables of concern routed through the zone, DD4-VN5/1 and DD4-VN5/2, is considered a low-likelihood event.

Based on the above, in light of the fire detection systems in or immediately adjacent to the above described fire zones, the procedural guidance to promptly secure the credited charging pump, there is reasonable assurance that failure of LCV-1 12C in the open (normal) position, loss of all VCT inventory replenishment functions, and concurrent or sequential cable damage causing a spurious restart of the selected charging pump is a low-likelihood event.

RAI-01.3 Several inconsistencies were noted in the September 29, 2010, response regarding the capability of operator actions to prevent pump damage by proactively shutting down the required/credited charging pump. Specific examples include:

1. Response to RAI 01.1 Item 1 (page 2) which states: If, the required/credited charging pump has been shut down proactively, no damage to the pump will occur.

2. Response to RAI 01.1 Item 5 (page 8) which states, in part: The pump is secured by placing the control room control switch in OFF and pullout. This action will stop 21 Charging Pump, to protect against any damage that could be caused by a spontaneous loss of all suction paths. Despite placing 21 Charging Pump in OFF/pullout, ... an internal conductor-to-conductor fault on the 21 Charging Pump control cable(s) could result in a spurious start of 21 Charging Pump.

3. Response to RAI 07.1, which states, in part: This potential failure mode is mitigated by procedural guidance to secure the charging pump in the event of a confirmed fire

NL-11-007 Docket No. 50-286 Attachment 1 Page 43 of 50 condition and to start another charging pump to support continued operation until the proper response to the fire condition is assessed. In this way, the charging pump will be protected from any damage scenario that may be caused by spurious loss of pump suction sources.

In summary, although the responses provided for RAI 01.1 (Item 1) and RAI 07.1 indicate that the control room action will preclude damage to the charging pump, the response to RAI 01.1 (Item 5) indicates that pump damage may still occur. Provide further clarification of the capability of this action to preclude pump damage. Where this action is credited, provide a detailed discussion of any plant-specific features which serve to minimize the likelihood of fire damage to all cables of concern.

RAI-01.3 RESPONSE The described operator action to secure the credited charging pumps and place the pump control switches in "pullout" is a control room operator action, and not subject to consideration as an OMA in the context of Appendix R Paragraph III.G.2.

As described in the September 29, 2010 response, plant operating procedures have been revised to include guidance to promptly secure the credited charging pumps upon detection of a fire in plant areas containing cables associated with charging pump controls and charging suction valves LCV-1 12C and LCV-1 12B. By promptly securing the designated charging pumps for the specific fire area of concern, the fire-induced spurious isolation of all charging pump suction paths will not challenge the credited charging pump. The purpose of the proactive proceduralized response to secure the credited charging pump is to promptly remove the pumps from operation, to minimize the potential for prompt pump damage that could be experienced if all suction is spontaneously isolated while the positive-displacement pump is running. A comparable concern may exist in the event that LCV-1 12C fails open due to fire damage to control cables, concurrent with failure of LCV-1 12B to automatically open, with the concurrent fire-induced loss of all VCT automatic makeup functions. Under these conditions, pump damage could occur as the result of gas binding as VCT cover gas is drawn into the pump, following drain-down of the VCT.

As also described in the September 29, 2010 response, notwithstanding securing the credited charging pumps by placing the central control room (CCR) switch in "OFF/pullout," the charging pump control cable, downstream of the CCR control switch, presents the potential for fire damage to that cable to initiate a spurious start signal to the charging pump, thereby creating a potential pump damage concern, under the postulated conditions of loss of a viable pump suction source.

However, following further review, Entergy has determined that the information provided in the September 29, 2010 response relative to the potential for a spurious restart of the charging pump is unduly conservative, in light of the protective features integral to the circuit breaker.

While the potential exists for generation of a spurious pump start signal, the potential for actual starting of the pump is virtually nil. The following clarification is provided relative to the potential fire-induced initiation of a spurious pump start signal:

NL-11-007 Docket No. 50-286 Attachment 1 Page 44 of 50 The 480V circuit breakers supplying all three charging pumps are Westinghouse DS circuit breakers, which are provided with an "anti-pump" feature as discussed below, and this feature can be expected to ensure that spurious restart of the charging pump will not occur. A review of elementary wiring diagram 500B971, Sheet 26, Revision 10 and 500B971, Sheet 72, Revision 10, and elementary wiring diagram switch development 5008971, Sheet 9, Revision 4 confirms that when the 31 or 32 Charging Pump CCR control switch is placed in "pullout," several conductors of the control cable remain energized with 125VDC control power, to maintain operation of the breaker position/status indicating light and to maintain the breaker trip logic energized. With the breaker in the tripped (open) position, a normally-open auxiliary contact in series with the trip coil maintains the trip coil deenergized.

In the event of a fire-induced intra-cable (conductor-to-conductor) fault, one or more of the normally energized conductors may contact the conductor(s) associated with the breaker closing circuit, potentially energizing the closing coil. However, in this event, the closing of the breaker will simultaneously cause the closure of the above described auxiliary contact, thereby energizing the breaker trip coil. The breaker close signal will immediately be countermanded by the trip signal, and within one or two cycles, the electromechanical "anti-pump" feature will mechanically lock the breaker in the open/tripped position. Any further spurious or intentional pump start signals will have no effect on the breaker position. It will remain tripped/open until manually reset. The electromechanical components associated with the protective anti-pump feature are located at the circuit breaker cubicle, in the 480V Switchgear Room (Fire Area CTL-3), a III.G.3 fire area, and are not subject to damage or maloperation as a result of a fire in any other fire area.

The potential fire-induced cable failure(s) considered, and the resultant potential effects, include the following:

• Intra-cable conductor-to-conductor fault: energized conductor(s) within the cable may contact the normally deenergized conductor serving the breaker closing coil, as described above. The described anti-pump feature ensures that the breaker is mechanically locked out and precluded from closing, despite any subsequent spurious close signals.

• Ground fault: No effect on breaker closing circuit would be expected, as the breaker control logic is powered by an ungrounded 125VDC supply. Multiple concurrent ground faults could potentially result in blowing of the control circuit control power fuses, leaving the breaker in the open/tripped position, and rendering the breaker not vulnerable to further spurious close signals.

" Inter-cable hot short: The closing circuit may be spuriously energized, but the trip circuitry and anti-pump feature can be expected to continue to function as described above. This failure mode is considered unlikely, given that it would be necessary to experience a proper-polarity 125VDC external hot short to energize the breaker closing coil, requiring faults on two separate conductors to complete the circuit.

NL-11-007 Docket No. 50-286 Attachment 1 Page 45 of 50 Open circuit failure: This low-credibility failure mode could result in the circuit to the closing coil being rendered inoperable (and therefore spurious closing of the breaker would not be possible); and/or the circuit to the trip coil could be rendered inoperable, thereby impacting the described protective anti-pump feature. While open-circuit failures must be postulated and evaluated as required by Appendix R Paragraph Ill.G, as noted in NEI 00-01, Rev. 2, the cable fire testing performed to date has not identified open-circuit failures as a credible primary cable failure mode. Therefore, a selective fire-induced failure mode in which the circuit breaker close circuit conductors would remain intact, while the trip circuit conductors would fail open, is considered to be an exceedingly unlikely scenario.

In light of the above, the previously described control room, operator action to place the credited charging pump in pullout will provide an effective means of protection for the charging pump, by ensuring that it will remain deenergized and "locked out' until it is restored to service in accordance with the post-fire safe-shutdown procedural guidance.

Thus, a fire-induced spurious isolation of the charging pump suction path will have no impact on the credited charging pump, following securing the pump in response to detection of a fire in the associated plant area.

It should be noted that during plant power operation, only one of the three charging pumps is in operation at any given time. IPEC operational practice is to rotate the usage of all three pumps, such that over a plant operating cycle, each pump experiences a comparable period of operation. In the event of a fire scenario as discussed herein, at most one charging pump would be in operation, and potentially vulnerable to fire-induced failures of the normal and alternate charging suction paths.

In addition to credited control room action to secure the 31 and 32 Charging Pumps, which is considered to provide reliable and effective protection of the pump and associated safe-shutdown capability - despite fire damage to cables -- the likelihood of concurrent or sequential fire-induced cable damage to cause spurious pump start signals and failure of the charging pump suction path is considered to be low. The fire zones containing control cables for the 31 and 32 Charging Pump and charging pump suction valves LCV-1 12C and LCV-1 12B are characterized by low combustible loading, insubstantial ignition sources, and the presence of a smoke detection system in the fire zones of concern, with the exception of Fire Zone 27A, as discussed above. The active and passive fire protection features, and other mitigating factors associated with these fire zones are presented herein in summary form by Table RAI-01.1-1. Given these features, Entergy believes there is reasonable assurance that a fire scenario of sufficient size, scope, and rapidity of development, capable of challenging not only the 31 and 32 Charging Pumps, but also the remaining charging pump, the charging suction valves, and sufficient other plant equipment, so as to require substantial implementation of the post-fire safe-shutdown capability, is a low-likelihood event. The proceduralized control room operator action to secure the credited (31 or 32) charging pump upon detection of a fire in the area of concern is considered to be a reliable and effective means of preventing spurious

NL-11-007 Docket No. 50-286 Attachment 1 Page 46 of 50 restarting of the pump, during a fire scenario that presents the potential for spuriously isolating all charging pump suction sources.

RAI-01.4 The September 29, 2010, response indicates that Cable YZ1-JB5, provides the interlock between the refueling water storage tank (RWST) outlet valve LCV-1 12B and (under normal operating conditions) an inter-cable (cable to cable) Hot Short would be required to cause LCV-1 12C to spuriously close. However, the response does not clearly identify circuit faults that would be required to prevent normally-closed RWST outlet valve LCV-1 12B from opening automatically as designed in response to a close signal from LCV-1 12C. Identify the cables of concern, and describe their routing, type of cable faults (Open, Short to ground, inter-cable hot short or intra-cable hot short) required to prevent the normally-closed RWST outlet valve LCV-1 12B from automatically opening, and the proximity to other cables that, in conjunction with fire damage to this cable(s) could result in a loss of all charging suction (e.g. LCV-1 12C control cables).

RAI-01.4 RESPONSE Valves LCV-1 12C and LCV-1 12B provide for redundant suction sources to the charging pumps, with motor-operated valve LCV-1 12C, the VCT outlet valve, normally open, and providing suction to the operating charging pump. LCV-1 12B, a motor-operated valve that provides an alternate charging pump suction path from the RWST. Valve LCV-1 12B will fail as is on loss of power. Valve LCV-1 12B is normally maintained closed, and is automatically opened in response to a VCT low-level signal. -Upon receipt of the automatic open signal, LCV-1 12B will travel to the full-open position, to establish suction from the RWST. Upon reaching the full-open position, a limit switch on LCV-1 12B provides an interlock to LCV-1 12C that will cause LCV-1 12C to close. Alternatively, LCV-1 12B can be expected to automatically open in response to LCV-1 12C being moved off the full-open position.

Conversely, as VCT level is restored, LCV-1 12C will receive an open signal, and upon reaching the full-open position, a limit switch on LCV-1 12C provides an interlock to LCV-1 12B that will cause LCV-1 12B to close.

The cables of concern associated with LCV-1 12C and interfacing with LCV-1 12B, as given by drawing 9321 -LL-31263, Sheet 133A, Revision 8, and routed through the fire areas of concern (ETN-4{1}, PAB-2{31, and PAB-2{5}) are as follows:

LCV-1 12C: DD4-JB5, DD4-VN3, DD4-VN5/1, DD4-VN5/2 LCV-1 12B: DK7-JB5, DK7-VN5, DK7-VN3/1, DK7-VN3/2 The physical routing of the above listed LCV-1 12C cables is discussed in detail in the response to RAI-01.1 as presented in Entergy's September 29, 2010 submittal. The cables of concern routed through Fire Areas ETN-4{1}, PAB-2(31, and PAB-2{5}and their potential fire-

NL-11-007 Docket No. 50-286 Attachment 1 Page 47 of 50 induced failure modes and effects on redundant charging pump suction valves LCV-1 12C and LCV-1 12B, are summarized below.

Potential Potential Net Effect on Cable Failure Mode LCV-1 12C LCV-1 12B Charging Effects Effects Operability DD4-JB5 Ground fault, Fails open or Valve can be LCV-1 12B can be blowing control spuriously expected to expected to provide power fuse, intra- closed remain available continued suction cable fault, open to auto open, if to charging pump, circuit LCV-1 12C were prior to operators to travel off the securing the pump full-open per procedure.

position (via interlock contact). The auto-open function would only be impaired in the event of conductors failing open due to fire damage.

DD4-VN3 Intra-cable fault, May fail to None LCV-1 12B can be ground fault, open automatically expected to circuit, inter-cable open/close automatically fault when required, provide an as this cable alternate charging provides source, prior to interlock operators securing between LCV- the pump per 112B and LCV- procedure.

112C.

DD4-VN5/1 Intra-cable fault, Damage to this No effect on LCV-1 12B can be ground fault, open three-phase LCV-1 12B level expected to circuit power cable will control circuit. automatically cause the valve LCV-1 12B can provide an to fail as is, in be expected to alternate charging the normally open in source, prior to open position. response to a operators securing low VCT level the pump per signal. procedure.

NL-11-007 Docket No. 50-286 Attachment 1 Page 48 of 50 Potential Potential Net Effect on Cable Failure Mode LCV-112C LCV-112B Charging Effects Effects Operability DD4-VN5/2 Intra-cable or Remains Valve can be LCV-1 12C may inter-cable fault, open/failed expected to auto spuriously close or energizing open open, or may open based on fail open; LCV-or close spuriously close movement of 112B can be contactor, or LCV-1 12C off expected to auto blowing control the full-open open in response power fuse position (via to interlock contact, interlock actuated when contact). The LCV-1 12C moves auto-open off the full-open function would position, providing only be impaired a sustained suction in the event of source, prior to conductors operators securing failing open due the pump per to fire damage. procedure.

DK7-JB5 Ground fault, LCV-112C can Fails open or LCV-112C can be blowing control be expected to spuriously expected to remain power fuse, intra- remain closed open/operable, cable fault, open open/operable, providing continued circuit, inter-cable providing suction to charging fault continued pump, prior to suction to operators securing charging pump, the pump per prior to procedure.

operators securing the pump per procedure.

DK7-VN3/1 Intra-cable fault, No effect on Damage to this LCV-1 12C can be ground fault, open LCV-1 12C level three-phase expected to circuit control circuit. power cable will continue to provide LCV-1 12C can cause the valve an effective be expected to to fail as is, in charging source, open in the normally prior to operators response to a closed position. securing the pump low VCT level per procedure.

signal.

NL-1 1-007 Docket No. 50-286 Attachment 1 Page 49 of 50 Potential Potential Net Effect on Cable Failure Mode LCV-1 12C LCV-1 12B Charging Effects Effects Operability DK7-VN3/2 Intra-cable or Valve can be Remains LCV-1 12C can be inter-cable fault, expected to auto closed/failed expected to energizing open open (if not closed, or may continue to provide or close already open, its spuriously open. an effective contactor, or normal position) charging source, blowing control based on prior to operators power fuse movement of securing the pump LCV-1 12B off per procedure.

the full-open position (via interlock contact). The auto-open function would only be impaired in the event of conductors failing open due to fire damage.

DK7-VN5 Intra-cable fault, None May fail to LCV-1 12C can be ground fault, open automatically expected to provide circuit, inter-cable open/close a charging suction fault when required, source, prior to as this cable operators securing provides the pump per interlock procedure.

between LCV-112B and LCV-112C As discussed in the September 29, 2010 response, post-fire safe-shutdown operating procedures include direction to secure the credited charging pumps, upon receipt of a fire alarm in any of the plant areas of concern. Upon securing the credited charging pumps, the potential loss of all suction sources will not challenge the credited pumps, one of which will be restarted per the post-fire safe-shutdown procedure, following manual alignment of charging pump suction to the RWST, by locally opening manual valve 288. Given that the credited charging pumps are secured promptly via operator action in the CCR, the remaining concern is that fire-induced damage to the charging pump control cable(s), downstream of the CCR control switch, should not present the potential for spurious restart of the pump, concurrent with spurious closure of both charging suction valves LCV-1 12C and LCV-1 12B. That

NL-11-007 Docket No. 50-286 Attachment 1 Page 50 of 50 concern is addressed by the circuit breaker control circuit protective features as described above.

In light of the above, the following conclusions apply: (1) it is unlikely that a fire of sufficient size and rapidity of development will occur, to challenge both charging pump suction capabilities, (2) with the charging pump control room control placed in pullout, spurious start signals can be expected to be locked out and have no effect on the secured pump motors.

In summary, concurrent or sequential loss of all suction sources AND a spurious start of the credited charging pump, thereby leading to potential pump damage, is considered to be a low likelihood event.

ATTACHMENT 2 TO ENTERGY LETTER NL-1 1-007 New Material to Support the Response to December 16, 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-11-007 Docket No. 50-286 Attachment 2 Page 1 of 9 The information provided in this attachment supports the responses to the RAI questions in . The cable routing information belongs in the RAI-01.1 Response and-the RAI-02.1 Response in Entergy Letter NL-10-101, dated September 29, 2010. Additions are indicated by underlined text and deletions by strikethrough. The tables RAI-GEN-24, RAI-GEN-25, and RAI-GEN-26 belong with the RAI-GEN-xx tables that were provided in the RAI-02.2 Response in Entergy Letter NL-10-043, dated May 4, 2010.

CABLE ROUTING INFORMATION DELETE the existing section in the RAI-01.1 RESPONSE titled "Fire Zone 6 - 32 Charging Pump Room" and REPLACE with the following:

Fire Zone 6_32 Charging Pump Room and Fire Zone 17A, PAB 55' Corridor Cable DD4-VN5/1 for LCV-1 12C is located in zone 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising vertically to the cable tray then turning south for approximately 13 ft and then east for approximately 50 ft then turning up and penetrating the ceiling approximately 16 ft above the floor and into the zone above.

Ignition sources in the zone located less than 20 ft horizontally from the cable consist of the MCC panels, lighting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power panels are separated from the cable by greater than approximately 7.4 ft horizontally. Two electrical cabinets are located under the cable routing separated by greater than 3.5 ft vertically. The rest of the electrical cabinets are separated from the cable by greater than 10 ft horizontally. There are no intervening combustibles between the identified ignition sources and the cable.

Cable DD4-VN5/2 for LCV-1 12C is located in zone 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising Vertically to the cable tray then turninq south for approximately 16 ft and then east for approximately 100 ft and then turning up penetrating the ceiling approximately 16 ft above the floor and into the zone above. Ignition sources in the zone located less than 20 ft horizontally from the cable consists of the MCC panels, lighting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power panels are separated from the cable by greater than approximately 7.4 ft horizontally. Three electrical cabinets are located under the tray routing separated from the cable by greater than approximately 3.5 ft vertically. The rest of the electrical cabinets are separated from the cables by greater than approximately 5.6 ft horizontally. There are no intervening combustibles between the identified ignition sources and the cable.

Cable DD4-VN3 for valve LCV-1 12C is located in zones 6 and 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising vertically to the cable tray then turning south for approximately 16 ft and then east for approximately 52 ft and then turning north and traversing the corridor for approximately 20 ft before entering zone 6. In zone 6, the cable terminates at LCV-112B located in the south end of the zone approximately 7.5 ft above the floor. Ignition sources in zone 17A located less than 20 ft

NL-11-007 Docket No. 50-286 Attachment 2 Page 2 of 9 horizontally from the cable consist of the MCC panels, ligqhting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power Panels are separated from the cable by greater than approximately 7.4 ft horizontally. Three electrical cabinets are located under the tray routing separated from the cable by greater than approximately 3.5 ft vertically. The rest of the electrical cabinets are separated from the cable by greater than approximately 5.6 ft horizontally. Ignition sources in zone 6 located less than 20 ft horizontally from the cable consist of the charging pump motor and a transfer switch (alternate safe-shutdown power supply for the charging pump). The motor is separated from the cable by approximately 13.8 ft horizontally. The transfer switch is separated from the cable by approximately 16 ft horizontally. There are no intervening combustibles between the identified ignition sources and the cable.

REVISE the existing section in the RAI-02.1 RESPONSE titled "Fire Area PAB-2 / Fire Zones 6, 19A - PAB 55"'as follows:

Fire Area PAB-2 / Fire Zones 6, 17A, 19A - PAB 55' Cable DD4-VN5/1 for LCV-1 12C is located in zone 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising vertically to the cable tray then turning south for approximately 13 ft and then east for approximately 50 ft then turninq up and penetrating the ceiling approximately 16 ft above the floor and into the zone above.

Ignition sources in the zone located less than 20 ft horizontally from the cable consist of the MCC panels, lighting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power panels are separated from the cable by greater than approximately 7.4 ft horizontally. Two electrical cabinets are located under the cable routing separated by greater than 3.5 ft vertically. The rest of the electrical cabinets are separated from the cable by greater than 10 ft horizontally. There are no intervening combustibles between the identified igqnition sources and the cable.

Cable DD4-VN5/2 for LCV-1 12C is located in zone 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising vertically to the cable tray then turning south for approximately 16 ft and then east for approximately 100 ft and then turning up penetrating the ceiling approximately 16 ft above the floor and into the zone above. Ignition sources in the zone located less than 20 ft horizontally from the cable consist of the MCC panels, lighting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power panels are separated from the cable by greater than approximately 7.4 ft horizontally. Three electrical cabinets are located under the tray routing separated from the cable by greater than approximately 3.5 ft vertically. The rest of the electrical cabinets are separated from the cable by greater than approximately 5.6 ft horizontally. There are no intervening combustibles between the identified ignition sources and the cable.

Cable DD4-VN3 for valve LCV-1 12C is located in zones 6 and 17A routed in tray located approximately 14 ft above the floor. The cable originates in MCC 36A rising vertically to the cable tray then turning south for approximately 16 ft and then east for approximately 52 ft

NL-11-007 Docket No. 50-286 Attachment 2 Page 3 of 9 and then turning north and traversing the corridor for approximately 20 ft before entering zone 6. In zone 6, "onto"-ingthe.. uth end of the zono at the coiling in conduit locatcd app..Ximat.ly ,4 ft abeoe the fl'oo.

" the cable terminates at LCV-1 12B located in the south end of the zone approximately 7.5 ft above the floor. Ignition sources in zone 17A located less than 20 ft horizontally from the cable consist of the MCC panels, lighting power panels, electrical cabinets, and instrument panels. The MCCs and lighting power panels are separated from the cable by greater than approximately 7.4 ft horizontally. Three electrical cabinets are located under the tray routing separated from the cable by greater than approximately 3.5 ft vertically. The rest of the electrical cabinets are separated from the cable by greater than approximately 5.6 ft horizontally. Ignition sources in the-zone 6 located less than 20 ft horizontally from the cables consist of. the charging pump motor and a transfer switch (alternate safe-shutdown power supply for the charging pump). The motor is separated from the cable by approximately 13.8 ft horizontally. The transfer switch is separated from the cable by approximately 16 ft horizontally. There are no intervening combustibles between the identified ignition sources and the cable.

Cables AH9-PL2 and JA4-PL2/2 for fer-32 Charging Pump are located in zones 17A and 19A. The cables enters the southeastwest-e... qkuadrant of the-zone 17A from the electrical tunnel and are routed west to east along the south wall for approximately 33.5 ft before entering zone 19A. In zone 19A the cables continueand arc rMuted along the. .uth wal:-l fr west to east in tray located approximately 10 to1 2 ft above the floor for approximately 37 ft exiting at the east end of the zone. Ignition sources in the zone located less than 20 ft horizontally from the cables consist of an instrument panel, twenty-one__iaeteen electrical cabinets and one dry transformer. The instrument panel and eiatwelve of the electrical cabinets are located under the cables routing separated by apprx*imatoy, greater than 4.2 ft vertically-e.--..eae. The remaining nine electrical cabinets are separated from the cables by app.oxm"atoly greater than 4.2 ft horizontally-eo g-eateF. The dry transformer is separated from the cables by approximately 15.8 ft horizontally, There are no intervening combustibles between the identified ignition sources and the cables.

NL-11-007 Docket No. 50-286 Attachment 2 Page 4 of 9 TABLE RAI-GEN-24 CHARACTERISTICS OF ETN-4 / FIRE ZONE 7A Fire Area / Description ETN-4 / Electrical Tunnels Fire Zone / Description 7A / Lower Electrical Tunnel, Elevation 33'-0" Fire Zone Dimensions 2,975 sqft w/ 9 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

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 2.34E+08 BTU Total Fixed Combustible Loading Fire Severity. 78,716 BTU/sqft / 59 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

NL-11-007 Docket No. 50-286 Attachment 2 Page 5 of 9 TABLE RAI-GEN-24 CHARACTERISTICS OF ETN-4 / FIRE ZONE 7A Fixed Suppression Type / Coverage Dry Pipe Pre-action Sprinkler / In Cable Trays 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 Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources The west wall separating Zone 7A from Fire Area CTL -3 is a controlled barrier 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 ceiling between Zones 7A and 60A 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 Other Evaluations (i.e., 86-10) mechanical penetrations of the barrier have been sealed to maintain a 3-hour fire rating.

Evaluation of supports penetrating barriers between Turbine Building and Cable Spreading Room and between Cable Spreading Room and Electrical Tunnels" (IP3-ANAL-FP-01053)

Fire Barrier Analysis: Cable Spreading Room to Electrical Tunnels (IP3-ANAL-FP-01 049)

Fire Damper Assembly Analysis: Fire Dampers 4 and 9 Separating the Control Building from the Electrical Tunnel and the Turbine Bui/ding (IP3-ANAL-FP-01 325)

NL-1 1-007 Docket No. 50-286 Attachment 2 Page 6 of 9 TABLE RAI-GEN-25 CHARACTERISTICS OF FIRE AREA PAB-2 / FIRE ZONE 17A Fire Area / Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 17A / Elevation.55'-0" PAB Corridor Fire Zone Dimensions 6,386 sqft w/ 16 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions Yes - SER dated January 7, 1987 Fixed Combustible Materials Cable, Incidental material, Cellulose, Plastic, Resin, Hydrogen, Rubber Cable BTU / Loading / Fire Severity 190,552,185 BTU /29,839 BTU/sqft / 22 minutes Fixed Combustible Loading / Fire Severity 20,354 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 / 15 minutes Combustible Loading - Rating Low (Fixed + Transient loads = <100,000 BTU/sqft)

Ignition Sources Cable run, Junction Boxes, 3-MCCs, 5-Transformers, 1-Water heater, 12-Elect Cab, Lighting Power Supply, Instrument Panel

NL-11-007 Docket No. 50-286 Attachment 2 Page 7 of 9 TABLE RAI-GEN-25 CHARACTERISTICS OF FIRE AREA PAB-2 / FIRE ZONE 17A Detection Type / Coverage Area Wide Smoke Detectors, Ionization detectors in under-floor area at MCC Nos. 36A, 36B and 37, and Ultra-violet detectors in MCC area Code of Record NFPA 72E-1 974 Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (water),- C02 extinguishers Adjacent Zone Manual Suppression None Additional FP Features Fire stops (marinite boards) over cable trays Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Maximum Permissible Combustible Loading 50,194 BTU/sqft Other Evaluations (i.e., 86-10) Fire Barrier Analysis: Primary Auxiliary Building to Radioactive Machine Shop (IP3-ANAL-FP-01047)

NL-1 1-007 Docket No. 50-286 Attachment 2 Page 8 of 9 TABLE RAI-GEN-26 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 20A Fire Area Description PAB-2 / Primary Auxiliary Building Fire Zone / Description 20A / Sample Room, Elevation 55-0" Fire Zone Dimensions 210 sqft w/14.5 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 Cable BTU / Loading / Fire Severity 1,522,031 BTU / 7,248 BTU/sqft / 5 minutes Fixed Combustible Loading / Fire Severity 7,648 BTU/sqft / 6 minutes Transient Combustible Materials Wood, Plastic, Solvent, Cleaning materials, Anti-Cs Transient Combustible Loading / Fire Severity 115,407 BTU/sqft / 87 minutes Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sqft)

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

NL-1 1-007 Docket No. 50-286 Attachment 2 Page 9 of 9 TABLE RAI-GEN-26 CHARACTERISTICS OF PAB-2 / SSA FIRE/ANALYSIS AREA PAB-2{5} / FIRE ZONE 20A 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 Maximum Permissible Combustible Loading 240,000 BTU/sqft Other Evaluations (i.e., 86-10) None