Text

Revised Tables from Responses to Requests for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions
	ML110540321
Person / Time
Site:	Indian Point
Issue date:	02/10/2011
From:	Joseph E Pollock; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-11-0141, TAC ME0798
	Download: ML110540321 (70)
	v • d • e

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Entergy Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President NL-1 1-014 February 10, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Revised Tables from Responses to Requests 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. 2 (TAC No. ME0798)

Indian Point Unit No. 2 Docket No. 50-247 License No. DPR-26

References:

1. Entergy letter NL-1 1-006, 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. 2 (TAC No. ME0798)," dated January 19, 2011

2. 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)"

3. Entergy letter NL-10-100, "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. 2 (TAC No. ME0798)," dated September 29, 2010

4. 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)"

NL-11-014 Docket No. 50-247 Page 2 of 3

5. Entergy letter NL-10-042, "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. 2 (TAC No. ME0798)," dated May 4, 2010

6. 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)"

7. Entergy letter NL-09-116, "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. 2," dated October 1, 2009

8. Entergy letter NL-09-031, "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 8), Entergy Nuclear Operations, Ing, (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 7). Responses to the Request for Additional Information contained in NRC letter dated January 20, 2010 (Reference 6) were provided by letter dated May 4, 2010 (Reference 5). Responses to the Request for Additional Information contained in NRC letter dated August 11, 2010 (Reference 4) were provided by letter dated September 29, 2010 (Reference 3).

Responses to the Request for Additional Information contained in NRC letter dated December 16, 2010 (Reference 2) were provided by letter dated January 19, 2011 (Reference 1).

The purpose of this letter is to provide changes to tables of information previously provided in References 1 and 5. Tables RAI-06.1-1 and RAI-08.1-1 through RAI-08.1-7 from Reference 5 were previously revised in Reference 3, and additional changes were determined to be required during the preparation of Reference 1. Reference 1 stated that these changes would be made in a separate letter. Changes to Tables RAI-01.1-1 and RAI-01 .1-2 from Reference 1 were also determined to be required during the preparation of this current letter. Complete tables have been provided with additions indicated by bold underline and deletions by bold strikethrough. These tables replace the tables previously provided.

NL-11-014 Docket No. 50-247 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 Attachments:

1. Revised Table RAI-06.1-1 from Entergy Letter NL-10-042 dated May 4, 2010

2. Revised Tables RAI-08.1-1 through 08.1-7 from Entergy Letter NL-10-042 dated May 4, 2010

3. Revised Table RAI-01.1-1 from Entergy Letter NL-11-006 dated January 19, 2011

4. Revised Table RAI-01 .1 -2 from Entergy Letter NL-1 1-006 dated January 19, 2011 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 NL-11-014 Revised Table RAI-06.1-1 from Entergy Letter NL-1 0-042 dated May 4, 2010 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26

NL-11-014 Docket No. 50-247 Attachment 1 Page 1 of 13 Summary of Required Changes to Table RAI-06.1-1 from Entergy Letter NL-10-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE SSD Feature column to ADD 22 Cables associated with 22 AFW Pump steam supply Entergy Letter NL-10-100 AFW Pump steam supply isolation valves for isolation valves PCV-1310A/B and PCV- 1139 have dated September 29, 2010 Fire Area/Zone C/23 been verified to route through Fire Area/Zone C/23 Fire Area/Zone F/6 This zone was included on the table in Entergy letter Entergy Letter NL-10-100 NL-10-042 but was then inadvertently deleted from the dated September 29, 2010 table in Entergy Letter NL-10-100 Entergy Letter NL-1 1-014 dated February 10, 2011 REVISE SSD Feature column to ADD "LCV- Cables associated with charging suction valve LCV- Entergy Letter NL-10-100 112C" for Fire Area/Zone F/7A 112C have been determined by field walkdown to be dated September 29, 2010 included in Fire Area/Zone FI7A REVISE SSD Feature column to ADD "LCV- This component was inadvertently omitted from the Entergy Letter NL-1 1-014 112B" for Fire Area/Zone F/7A table dated February 10, 2011 REVISE SSD Feature column to DELETE These components were inadvertently included inthe Entergy Letter NL-1 1-014 "Charging makeup valves 227/HCV-142:" for table dated February 10, 2011 Fire Area/Zone F/7A REVISE SSD Feature column to ADD These components were inadvertently omitted from Entergy Letter NL-1 1-014 "Charging makeup valves 227/HCV-142:" for the table dated February 10, 2011 Fire Area/Zone FI27A ADD Fire Area/Zone F/59A Identified new Fire Area/Zone F/59A impact via cable Entergy Letter NL-10-100 routing and field walkdown dated September 29, 2010

NL-11-014 Docket No. 50-247 Attachment 1 Page 2 of 13 Summary of Required Changes to Table RAI-06.1-1 from Entergy Letter NL-10-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE to ADD Fire Area/Zones HI71A, Fire Area/Zones Ht71A, H-72A, H/84A, and H/85A Entergy Letter NL-10-100 H/72A, H/84A, and H/85A and to DELETE have been identified to contain cables/components for dated September 29, 2010 HW76A the listed SSD features, and it incorrectly identifies Fire Area/Zone H/76A as a zone that contains cables/components for the listed SSD features REVISE SSD Feature column to DELETE These components were inadvertently included in Entergy Letter NL-1 1-014 "IBUS23/IBUS23A" for Fire Area/Zones J19 these zones dated February 10, 2011 and J/45A REVISE SSD Feature column to DELETE Cables associated with LCV-1 12C have been verified Entergy Letter NL-10-100 "LCV-1 12C" for Fire Area/Zones J/43A and to not be routed in Fire Area/Zones J/43A or J146A dated September 29, 2010 J/46A REVISE SSD Feature column to DELETE Cables associated with valves FCV-405B/C and FCV- Entergy Letter NL-10-100 "FCV-405B, C; FCV-406A" for Fire 406A have been verified to not be routed in Fire dated September 29, 2010 Area/Zone J/46A Area/Zone J/46A REVISE SSD Feature column to ADD This component was inadvertently omitted from the Entergy Letter NL-1 1-014 "IBUS23/IBUS23A" for Fire Area/Zone J/46A table dated February 10, 2011 REVISE SSD Feature column to CHANGE "- Cables for all AFW flow control valves are located in Entergy Letter NL-1 1-014 D"to ",B" for "FCV-406A-D" for Fire these zones but only FCV-406A and FCV-406B are dated February 10, 2011 Area/Zones K/60A and K/65A associated with 21 AFW Pump which is credited for the OMA

NL-1 1-014 Docket No. 50-247 Attachment 1 Page 3 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Table.RAI-06.1-1 Proximity of Redundant SafeShutdownCables/Components, 4 Fire Hazards, and IgnitionSources Within Fire Areas and Fire Zones of Concern

.Fire :Area " " '" * ÷.* iProxim tyto Significant Fixed:* *: *' *:' * :*: :'*

riretirea SSD Feature Proximtog......ity.to Ignition Sources, Comments

. Zone *. __ .___ ...

___... ... ombbustibles, '..

C /23 All three AFW Small quantities of cable in The cable runs and pump Nonmechanistic ignition of control or instrument cables in pumps, flow overhead trays, with pumps and motors are the credible ignition the overhead trays would present an immediate impact on control valves, valves at floor elevation. The sources, in addition to an redundant AFW trains, as the trays contain (in part) control and 22 AFW trays containing cables serving alternative power transfer cables serving the AFW flow control valves Pump steam the AFW flow control valves are switch located at the south end The remaining fixed combustibles, consisting of a minute supply also located in the overhead of the room quantity of lube oil and electrical cabinets, present no isolation area. credible challenge to the AFW components in the zone valves, and associated The smoke detection system in the zone provides cables assurance of early warning of a fire condition, enabling fire brigade response prior to significant fire development F / 5A Cables The dominant combustible is The ignition sources, The flame-retardant characteristics of the cables ensure associated cable in overhead trays. The consisting of cable tray runs, that any fire would be limited in scope and severity with Charging cables of concern are located in junction boxes, and electrical No fire detection is installed in the zone, but given the suction valves or adjacent to the trays. cabinets, are in direct contact insignificant ignition sources, the occurrence of a fire of LCV-1 120 with, or in close proximity to theininfcnigtonsuethocrecefafref and LCV- coruin combustibles (electrical cables) significance in the zone detection in adjacent Fireis Zone a low-credibility event. Smoke 7A may provide 11 2B annunciation of any smoke that may migrate out of Fire Zone 5A to the main corridor area.

NL-1 1-014 Docket No. 50-247 Attachment 1 Page 4 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 o" Table RAI-06.1-1 Proximitof Redundant Safe-Shutdown Cables/Components,

,Fire Hazards, andlgnition Sources Within FireAreas and FiZones ofConcern

,FireArera Proximity to Signif icant Fixed SSD Feature , o Proximity to Ignition Sources "'Comm."ents

/Zone Cpombustibles _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

F/6 Cables Cables and valve LCV-1 12B are The only credible ignition There is no clear mechanism for ignition of the lubricating associated located adjacent to the Charging source, the Charging pump oil contained within the pump with: Charging pump, containing lubricating oil, motor, is located at the suction valves the dominant LCV- 1 Ccombustible zne in the midpoint CV- 12 ofan the zone, while calesare Theusmoke o warning assurance of early fire zcondition, n systemninof a the ioenproide enabling and LCV- located at the south end of the brigade response prior to significant fire development.

112B; zone Manual valve 288 (LCV-1 12B bypass) is also located in Instrument this zone.

Buses 23 and 23A F / 7A Cables The dominant combustible Ignition sources in the form of Combustibles other than cables in trays are minimal associated material in the zone is cable in electrical cabinets are throughout the zone. The credible fire scenario would with: overhead trays. The subject distributed throughout the involve transient combustibles, which are tightly controlled G-ho..... cables, in part, are located in or zone. Cable trays are oriented to "Level 2" limits per administrative control procedure.

makeup adjacent to these trays. directly above electrical valves cabinets in the primary corridor Combustibles in this large zone are widely distributed, area of the zone. presenting minimal potential for significant involvement in Instrument Buses 23 and response to initiation by any single ignition source in the Secondary combustibles in the zone 23A LCn area are dispersed, and 112C and substantial quantities of these The smoke detection system in the zone provides combustibles are not proximate assurance of early warning of a fire condition of any LCV-112B to the ignition sources in the significance, enabling fire brigade response prior to zone significant fire development

NL-11-014 Docket No. 50-247 Attachment 1 Page 5 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, .

Fire Hazards, andIginition Sources Within Fire Areas and Fire Zones of Concern Fire Area Proiiyt infcn ie Proximity to Ignition Sources Comments SSD Feature F / 22A Cables The zone contains a negligible The ignition sources, defined Redundant SSD trains are not located in the zone, but associated quantity of fixed combustibles as electrical cabinets, do not damage to cables associated with LCV-1 12C requires an with Charging present the potential for ignition OMA to align an alternate Charging suction source, outside suction valve of secondary combustibles, this zone LCV-1 12C given the insignificant content and LCV- of the zone No fire detection is installed in the zone, but given the 112B insignificant ignition sources, and the absence of significant combustibles, the occurrence of a fire of significance in the zone is a low-credibility event F / 27A Cables The dominant combustible is The ignition sources consist of Combustibles other than cables in trays are minimal associated cable in overhead trays. The cable tray runs and a throughout the zone. The credible fire scenario would with Charging cables of concern are located in significant number of motor involve transient combustibles, which are tightly controlled suction valve or adjacent to the trays. control centers, located in the to "Level 2" limits per administrative control procedure.

LCV-1 12C southeast corner of the zone.

and LCV- Cable trays are in overhead Combustibles in this large zone are widely distributed, 112B. proximity to one or more presenting minimal potential for significant involvement in Charging MCCs. response to initiation by any single ignition source in the makeup zone valves The smoke detection system provides assurance of early 227/HCV-142 warning of a fire condition, enabling brigade response prior to significant fire development

NL-1 1-014 Docket No. 50-247 Attachment 1 Page 6 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

': :: * ,-* :*:* * *:-' *Table R A -06. 1-1.. ' *;!.*:: :.:i*.. " i, * . .,

Proximity of Redundant'Safe-Slutdown CblsCorn nents.

Fire Hazards, nd Ignition Sources Within Fire Areas and Fire Zones of Concern .

Fire Area

Proximity to Significant Fixed o t n... .

./Zon&: SD Feature .ximityto P iitionSurces .... Comments F / 33A Cables The dominant combustible is The ignition sources consist of While not contained within a rated barrier, the effects of a associated cable in overhead trays. The the cable tray runs themselves, fire in this zone can be expected to be largely confined to with Charging cables of concern are located in as well as a significant number the zone, which is enclosed by a partial-height (10 ft) makeup or adjacent to the trays of motor control centers. concrete block wall. In the event of a significant fire in the valves Cable trays containing the zone, smoke migration through the open ceiling of the 227/HCV-142 cables of concern are in zone to adjacent Fire Zone 27A, the adjacent main corridor overhead proximity to one or area, can be expected to be detected by the smoke more MCCs. detection system in Zone 27A.

F / 59A Cables The dominant combustible is Ignition sources consist of The predominant combustible in the zone (charcoal) is associated charcoal enclosed in HVAC electrical cabinets. Conduit enclosed in filter housings equipped with an with HCV-142 filter units. containing the cables of automatic fire detection and water suppression bypass valve concern is routed directly system.

227 above one electrical (instrument) cabinet.

NL-11-014 Docket No. 50-247 Attachment 1 Page 7 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Table RAI-06.1 -1 Proximity of Redundant Safe-Shutdown Cables/Components,..............

Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of *oncern Fire Area SSD Feature Proximity to Significant Fixed Prit t It Sources Comments IZo:ne. Combustibles H / 70A, Charging Significant fixed combustibles are Cables for valves 204A and RCP lube oil is not considered to present a credible 71AX 72A, makeup cables in trays located in the 204B and safe-shutdown hazard, in that the RCPs are provided with a lube oil 75A, 76A, valves 204A annulus area proximate to the instrumentation are located collection system, ensuring that any leakage cannot 77A, 84X and 204B and electrical penetrations in Fire within zones containing RCPs contact hot surfaces and present an ignition threat 85A, 87A associated Zone 75A, and RCP lubricating and the associated lube oil.

cables oil located in Fire Zones 70A and However, as noted at right, the Smoke detectors are installed in the annulus - electrical 71A. Combustibles in the oil collection systems are penetration area, where the density of exposed cables is balance of containment are considered to reduce the high. Smoke detection is also installed in each of the RCP Safe- minimal, as are ignition sources, potential fire hazard to a bays. While the RCP oil collection systems can be shutdown during normal plant operation. negligible level, expected to minimize the potential for an oil fire in the RCP instruments areas, the smoke detection in each zone can be expected (Pressurizer Cables for valves 204A, 204B, Cables for the normal SSD to provide timely annunciation of an oil or electrical fire that level and and normal SSD instrument instrument channels are may occur.

pressure, channels are located proximate located proximate to ignition Steam to ignition source represented by sources in the form of cable Generator cable tray runs, located tray runs containing these level, RCS principally in Fire Zone 75A. cables loop Instrument cables are located in temperatures, Fire Zones 70A, 71A, where the and source- RCP oil collection systems range neutron minimize the potential for a fire of monitoring) significance, and in Fire Zone 75A, where smoke detectors and minimal ignition sources other than cable runs minimize the potential fire challenge. Cables and instruments are also located in Fire Zones 76A, 77A, and 87A, all of which contain minimal quantities of fixed combustibles.

NL-11-014 Docket No. 50-247 Attachment 1 Page 8 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

~Table RAI-06.1-1 F Proximity of Redundant Safe-Shlutdown Cables/Components, Fire Hazards, and Ignition Source* Within Fir a andFire ZonZe of Concern Fire Area Proximity to Significant Fixed SSDFeature Proximityt giio ore Comments S aZone CoM,.ustibles .r tolgnition Sources .

J / 17 Cables Cables routed through the zone Two electrical control cabinets An automatic Aqueous Film Forming Foam system is associated are above the turbine lube oil are located in the zone, provided for the turbine lube oil reservoir, located in the with 480V heat exchangers, and below the proximate to the turbine lube oil overhead of this zone Buses 5A and turbine oil reservoir located heat exchangers. No 6A above the zone combustibles are in proximity to these potential ignition sources.

J /19 Cables Cables routed through the zone No significant combustibles are The dominant combustible in the zone is lubricating oil in associated are above the air compressor located proximate to the air the air compressor, with minimal potential for ignition of the with: 480V located in the zone compressor, the principal enclosed oil inventory Buses 5A and ignition source in the zone, or 6A; to the control cabinet located in IBUS23/IBUS the zone 23A J /25 Cables Cables are located proximate to Cables are routed above the The concrete block construction of this small zone, in associated batteries in the zone ignition source (batteries) consideration of the minimal combustibles (battery cases) with and low likelihood of ignition, provides reasonable IBUS23/IBUS assurance that any fire in the zone would be confined to 23A the zone. Effects on the post-fire safe-shutdown capability would be minimal as a result.

NL-11-014 Docket No. 50-247 Attachment 1 Page 9 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Proximity of Redundant Safe-Shuitdown Cables/Components,

_________Fire Hazardsand Ignition Sources Within Fire Areas and fire Zones of Concern Fire Area Proxi~mity to Significant Fixed

[.Zone Featur Combustibles Proximitfto IgnitionSources/e Comments J /39A Cables The dominant combustible in this Ignition sources include The limiting fire scenario postulated for this zone, a turbine associated zone isturbine lube oil, which is electrical cabinets and motors, lube oil fire, would require a nonmechanistic piping failure with: 480V contained within the lube/control distributed throughout the to release the anticipated quantity of lubricating oil. The Buses 5A and oil piping system. A piping zone. Cables intrays are only other significant fuel source/ignition source isf ire-6A; system failure would be required located above one or more of retardant electrical cables in trays.

IBUS23/IBUS to create a credible fuel loading the identified ignition sources.

23A concern. Other combustibles include cables in trays.

J /43A Cables Cable trays are the dominant Ignition sources include 6.9kV No fire detection or automatic suppression systems are associated combustibles in the zone, and switchgear and motors located provided for this zone, but a fire involving the 6.9kV with: 480V cables of concern are located in in the zone, with 6.9kV switchgear can be expected to be promptly detected in the Buses 5A and or in proximity to these trays switchgear also presenting CCR, via annunciation of loss of power to the affected 6A; HEAF event potential. Cables 6.9kV buses. Inaddition, Zone 43A is a high-traffic area IBUS23/IBUS of concern are routed through and a developing fire condition can be expected to be 23A; LCV- the overhead area of the zone. detected and reported by personnel in the area.

112131412C

NL-11-014 Docket No. 50-247 Attachment 1 Page 10 of 13 ORIGINALLY PROVIDED INENTERGY LETTER NL-10-042 DATED MAY 4,2010 Proximityof Redundant SafeShutdown CablesComponents, .

__________ Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD, Feure to Significant

.ProximityFixed Proximitylgnition Sources Comments

/zone SSQeaue onbustiblesSokc Cmet J / 45A Cables Cable trays are the dominant Ignition sources include The principal fuel source and ignition source exposure to associated combustibles in the zone, and electrical cabinets, MCCs, and the zone is the Main Boiler Feedwater pump oil equipment with: 480V cables of concern are located in motors distributed throughout located immediately beneath this zone, under a partially-Buses 5A and or in proximity to these trays the zone. Cables of concern open floor deck. The oil storage/handling area below is 6A; are routed through the provided with an automatic Aqueous Film Forming Foam IBUI23/IIUlS overhead area of the zone. system.

23A J / 46A Cables The dominant combustible Ignition sources include Absent the postulation of a lube oil piping failure, the associated considered in this zone is turbine electrical cabinets and motors, dominant combustible in the zone is electrical cable in with: 480V lube oil, which is contained within distributed throughout the trays. The flame-retardant characteristics of the cables Buses 5A and the lube/control oil piping system. zone. Cables in trays are ensure that any fire would be limited in scope and severity.

6A; FCV- A piping system failure would be located above one or more of 405B, C; required to create a credible fuel the identified ignition sources.

FCV-4Q6Ai loading concern. Other LCV- combustibles include cables in 1121B/3142 trays.

IBUS23fIBUS 23A

NL-11-014 Docket No. 50-247 Attachment 1 Page 11 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

~~~~~~~.

........ :.....*=:= ,*4,;,.=*

Proximity of Redundant Sae-Shiutdown CalsCmpnns

.Fire Hazards, and Ignition Sources Within Fire Areas and.Fire Zones of ConcernI,.

Fire Area * ' * ",roximity P... to Signifcant Fixed:i *...* ..... .. ....... * ** .. ':,i FirZAne :SSD Feature Proximity Fixedton*ifibali

' x ignition Sources

Comments I Zone CombustiblesPrxmt J / 47A Cables Cable trays are the dominant Ignition sources include The postulated fire in this zone is a lube oil fire involving associated combustibles in the zone, and electrical cabinets, distributed one or more turbine lube oil transfer pumps. The area is with 480V cables of concern are located in throughout the zone. Cables in not provided with automatic detection or suppression Buses 5A and or in proximity to these trays trays are located above one or systems.

6A more of the identified ignition sources.

J / 50A Cables The dominant combustible Ignition sources include Absent the postulation of a lube oil piping failure, the associated considered in this zone is turbine electrical cabinets and motors dominant combustible in the zone is electrical cable in with: 480V lube oil, which is contained within distributed throughout the trays. The flame-retardant characteristics of the cables Buses 5A and the lube/control oil piping system. zone. Cables in trays are ensure that any fire would be limited in scope and severity.

6A; A piping system failure would be located above one or more of IBUS23/IBUS required to create a credible fuel the identified ignition sources.

23A loading concern. Other combustibles include cables in trays.

J / 270 Cables Cables associated with Battery The dominant ignition sources The cables of concern are predominantly confined to the associated 23 are located remote from the (transformers, electrical northwest area of the zone, which does not contain the with principal combustibles located in panels, motors) are not located substantial combustible loads and ignition sources IBUS23/IBUS the zone in proximity to Battery 23 and presented by the switchgear, transformers, and electrical 23A cables traversing to the Cable panels located in the balance of this zone Spreading Room and CCR from Battery 23

NL-11-014 Docket No. 50-247 Attachment 1 Page 12 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Table RAI-06.1-1 Proximity of Redundant Safe-Shudown Cables/Components, Fire.Hazards, and jgnition Sources Within FireAreas and Fire Zqnes of Concern,:,.

I Fire Area, P roximiy toSignificant Fixel Fire IZone% SSe Feature .**

Combustibles ; . P t Ignition Source's Comments K / 60A Cables Zone contains negligible fixed Motors on two penetration This area is devoid of significant fixed combustibles, and a associated combustibles blowers and two electrical substantial fire capable of challenging the integrity of the with 21 AFW cabinets represent the ignition cables of concern is not considered a credible event Pump; 21 sources in this zone. The ignition sources are located in AFW Pump the south end of the zone as recirculation are the SSD cables listed as valve FCV-SSD Features.

1121; AFW flow control valves FCV-406AB-D K I 65A Cables Zone contains negligible fixed This zone contains no ignition This area is devoid of significant fixed combustibles, and a associated combustibles sources substantial fire capable of challenging the integrity of the with: 21 AFW cables of concern is not considered a credible event Pump; 21 AFW Pump recirculation valve FCV-1121; AFW flow control valves FCV-406A, B -D

NL-11-014 Docket No. 50-247 Attachment 1 Page 13 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Table RAI-06.1-i1

'P.roximiy of RedundantSafe-Shutdown Cables/Components, .

' .* .... .. Fire Hazardsand Ignition Sources Within Fire eas and Fire Zones of Concern.

F+ire Area Proximity to Significant Fixed~

IzoSD 'SFeature ~ pmutb~~Proximity to Ignition Sources Comments P /1 All three CCW Zone contains negligible fixed Ignition sources are the COW Separation between CCW pumps previously approved by pumps and combustibles pump motors themselves exemption (SER dated October 16, 1984) associated cables YD /900 Cables Outdoor area with minimal fixed Ignition sources, if any, would While this area contains minimal fixed combustibles, associated combustibles be transient in nature credible fire scenarios would involve transient materials with HCV- and ignition sources. However, given the minimal footprint 142/227 of SSD circuits in the area/zone, the impact on the post-fire I I Isafe-shutdown capability would be minimal.

ATTACHMENT 2 TO NL-11-014 Revised Tables RAI-08.1-1 through RAI-08.1-7 from Entergy Letter NL-10-042 dated May 4, 2010 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26

NL-11-014 Docket No. 50-247 Attachment 2 Page 1 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-7 from Entergy Letter NL-1 0-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-1 OMA Performance Cables associated with 22 AFW Pump steam Entergy Letter NL-10-100 column to ADD Fire Area/Zone C/23 as a supply isolation valves PCV-131OA/B and PCV- dated September 29, 2010 Performance Zone for the Required OMA of 1139 have been verified to route through Fire "Open/check open 22 AFW Pump steam supply Area/Zone C/23 isolation valves" REVISE Table RAI-08.1-2 OMA Initiator column Cable EDC3-EXF6/2 for OMA "Align charging Entergy Letter NL-10-100 from Zone 27 (sic - should have read "27A") to path to RCS" found NOT routed through Fire dated September 29, 2010 Zone 59A as an Initiator Zone for the Required Area/Zone F/27A - actually routed through Fire OMA of "Align Charging pump makeup path to Area/Zone F/59A RCS" REVISE Table RAI-08.1-2 OMA Initiator column Cable EDC3-EXF6/2 was incorrectly reported in Entergy Letter NL-1 1-014 to ADD Zone 27A for the Required OMA of "Align Entergy Letter NL-10-100 as not routed in Zone dated February 10, 2011 Charging pump makeup path to RCS" 27A REVISE Table RAI-08.1-2 OMA Initiator column The correct zone number is 33A, the 'A' was Entergy Letter NL-1 1-014 to ADD "A"to Zone 33 as an Initiator Zone for the inadvertently omitted dated February 10, 2011 Required OMA of "Align Charging pump makeup path to RCS" REVISE Table RAI-08.1-2 OMA Initiator column These zones were inadvertently omitted from the Entergy Letter NL-1 1-014 to ADD Zones 5A and 27A for the Required OMA table dated February 10, 2011 of "Align Charging pump suction source to Refueling Water Storage Tank (RWST)"

NL-11-014 Docket No. 50-247 Attachment 2 Page 2 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-7 from Entergy Letter NL-10-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-3 OMA Initiator column Zones 70A, 77A, and 87A were inadvertently Entergy Letter NL-1 1-014 to ADD Zones 70A, 72A, 77A, 84A, 85A, and 87A omitted from the table in Entergy letter NL dated February 10, 2011 as Initiator Zones for the Required OMA of "Align 042 dated May 4, 2010. Zones 72A, 84A, and Charging pump makeup path to RCS." 85A were added to Table RAI-06.1-1 in Entergy letter NL-10-100 dated September 29, 2010 but were inadvertently omitted from Table RAI-8.1-3.

REVISE Table RAI-08.1-3 OMA Initiator column The zone was deleted from Table RAI-06.1-1 in Entergy Letter NL-1 1-014 to DELETE Zone 76A as an Initiator Zone for the Entergy letter NL-10-100 dated September 29, dated February 10, 2011 Required OMA of "Activate/enable Alternate Safe 2010 but was inadvertently not omitted from Shutdown System (ASSS) pneumatic instruments Table RAI-8.1-3 (Steam Generator level, Pressurizer pressure and level) at Fan House local control panel. Also enable ASSS source-range channel and Loop 21 and 22 hot (Th) and cold leg (Tc) temperature channels" REVISE Table RAI-08.1-4 OMA Initiator column Incorrect reference is made to Fire Area/Zone Entergy Letter NL-10-100 to DELETE Zone 24 as an Initiator Zone for the J/24, which is a III.G.3 zone, and not relevant to dated September 29, 2010 Required OMA of "Transfer Instrument Buses 23 the OMA issue and 23A to emergency power source" Note that Zone 24 is in fact a correct part of the routing of the affected circuits, but should not be mentioned here, since it is not a III.G.2 zone

NL-11-014 Docket No. 50-247 Attachment 2 Page 3 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-7 from Entergy Letter NL-1 0-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-4 OMA Initiator column These zones were inadvertently omitted from the Entergy Letter NL-11-014 to ADD Zones 39A, 43A, 46A, and 50A as Initiator table dated February 10, 2011 Zones for the Required OMA of 'Transfer Instrument Buses 23 and 23A to emergency power source" REVISE Table RAI-08.1-4 OMA Initiator column Cables associated with LCV-1 12B have been Entergy Letter NL-1 1-014 to delete Zones 19, 39A, 45A, and 50A as Initiator verified to not be routed in Fire Area/Zones J/19, dated February 10, 2011 Zones for the Required OMA of "Align Charging J/39A, J145A, or J/50A pump suction source to RWST" NOTE: This change was included in the table of changes in Entergy letter NL-10-100 dated September 29, 2010 but was inadvertently not omitted from the table REVISE Table RAI-08.1-4 Comments column to Cables associated with LCV-1 12C have been Entergy Letter NL-10-100 DELETE "LCV-1 12C" and to specify that a cable verified to not be routed in Fire Area/Zones J/19, dated September 29, 2010 associated with a supporting component for LCV- J/39A, J/43A, J/45A, J/46A, or J/50A 112B is the Target for the Required OMA of "Align Charging pump suction source to RWST'" Cables associated with LCV-1 12B have been verified to not be routed in Fire Area/Zones J/19, J/39A, J145A, or J/50A

NL-11-014 Docket No. 50-247 Attachment 2 Page 4 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-7 from Entergy Letter NL-1 0-042 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-4 to WITHDRAW the Unnecessary OMA to operate 22 AFW Pump Entergy Letter NL-10-100 Required OMA of "Operate 22 AFW Pump flow flow control valves (FCVs 405B, C) for Fire dated September 29, 2010 control valves to align AFW flow to selected Area/Zones J/1 9, J/39A, J/43A, J/45A, J/50A.

Steam Generators(s)" Failure as determined by Safe-Shutdown Analysis is the failure of the valve power supplies (instrument buses), which are recovered by a separate OMA to transfer the instrument buses to their emergency power supplies. After reenergizing the instrument buses, the valves can be operated from the controls in the CCR, so an OMA is not required.

NL-11-014 Docket No. 50-247 Attachment 2 Page 5 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 TABLE RAI-08.1-1

, EFIRE AREA C

.. ~ CREDITED IIL.G.2 OPERATOR MANUAL ACTIONS, R~equired ActualimetActual Tiet Total Time to Initiator (1)

Required OMA

.Diag.se Time to Need Complete Co.plete and ... l Fire

.*..et eaZone "Complete' for OMA ~ OMA 3. Resultant Margin4 OM Pefrac (P FlAra*

F o..e '.

Implement FR-H.1 if N/A N/A NA - no OMAs N/A 1:Area C, Zone 23 Action performed from OCR, and not necessary to establish ()rqieP:NAan OMA, but described for alternate secondary heat ()rqieP:NAcompleteness sink Operate Steam Generator --- WITHDRAWN Atmospheric Dump Valve(s) Sersos oRI0.

(a) The Required Time to Complete for this potential action was shown in the previous submittals as 34 minutes. However, the 34-minute limitation refers to the Steam Generator (SG) boll-dry time in the absence of AFW flow to the SGs, and represents the time available to restore AFW flow. In the unlikely event that the EOP 2-FR-H.1 methodology would be necessary, the time to boil dry the SGs has no direct applicability, as actions within 2-FR-H.1 are driven to be implemented at substantially greater remaining SG inventories, and the boil-dry time does not have direct applicability given the multiple methods that 2-FR-H. 1 provides for reactor coolant heat removal alternatives. The reference to "34 minutes" has therefore been deleted in this submittal.

These notes apply to Tables RAI-08.1 -1 through RAI-08.1 - 7:

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

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

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

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

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

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

NL-11-014 Docket No. 50-247 Attachment 2 Page 6 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

.... . " **' *:*". * *:* = *: = " * . *: '*'" " " TABLE RAI-08.1 -1I . * . . * * **.. , ..... * * ., ". .. . '...

FIRE AREA C CREDITED II.G.2 OPERATORMANUAL ACTIONS . o Required Actual Time to Actual Timeto. Total Time to initiator (I)

Rquired OMA Time to Diagnose Need .Complete Complete and 9 Fire Area/Zone5 Comments Complete for OMA 2 OMA.. Resultant Margin OMA Perfo c (P)

Operate 22 AFW Pump >1 hr 4.5 m 22 m TTC: 26.5 m 1:Area C, Zone 23 Targets: 21, 22, 23 AFW pumps; (turbine-driven) [previously Cables associated with AFW pumps "steam-driven"] Margin: 33.5 m; P: Area C, Zone 23 and flow control valves FCV-405A, 56% FCV-405B As described in Entergy letter NL 031, Att. 2, Table 2 NOTE, reentry to the AFW pump room is credited, following the initial 60 minutes of the fire event Open/check open 22 AFW >1 hr 4.5 m 15 m ITC: 19.5 m I: Area C, Zone 23 Targets: Cables associated with 22 Pump steam supply AFW Pump steam supply isolation isolation valves Margin: >40.5 m; P: Area K, Zones 60A valves

>67% and 61A. Area C. Zone 23 Operate 22 AFW Pump flow >1 hr 4.5 m 22 m TTC: 26.5 m I: Area C, Zone 23 Targets: Cables associated with 23 control valves to align AFW AFW Pump flow control valves FCV-flow to selected Steam Margin: >33.5 m; P: Area C, Zone 23 405A, FCV-405B Generator(s) >56%

NL-11-014 Docket No. 50-247 Attachment 2 Page 7 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

NL-11-014 Docket No. 50-247 Attachment 2 Page 8 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 TABLE RAW~8.1 -2~

FIRE AREA F

________________CREDITED III.G.2 OPERATOR MANUAL ACTIONS eqieiRequired~ Actualjime to Acua Tiet Total Time to : Initiator (11 Rqie MTiet agnose Need Complete CMA, Complete and i&'AeZn Comments Copee for OMA Resulltant Margin ~MA O P6 rformance (P)

FireArea/Zone' Align Charging pump 75 m 14 m 18 m TTC: 32 m 1:Area F, Zone 5A .Targets cables

associated with suction source to Refueling 7A, Gr-22A or 27A valves LCV-1 12B, LCV-1 120 Water Storage Tank (c) Margin: 43 m; (RWST) 57% P: Area F,Zone 6; Area Reentry to Area Fto implement OMA F,Zone 22A is following extinguishment of and securing from fire, >1 hour from start of event Travel time conservatively taken to be 10 minutes, from OCR to PAB. Travel time isnon-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. Note that time to diagnose the need for this OMA is measured from T=0, and not from the time of fire area reentry, at 60 minutes into the scenario.

(c) The Total Time to Complete is conservatively revised to 18 minutes, whereas the referenced submittals showed a value of 8 minutes for the Actual Time to Complete

NL-11-014 Docket No. 50-247 Attachment 2 Page 9 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Required OlA~

IFire Transfer Instrument Buses 5.5 m 2m iTc: 7.5 m 1:Area F, Zone 6 or 7A Targets: Cables associated with 1B23, 23 and 23A to alternate IB23A power Margin: 22.5 m; P: Area A, Zone 11 75%

NL-11-014 Docket No. 50-247 Attachment 2 Page 10 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 I

Align Charging pump 75 m 14 m 14 m -TC: 28 m 1: Area H, Zones 70A, Targets: Cables associated with makeup path to RCS 71A, 72A. 75A, 77A, Charging makeup valves 204A, 204B (d) Margin: 47 m; 84A, 85A and 87A 63% Only required OMA is local closing of P: Area A, Zone 1A manual valve IA-501. OMA time basis is conservatively taken as equivalent to that for OMA to locally operate MOV 227, also located in Area A, Zone IA, and with equivalent accessibility.

Travel time is conservatively taken to be 10 minutes, from CCR to PAB.

(d) The Total Time to Complete is conservatively revised to 14 minutes, whereas the referenced submittals showed a value of 4 minutes for the Actual Time to Complete

NL-11-014 Docket No. 50-247 Attachment 2 Page 11 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

[

I Activate/enable Alternate <1 m 13 m: ASSS -- c: I: Area H, Zone. 70A, Loss of multiple channels of some key Safe Shutdown System (instruments pneumatic 75A, 7-6A,77A, 87A instrumentation is assumed to occur at (ASSS) pneumatic assumed failed 13 m (ASSS channels in T=0, and therefore the time-to-instruments (Steam pneumatics) diagnose is effectively considered to at T=0) service P: Area A, Zone !A; Generator level, Pressurizer 23 m (Th, Tc, Area J, Zone 270, 360; be <1 minute pressure and level) at Fan 10 m: ASSS source range) Area F, Zone 59A House local control panel. source range, Deployment of ASSS instruments Also enable ASSS source- Th, Tc channels Margin: involves parallel actions by two range channel and Loop 21 in service operators. PAB operator aligns ASSS and 22 hot (Th) and cold leg 21 m (ASSS pneumatic channel isolation valves (Tc) temperature channels pneumatics); 62% and manipulations necessary to energize ASSS source-range drawer; 11 m (Th, Tc, conventional operator enables ASSS (e) source range); 32% power supply to power up ASSS source-range channel and Loop 21/22 Th and Tc channels, located in Area F, Zone 59A Time to close supply breaker on ASSS switchgear 12FD3 to energize ASSS source range, Th and Tc channels conservatively taken to be 10 min, equivalent to the time required for the more complex breaker operation OMA taken for the Fire Area J scenario. In parallel with breaker closure, PAB operator installs fuses and closes knife switch to energize ASSS channels locally.

NL-11-014 Docket No. 50-247 Attachment 2 Page 12 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 RTimet*o i Au nose Need Diag to to Totaali L ReureoMATmpe to Need 9 figorsMe~ ~it *Complet~e and Fire'A'ia/Zone Cmet in service, in support of the required restoration of AFW to the Steam Generators within 34 minutes to preclude SG boil-dry conditions being reached. Therefore, the Total Time to Complete is conservatively revised to 34 minutes, whereas the referenced submittals showed a nominal value of "30+" minutes for the Actual Time to Complete.

Consistent with the information presented in the March and October 2009 submittals, the Time to Complete the OMA remains 13 minutes, for the deployment of the pneumatic instrument channels. Additional data is now shown for the time required for deployment of the ASSS electronic instrument channels.

NL-11-014 Docket No. 50-247 Attachment 2 Page 13 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Trip breakers 52/5A and 52- 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 0 10m TTC: 10 m 1:Area J, Zone 17, 19, Targets: Cables associated with Bus SAC on Bus 5A and 52/6A (Offsite power 39A, 43A, 45A, 46A, 6A supply breakers and 52/TAO at Bus 6A and assumed Margin: 50 m; 47A, or 50A remove control power fuses unavailable at 83% Actual time to complete in this case is T=0) P: Area A, Zone 14 based on equivalent breaker tripping actions in the 480V Switchgear Room that have been previously validated Transfer Instrument Buses 30 m 5.5 m 2m HTC: 7.5 m 1:Area J, Zone 24, 25, Targets: Cables associated with 1B23, 23 and 23A to emergency 39A, 43A. 46A, 50A or IB23A power source Margin: 22.5 m; 270 75%

P: Area A, Zone 11 Align Charging pump 75 m 14 m 18 m HOC: 32 m I: Area J, Zone 19,-39A, Targets: Cables associated with suction source to RWST 43Ar45Ay r 4 6AArw supportinq components for valves s0(f) Margin: 43 m; A LCV-112B, LCV-112C 57%

P: Area F, Zone 6; Area Travel time conservatively taken to be F, Zone 22A 10 minutes, from CCR to PAB Operate 22 AFW Pump flow 34- m 4 -m 1 M i-..M.

11.-1-.. Area j, Zone 19, 39A, WITHDRAWN Targets!Cables control valves to align AFW 43A,, '.15., or 50.pA .. it.. ith ARFW flnow" contral flow to selected Steam Ma*gn-22-5nm malve F* 1-140S*D Generator(s) , e Area C, Zone23*

(f) The Total Time to Complete is conservatively revised to 18 minutes, whereas the referenced submittals showed a value of 8 minutes for the Actual Time to Complete

NL-11-014 Docket No. 50-247 Attachment 2 Page 14 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010 Transfer 21 AFW Pump to 34 m 4.5 m 17 m t TTC: 21.5 m 1:Fire Area K, Zone 60A Targets: Cables associated with 21 ASSS power source or 65A AFW pump normal power (g) Margin: 12.5 m; 37% P: Fire Area C, Zone 23; Two discrete operations are performed Fire Area J, Zones 360 by an operator dispatched to Fire Area and 361 C and a second operator dispatched to ASSS switchgear 12FD3 in Fire Area J Operate SGADVs as - - WITHDRAWN required to control secondary system cooldown See response to RAI-02.1 Open 21 AFW Pump 34 m 4.5 m 5m TUC: 9.5 m 1:Fire Area K, Zone 60A Target: Cable associated with valve recirculation bypass valve or 65A FCV-1121 Margin: 24.5 m; 72% P: Fire Area C, Zone 23 Operate 21 AFW Pump flow 34 m 4.5 m 7m TTC: 11.5 m I: Fire Area K, Zone 60A Targets : Cables associated with FCV-control valves to control or 65A 406A and FCV-406B AFW flow to Steam Margin: 22.5 m; Generators 21 & 22 66% P: Fire Area C, Zone 23 (g) The Total Time to Complete is revised to 17 minutes, whereas the referenced submittals showed a value of 5 minutes for the Actual Time to Complete

NL-11-014 Docket No. 50-247 Attachment 2 Page 15 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

~TABLE RAI-08. 1-6~~

. ..... . CRED'TED III.G.2 OPERATOR MANUAL ACTIONS "_"_'_.....

W~ ~ OMA 1 Required ActuaITime.to Total to ... t"... .. oiete RequiredOMA *Time to Diagnose e ActualN imet°to mpleteoand . Fire

... a.oCom Compiete for OMA Complete OMA Resultant arginK ONMAPerformiace (P)

Transfer 23 CCW Pump to > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 m 7m I-C: 31 m I: Area P, Zone 1 Targets: 21, 22, 23CCP and their ASSS power feed if normal power cables power/control is lost Margin: >29 m; P: Area F, Zone 7A

>48%

Start Appendix R Diesel 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 0m 17 m TTC: 17 m I: Area P, Zone 1 Target: Normal power cable to 23CCP Generator (ARDG) if normal (Offsite power power and offsite power are assumed Margin: 43 m; 72% P: Area J, Zones 360 Offsite power availability is not lost unavailable at and 361 affected by a fire in Fire Area P T=0)

NL-11-014 Docket No. 50-247 Attachment 2 Page 16 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

.TABLE RAI-08.1-6 FIRIEAREA P

_______....__ , . : CREDITED III.G.22OPERATOR MANUAL ACTIONS . _,'._.._."_ _"

.*o

... "ctualTime toNe Actual.Time t Total Time to, Initiator (1 Required OMA toMA Dia orTimee NC omplete and Fire Area/Zone Comments Resultant Margin . OMA Performance (P) 7Fire Area/Zone*

Transfer 23 CCW Pump to > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 m 7m TTC: 31 m I: Area P, Zone 1 Targets: 21, 22, 23CCP and their ASSS power feed if normal power cables power/control is lost Margin: >29 m; P: Area F, Zone 7A

>48%

Start Appendix R Diesel 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 0m 17 m IIC: 17 m I: Area P, Zone 1 Target: Normal power cable to 23CCP Generator (ARDG) if normal (Offsite power power and offsite power are assumed Margin: 43 m; 72% P: Area J, Zones 360 Offsite power availability is not lost unavailable at and 361 affected by a fire in Fire Area P T=0)

NL-11-014 Docket No. 50-247 Attachment 2 Page 17 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-042 DATED MAY 4,2010

<FIRE AREA YD ~.:..

. . . CREDITED III.G.2OPERATOR MANUAL ACTIONS .. .

Required Actual Time to Actu.al Time to TtalTimeeto ~OMAN Initiator (I)" .

Required O.MA to Diagnose Need .Time "paire Arei/one: Comments

.oResultant Margin OMA Performance (P)

____ ___ ___ ___ __ ___ __ !FireAi /Zone, Align Charging pump 75 m 14 m 4m TTC: 28 m I: Area YD, Zone 900 Target: Cable associated with valve makeup path to RCS 227 Margin: 47 m; P: Area A, Zone 1A 63%

ATTACHMENT 3 TO NL-11-014 Revised Table RAI-01.1-1 from Entergy Letter NL-1 1-006 dated January 19, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26

NL-11-014 Docket No. 50-247 Attachment 3 Page 1 of 13 Summary of Required Changes to Table RAI-01.1-1 from Entergy Letter NL-11-006 dated January 19, 2011 Change Reason for Change REVISE Component of Concern column to CHANGE "HVC" to Typographical error "HCV" for Areas/Zones F/27A, F133A, F159A and YD/900 for the Required OMA of "Align Charging pump makeup path to RCS" REVISE Cables of Concern column for the Required OMA of These cables were inadvertently omitted from the table "Repower instrument buses IBUS23 and IBUS23A from backup source" as follows: ADD "EDB8-EPB3" for Area/Zone J/25; ADD "JB1 -L91" for Area/Zone J/43A; ADD "EGA9-EDB8/4" and "EGA9-EDB8/5" for Area/Zone J1270 REVISE to ADD Area/Zones J/39A, J/46A and J/50A to the These Area/Zones were inadvertently omitted from the table Required OMA of "Repower instrument buses IBUS23 and IBUS23A from backup source" REVISE to DELETE the Required OMA of "Locally operate AFW This OMA was previously WITHDRAWN in Entergy Letter NL-flow control valves FCV-405B, 405C, or FCV-406A"10-100 dated September 29, 2010 and was inadvertently included in the table

NL-11-014 Docket No. 50-247 Attachment 3 Page 2 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

~<44444~ TABLE RI0.-

OMA Initiator Cables of Concern and Mitigating Features Minimizing the P=otentlal tolReouire Useof Credited OMAs

~OMA'

~Req~reaM' 1InitQia Component of 4 Firere Ara , on1m Cables4 of Con~cern. .Fire Protectioni Defense In Depth 3

Fire Zone'~ .4_________________________

Operate 22AFW Pump Area C 21 AFW Pump EDC5-M74/1 Exemption granted for App R III.G.2 in this area - SERs (turbine-d riven) Zone 23 EDC5-M74/2 dated Oct 16, 1984 and March 4, 1987 ELD11-EWC26 Area Wide Smoke Detection 23 AFW Pump JB1-PT1/1 Low Fixed Combustible Loading PT1-A19 Transient Combustible Controls XD7-M75/1 Minimal Ignition Sources XD7-M75/2 Hot Work & Ignition Source Controls Portable Extinguishers in the zone 23 AFW` Pump power cable wrapped w/ 30 minute ERFBS

________ _______________Radiant Energy Shield installed between 21 & 23AFW Pump Open/check open 22 Area C PCV-1139 JBl-PT1/3 Exemption granted for App R III.G.2 in this area - SERs AFW Pump steam Zone 23 PT1-RH7 dated Oct 16, 1984 and March 4, 1987 supply isolation valves PT1-YL4 Area Wide Smoke Detection PCV-1310B EWZ64-ENX2 Low Fixed Combustible Loading JBI-YP1 Transient Combustible Controls S95-EWZ64 Minimal Ignition Sources S95-S92 Hot Work & Ignition Source Controls S95-YP1 Portable Extinguishers in the zone PCV-1310A EWZ63-ENX1 23 AFW Pump power cable wrapped w/ 30 minute ERFBS JB1-YN9 Radiant Energy Shield installed between 21 & 23AFW Pump S94-EWZ63 S94-593 S94-YN9

References:

Entergy letter NL-10-042 dated May, 4, 2010, Tables RAJ-08. 1-1 through RAI-08.1-7; Entergy letter NL-10-100 dated September 29, 2010, Tables RAI-08.lI- 1, RAI-08.1-2, and RAJ-08.1-4 2

Reference:

Entergy letter NL-10-100 dated September 29, 2010, RAI-02.1 response 3 Rfeencs:Entergy letter NL-10-042 dated May, 4, 2010, Tables RAI-GEN-1 through GEN-27; Entergy letter NL-10-100 dated September 29, 2010, Tables RAI-GEN- 1, RAI-GEN-l10, RAI-GEN-23, RAI-GEN-25, RAI-GEN-28, RAI-GEN-29, RAI-GEN-30, and RAI-GEN-31

NL-11-014 Docket No. 50-247 Attachment 3 Page 3 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011

. .... . ..

TABLERAI.0,1, . ...

OMA Initiator Cabi*s of Concern and Mitigating Features Minimizing the.Potential to Require Use of Credited OMAs.

. OMA". .. .

2 3 Re""..red *O" A iA**rtato Cables of Concern CConent .!re Protection Defense infDepth Fie.

r : .. Fir Zon Concern

m. on. .

e. *o. :Ae .' .:.*.'* . ,. .* . . *. *: .* . .**' . k,.. ... . ..

Operate 22 AFW Pump Area C FCV-405A ]B1-LV1 Exemption granted for App R III.G.2 in this area - SERs flow control valves to Zone 23 dated Oct 16, 1984 and March 4, 1987 align AFW flow to FCV-405B JB1-LV2 Area Wide Smoke Detection selected steam Low Fixed Combustible Loading generator(s) FCV-405C JB1-LV3 Transient Combustible Controls Minimal Ignition Sources FCV-405D JB1-LV4 Hot Work & Ignition Source Controls Portable Extinguishers in the zone 23 AFW Pump power cable wrapped w/ 30 minute ERFBS FCV-406A ELZ27-YN6 Radiant Energy Shield installed between 21 & 23AFW Pump JF5-YN6 PU9-JG2 FCV-406B ELZ28-YN8 JF5-YN8 LL8-JF5 PU9-JH1 FCV-406C ELZ29-YN7 JF9-YN7 LL9-3F9 PU9-JF2 FCV-406D ELZ3O-YN5 JF9-YN5 PU9-JF79 Area K FCV-406A PU9-JG2 Low Fixed Combustible Loading Zone 60A LL8-3F5 Transient Combustible Controls FCV-406B PU9-JH1 Minimal Ignition Sources Hot Work & Ignition Source Controls FCV-406C PU9-JF2 Portable Extinguishers in the zone LL9-JF9 Hydrants in adjacent yard FCV-406D PU9-JF9

NL-11-014 Docket No. 50-247 Attachment 3 Page 4 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 fALE RAeulr.1s-

" Initia.t...o_*

ntc Cables of Concern adn itigating Features Minimizing the Potential to RequireoUse of Credited OMAs OMA. ...

RequiInid Inltiatrr

Component of 2 3 OMA' F Concerni Cables of Concern Fire Protection Defense In Depth* .

~..Fire Zone' ____________________

Area K FCV-406A PU9-JG2 Low Fixed Combustible Loading Zone 65A LL8-JF5 Transient Combustible Controls FCV-406B PU9-JH1 Minimal Ignition Sources Hot Work & Ignition Source Controls FCV-406C PU9-JF2 Portable Extinguishers in the zone LL9-JF9 Hydrants in adjacent yard FCV-406D PU9-JF9 Align charging Area F MOV-227 ECD3-EXF6/2 Area Wide Smoke Detection makeup path to RCS Zone 27A HCVC-142 Moderate Fixed Combustible Loading (locally open bypass Transient Combustible Controls valve 227 to mitigate Minimal Ignition Sources a spuriously closed Hot Work & Ignition Source Controls HCV-142) Portable Extinguishers in the zone Hose Station in the zone Area F MOV-227 ECD3-EXF6/2 Open to Zone 27A w/ Area Wide Smoke Detection Zone 33A HCVC--142 Moderate Fixed Combustible Loading Transient Combustible Controls Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose Station in adjacent zone Area F MOV-227 ECD3-EXF6/2 Thermistor and Smoke Detector for Charcoal Filters Zone 59A HCVC--142 Minimal Ignition Sources Portable Extinguishers in the zone Hose Station in adjacent zones Hydrant in adjacent yard Transient Combustible Controls Hot Work & Ignition Source Controls

NL-11-014 Docket No. 50-247 Attachment 3 Page 5 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

. TABLE RAI-01.1-1 ' 7 , ';

. OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potentialto Require Use. of Credited OMAs AA Coponent of FiAiat Coonent of Cables of Concern2

... Fi.re Protection Defense in Depth3

___ ___ ___ Flreýone1 concern'___

Area YD MOV-227 ECD3-EXF6/2 Outside - PAB roof Zone 900 HCVG-142 Low fixed combustible loading Hose Station in adjacent zones Portable Extinguishers in adjacent zone Align charging pump Area F LCV-112B PQ3-JB9/8 Low Fixed Combustible Loading suction source to Zone 5A LCV-112C Transient Combustible Controls RWST (close LCV- Minimal Ignition Sources 112C, open 288) Hot Work & Ignition Source Controls Extinguishers in adjacent zone Hose station in adjacent zone Area F LCV-112B YZI-JB5 Exemption granted for App R III.G.2 in this area - SER Zone 6 LCV-112C March 4, 1987 Area Wide Smoke Detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Extinguishers in adjacent zone Hose station in adjacent zone Area F LCV-112B CK1-YP3 Exemption granted for App R III.G.2 in this area - SER Zone 7A LCV-112C YZ1-JB5 October 16, 1984 CK1-JB5/1 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

NL-11-014 Docket No. 50-247 Attachment 3 Page 6 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 TABLERAIj01.1-1 OMA Initiator Cables of Concern and -,tlgating Features Minlmizing the Potent!al to Require Use of Credited O s.As Required OMA. Iiitr Componentof I Cale CConcerm Fire Protection. Defense in Depth.3fCnen Fir~e Area Concern~ -

Area F LCV-112B CK1-YP3 Low Fixed Combustible Loading Zone 22A LCV-112C Minimal Ignition Sources Transient Combustible Controls Hot Work Controls Portable Extinguishers in adjacent zone Hose Stations in adjacent zone Area F LCV-112B CK1-YP3 Area Wide Smoke Detection Zone 27A LCV-112C CK1-JB5/1 Moderate 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 J LCV-112B ECE19-MN3/01 Low to Moderate Fixed Combustible Loading Zone 43A LCV-112C AE2-BA7 Transient Combustible Controls ECE18-CC5/01 Minimal Ignition Sources EWF61-AG9/01 Hot Work & Ignition Source Controls EWF61-AG9/02 Portable Extinguishers in the zone EWF61-ECE19/01 Hose Station in the zone EWF61-ECE19/02 Area I ECE19-MN3/01 Low to Moderate Fixed Combustible Loading Zone 46A ECE18-CC5/01 Transient Combustible Controls EWF61-AG9/01 Minimal Ignition Sources EWF61-AG9/02 Hot Work & Ignition Source Controls EWF61-ECE19/01 Portable Extinguishers in the zone EWF61-ECE19/02 Hose Station in the zone

NL-1 1-014 Docket No. 50-247 Attachment 3 Page 7 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

~TABLE RAI[O1.1-1;

.OMA Initlator Cables of Concern and Mitlgating Featureslminimizing the 'Potential to Require Use of Credited OlAs OMA .

RequiredlalAorInitiator eqldQA FAaCnen Component of Cables o C Ca*blespofCoc *, 2

... Fire Protection De.fense in Depth ees~n.epth* 3 p,:.Re:roeto

.,j ,:.

Fonere Aracnen Fire Zo~ne'____ ___

Transfer Instrument Area F BUS3A PL2-M42 Area Wide Smoke Detection Buses 23 and 23A to Zone 6 Low Fixed Combustible Loading alternate power Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Extinguishers in adjacent zone Hose station in adjacent zone Area F BUS3A A15-PL2 Area Wide Smoke Detection Zone 7A PL2-JA2/2 Low Fixed Combustible Loading A14-PT2 Transient Combustible Controls PT2-JA2 Minimal Ignition Sources PL2-M42 Hot Work & Ignition Source Controls Close IA-501 to fail Area H Valve 204A Y17-H55 Smoke Detection over RCPs open valves 204A and Zone 70A Low to Moderate fixed combustible loading 204B Zone 71A Hose Station in adjacent zones Zone 72A Minimal Ignition Sources Zone 75A Transient Combustible Controls Zone 77A Hot Work & Ignition Source Controls Zone 84A Restricted access during operation (containment)

Zone 85A Oil collection system for RCPs Zone 87A

NL-11-014 Docket No. 50-247 Attachment 3 Page 8 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 OM ..... TABLE RAI-01.1 ."

OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited .Hs .

OMA Required OMA 1 Initiator FtiatCrm Component1 of Cables of.ConcerM2DenenDt~ Fire *frotection Defense In DepthS

______________ FireZone'~_____________ _________________

Open IIP-500X to Area H All normal safe- EPC3-H39/4 Low Fixed Combustible Loading enable ASSS Zone 70A shutdown EPC4-H41/4 Transient Combustible Controls pneumatic Zone 75A instrument channels EPC4-H41/3 Minimal Ignition Sources instruments Zone 77A for steam generator Hot Work & Ignition Source Controls EPC3-H139/3 Zone 87A level, pressurizer Hose station in adjacent zone PN8-H39/2 level, and RCP Smoke Detection pressurizer pressure PR3-H41/2 PR4-H33/2 PR4-H33/3 ETC5-EZC9 EZC9-H27 ETD4- EZA5 EZA5-H52 ETC6-EZD1 EZD1-H30 ETD5-EZA6 EZA6-H20 ETC7-EZD2 EZD2-H20 ETD6-EZA7 EZA7-H21 ETC8-EZD3 EZD3-H23 ETD7-EZA8 EZA8-H22

______________________ ___________ A _____________________ I ____________________ L

NL-11-014 Docket No. 50-247 Attachment 3 Page 9 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 OMAIntlaorablso~onera TABLE RAI-01A.

1-

___________ Intao Cbeofonrn an Mtgatng Features Mr3inimiigtePtnilt eur s of Credited OMAs 0MA Required. OMA, Fire Area Concern'. Cables of Conern 2 Fire Protectioi Defense in Depth3 Open breakers, pull Area I 480V Bus 5A AD1-BA8 Low to Moderate Fixed Combustible Loading fuses at two breakers Zone 17 AG5-XA5 Transient Combustible Controls on Bus 5A and 6A Zone 19 PC9-XA5/1 Minimal Ignition Sources Zone 39A PC9-XA5/2 Hot Work & Ignition Source Controls Zone 43A XA5-WU9 Portable Extinguishers in the area Zone 45A 480V Bus 6A AC4-BA6 Hose Stations in the area Zone 46A JC2-YA9 Zone 47A Zone 50A Repower instrument Area J PPNL23 EGA9-EDB8/4 Low Fixed Combustible Loading buses IBUS23 and Zone 25 BUS3A EGA9-EDB8/5 Transient Combustible Controls IBUS23A from backup Minimal Ignition Sources source Hot Work & Ignition Source Controls Area J JB1-L91 Low to Moderate Fixed Combustible Loading Zone 39A 3J7-]C3 Transient Combustible Controls EWD49-EAA24/01 Minimal Ionition Sources EWD49-EWE60/01 Hot Work & Ignition Source Controls WF6-AA2/01 Portable Extinguishers in the area Hose Stations in the area Area J AA3-BA5 Low Fixed Combustible Loading Zone 43A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adjacent zone Area J JB1-L91 Low to Moderate Fixed Combustible Loading Zone 46A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the area I Hose Stations in the area

NL-1 1-014 Docket No. 50-247 Attachment 3 Page 10 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-1 1-006 DATED JANUARY 19, 2011 TAB~LE RAI-0L.1-1 OMA Initiator Cables of Cncern. and Mitigpting Features Minimizing ~the OMA Initiator Component:of 2 Required OMA' Cables of Concern*

Fire Area. Concer,9i Fire Zone' Area J JB31-L91 Low to Moderate Fixed Comhuqtihle Loadinn Zone 50A Tr~nneinnt rnmh.,et~iHg t,~n#rniv Minimal Ionition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the area Hnose Ctntinnc in th4 =ra Area J EDB8-EPB3 Low Fixed Combustible Loading Zone 270 Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adiacent zone Leeall-j eperate AFW Area- 9 FGV 405B, AD! BA8 Low- to Moderate Famed Combustibic Leading Flov: e:ontro valves- Zoe 17-4 FGV-405G AG5-XAS Tr-ansient Comfbustibi: Controls FGV 405B, 405G, er Zone419 16V 406A Minimal Ignitn Seuriees FGV 406A Zetie 39A Helt WOr!k & Ignition Sourcc Controls Zone 43A Pertabic Extinguishers in the ar-a-Zone 45 Hose Stations On the arca Zone 46A.

F-ene 50A.

NL-11-014 Docket No. 50-247 Attachment 3 Page 11 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

..... . . .. TABLE RAI-.1.1.1 N N . ..

OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Useof Credited OMAs

~'OMA N NN SRequired OMA' c1noeI of Cables of Concern2 Fire Protection Defense inDet N NNN N N ~Fire Zone.. N Area 3 AE2-BA9 Law to Mede"atc Foxed Co-bustib Loadn Zene 43A EG-EIS -GSG5/G- Tr-ansient Combustibic Controls EWF6-lAG9ll* Minimal ignitll n Seurlecs EWF61 AG9M0 Hot Work & ignition Seur-ec Contr-els EWF61 ECE19/01 Portable Extingulsher-s On the zone EWF61 ECE19/02 Hose Station in the zone Area-3 EGE!8 GGS/01 Loew to Moderate Fixed Cembustibic Leading Zone 46A EWF61 AGW/01 Transient Cornbustiblie Controls EWF61 AG91G-2 Minimal ignit en SOUrees EWF61 ECE19101 Hot Work & 1-ito ControlS eorc EWF61 ECE19102 rortablcetigshr in the zene Hose Station n the zone Transfer 21 AFW Area K 21AFP JB1-PT1/2 Low Fixed Combustible Loading Pump to ASSS power Zone 60A PT1-A16 Transient Combustible Controls source Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hydrants in adjacent yard

NL-11-014 Docket No. 50-247 Attachment 3 Page 12 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 r TABLE RAI-01'.1-1

OMA Initiator Cables of Concern and Mitgatigng eatures nom/zing the Potential to Require Use of Credited OMAs n... 4>.: ... :: ,,* * * *

i Required OMA 1 4Jnitiator Area 9 Comnponent of2 Cocr' Cables of Concern2 Fie rotection Defense in Depth3 4 Fire

~t 2 ~Fire Zone' 4 ________

Area K 21AFP JB1-PT1/2 Low Fixed Combustible Loading Zone 65A PT1-AI6 Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hydrants in adjacent yard Open 21 AFW Pump Area K FCV-1121 3B1-YN9 Low Fixed Combustible Loading recirculation bypass Zone 60A Transient Combustible Controls valve Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hydrants in adjacent yard Area K FCV-1121 JB1-YN9 Low Fixed Combustible Loading Zone 65A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hydrants in adjacent yard Operate 21 AFW Pump Area K FCV-406A PU9-JG2 Low Fixed Combustible Loading flow control valves to Zone 60A LL8-JF5 Transient Combustible Controls control AFW flow to Minimal Ignition Sources Steam Generators 21 FCV-406B PU9-3H1 Hot Work & Ignition Source Controls

& 22 Portable Extinguishers in the zone Hydrants in adjacent yard Area K FCV-406A PU9-3G2 Low Fixed Combustible Loading Zone 65A LL8-IF5 Transient Combustible Controls

NL-11-014 Docket No. 50-247 Attachment 3 Page 13 of 13 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 OM

~ <7TABLE RAI-0.1.-17 InitiatorCableso0f;Concern.and Mitigating Features Minimizng the Potentialato Require Us e-.of Credited OMA's Req dOMAlato Component o Clfe*on*s.of., .

RequlrediOMA.> F*aefrea*

Are In:*t.ator ,.mpoej.t. *.bl .FreI t*.nemrCo, . Protection.Defense in*Depth*13 S.. .. . Eire Zone' Minimal Ignition Sources Hot Work & Ignition Source Controls FCV-406B PU9-JH1 Portable Extinguishers in the zone Hydrants in adjacent yard Transfer 23 CCW Area P 21CCP AG4-M43 Exemption granted for App R II.G.2 in this area - SER Pump to ASSS power Zone 1 22CCP AG9-M44/01 October 16, 1984 feed if normal 23CCP EZG3-M45 Area Wide Smoke Detection power/control is lost EZG2-A_]3/01 Low Fixed Combustible Loading EZG2-EDF9 Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adjacent zone Start Appendix R Area P 21CCP N/A Area Wide Smoke Detection Diesel Generator Zone 1 22CCP Low Fixed Combustible Loading (ARDG) if normal 23CCP (Reference Table Transient Combustible Controls power and offsite RAI-01.1-2) Minimal Ignition Sources power are lost Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adjacent zone

ATTACHMENT 4 TO NL-11-014 Revised Table RAI-01.1-2 from Entergy Letter NL-1 1-006 dated January 19, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26

NL-11-014 Docket No. 50-247 Attachment 4 Page 1 of 20 Summary of Required Changes to Table RAI-01.1-2 from Entergy Letter NL-11-006 dated January 19, 2011 Change Reason for Change REVISE the Associated Cables column to ADD "JB1-L91" for This cable was inadvertently omitted from the table Fire Area J for the OMA of "Repower instrument buses IBUS23 and IBUS23A from backup source" REVISE to DELETE the OMA "Locally operate AFW flow This OMA was previously WITHDRAWN in Entergy Letter NL control valves FCV-405B, 405C, or 406A" for Fire Area J 100 dated September 29, 2010 and was inadvertently included on the table REVISE the Comments/Conclusion column to ADD "a Clarification potential spurious closure signal resulting from" for Fire Area J for the OMA of "Open valve 288 and close valve LCV-1 12C"

NL-11-014 Docket No. 50-247 Attachment 4 Page 2 of 20 ORIGINALLY PROVIDED INENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 I

Operate 22AFW 21AFP EDC5-M74/1 Open circuit, Motor-driven Previously granted exemption (see pump (turbine 23AFP EDC5-M74/2 cable short, AFW pump is Table RAI-01.1-1) credited low driven) ELDI1-EWC26 ground fault disabled hazards of the area, smoke detection system, and radiant energy shields JB1-PT1/1 between pumps and ERFBS on 23AFW PT1-A19 pump power cable. Likelihood of XD7-M75/1 damage to both motor driven pumps, XD7-M75/2 and therefore the need to perform the OMA, is considered extremely low.

Open/check PCV-1139 JB1-PT1/3 Open circuit, intra- Valve(s) may This OMA is required only if the use of open 22AFW PCV-1310A PT1-RH7 cable short, spuriously 22AFW pump becomes necessary, due pump steam PCV-1310B PT1-YL4 ground fault, inter- close or fail to loss of both motor-driven AFW supply valves cable short closed pumps as discussed above.

EWZ63-ENX1 JB1-YN9 S94-EWZ63 Previously granted exemption (see S94-S93 Table RAI-01.1-1) credited low S94-YN9 hazards of the area, smoke detection system, and radiant energy shields EWZ64-ENX2 between pumps and ERFBS on 23AFW JB1-YP1 pump power cable. Likelihood of S95-EWZ64 damage to both motor driven pumps, S95-S92 and therefore the need to perform the S95-YP1 OMA, is considered extremely low.

NL-11-014 Docket No. 50-247 Attachment 4 Page 3 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 T-ableRAI-01.1-2 Credite nd1C32 OM~s Fire Area"CM~

CredtedOM~sAndCabe/Gompopenit failures That May Require the Us~e of the Credited PMO 1<Type f cable< Effect of ca~bleK OMA ~~Affected ~ Associated failIure(s),that may ~fail ure thatComts/onlin Co~GMponent~s) CablIes ~ cause need f~or,. 1!ads to need

-OMA~ for OMA Operate 22AFW FCV-405A JBl-LV1 Open circuit, intra- Valve(s) may This OMA is required only if cables for pump flow through D (for JB1-LV2 cable short, be spuriously all flow control valves for a given AFW control valves 22AFW pump) JB1-LV3 ground fault, inter- opened or pump are damaged, and remote to align AFW JBI-LV4 cable short closed control of all valves is lost. Given the flow to selected FCV-406A ELZ27-YN6 limited fire challenge expected in this steam through D (for JF5-YN6 area, as underscored by the referenced generator(s) 21 and 23 AFW PU9-JG2 exemption, loss of control of all FCVs pumps) ELZ28-YN8 for either the motor-driven AFW JF-Y pumps or the steam-driven AFW pump LL8-JF5 is considered a low-likelihood PU9-JH 1 occurrence.

ELZ29-YN7 The subject OMA is directed at a JF9-YN7 scenario in which both motor-driven LL9-J F9 AFW pumps have been rendered PU9-JF2 inoperable by fire damage, thereby ELZ3-YN5requiring local use of the turbine-JF93-YN5 driven pump. The associated cables PU9-JF9 for the motor-driven auxilary PU9-JF9feedwater pump flow control valves (FCV-406A through FCV-406D) are also listed, to illustrate the number of fire-induced cable failures that would be necessary to require the use of the subject OMA.

NL-11-014 Docket No. 50-247 Attachment 4 Page 4 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 Align charging Valve 227 ECD3-EXF6/2 Intra-cable short, Loss of power This OMA is unlikely to be needed for makeup path to ground fault, or to valve 227, a Fire Area F event, since HCV-142 RCS (locally open circuit causing it to (the normal charging makeup flowpath open bypass fail in the flow control valve) does not have valve 227 to normal cables routed through Fire Area F.

mitigate a position Only the unlikely concurrent scenario spuriously (closed) and of loss of the instrument air supply to closed HCV- rendering it HCV-142 (as the result of fire damage 142) inoperable for to instrument air header piping in Fire remote Area F) could cause HCV-142 to fail opening from closed, thereby creating the need for the CCR. performing the OMA to manually open bypass valve 227. Refer to Entergy response to RAI-09.1 in the September

29. 2010 submittal.

Align charging LCV-112C CK1-JB5/1 Open circuit, intra- LCV-112C fails The minimal hazards of the area and pump suction LCV-112B CK1-YP3 cable short, open or fails active fire protection features, as source to RWST PQ3-]B9/8 ground fault, inter- closed; LCV- summarized on Table RAI-01.1-1 (close LCV- YZ1-JB5 cable short 112B may fail minimize the potential for a significant 112C, open to fire capable of causing the cable 288) automatically damage necessary to initiate this OMA.

open As described in Entergy's September 29, 2010 submittal, alignment of a reliable suction source (valve 288) and return of a charging pump to service is

NL-11-014 Docket No. 50-247 Attachment 4 Page 5 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 STabft-RAI-01-1&2

____________ Credite.d * , * ,

P2 Fire Area F.

_Cre__ .M**tred MAs And G*able/Component*tailures That Ma Require the Use of the Credited 0MM" Type of cable~ Effecrto Icbl OM ~ Affected ~

OMpAnei(.s)e Asso~ciated~ 1ailure()thtmy

, fiueha comments Conclusion Compnents) Cblescause' need for leads. to neecd

_________ ~~~OMA for OMA' _ _________

required within nominally 75 minutes.

With respect to the potential charging prompt damage concern caused by loss of all suction sources, the proceduralized control room operator action to secure the credited charging pump on receipt of a smoke alarm from the affected plant area can be expected to effectively protect the pump from any damage potential. As described in the response to RAI-01.3 herein, upon placing the pump control into "pullout," any subsequent spurious start signals are effectively locked out, and present no threat to restart the pump.

Transfer BUS3A A14-PT2 Intra-cable short, Loss of normal The success logic for IBUS23 and Instrument AI5-PL2 ground fault, or power source IBUS23A requires a power source from Buses 23 and PL2-JA2/2 open circuit to Instrument EGA8 (Static Inverter 23), which is 23A to alternate PL2-M42 Buses 23/23A normally fed from PPNL23, which is fed power PT2-JA2 from BATTCHG23, which in turn is fed from 480V MCC26C, which is fed from BUS3A. The alternate power source for IBUS23 and IBUS23A is MCC29A, which is fed from BUS5A.

NL-11-014 Docket No. 50-247 Attachment 4 Page 6 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 Table RAI-U11-A-

___________. . 'Credited QMAs And Cable/Component Failures That May Require the* Use of the Credited OMAs

Type of cable Effect of cble AAffected uAssoiated may

, failure(s),that failure t*hat CommentS / Conclusion

~Component(s) Cables cause need for leads to need..om.e....Con

________OM~A ~ Kfor OMA The above described buses, power panel, and MCCs are located in Fire Area A.

As stipulated by Appendix R, a loss of offsite power is typically presumed to occur concurrent with a fire. However, circuit and routing analyses performed for Fire Area F have confirmed that offsite power distribution is not impacted by a fire in this area.

Therefore, it can be expected that the 480V distribution system, including BUS3A, will remain energized during this scenario.

If offsite power is nonmechanistically assumed to be unavailable during a fire in Fire Area F, the emergency diesel generators can be expected to automatically supply power to the safety-related 480V distribution system. Bus 3A is fed by 22EDG.

In the unlikely event that BUS3A and therefore Instrument Buses 23 and

NL-11-014 Docket No. 50-247 Attachment 4 Page 7 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 29 ~IP2 Fire Area&F -

1fece 1soiae Credited OMAs And Cable/Component Failures- Thda*May Require the Use of the Crediteod

. lOM -

~ ~.j 7Type of cabl~e iEffect of cablIe 7 OMA Afetd ~soitd

'alr s)t tm y fiue~~h~~yComnments failure that Con~clusion

.Compo.nents) Cable cause need for* .leads to need",

_________K . ~OM for OMA _ _ _ _ _ _ _ _ _ _ _

23A are not automatically repowered by the EDG, it can be expected that Static Inverter 23 will remain operable for a significant time, backed by 125VDC Battery 23, until the manual action to transfer to the alternate power source can be accomplished.

Given the low likelihood of loss of BUS3A due to fire damage to cables in this fire area as described above, the need to implement this OMA is also

____________ I ____________ I ____________ -I ______________ J ____________

considered to be low likelihood.

NL-11-014 Docket No. 50-247 Attachment 4 Page 8 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 P2Fire Area..H Credited OMAs And Cable/Componernt Failures That Mav Require the Use of the Credited OMAs

." Type ofcable . le Effect of..... .....

Associated failur(s) that may

,Af*iecte failure that Comment

, / :l,.

mponent(s) Cables . cause need for leads* nd'

________ ________ OMA ~ for OMA.

Close IA-501 to Valve 204A Y17-H55 Intra-cable short, Valves 204A The fire challenge within Fire Area H fail open valves Valve 204B YI5-H50 inter-cable short and 204B are (reactor containment) is minimal 204A and 204B spuriously during plant power operation. The closed due to principal hazard, the RCP lube oil internal cable inventories, are secured by virtue of oil fault collection systems that capture and conduct any oil leakage to collection tanks located in the containment annulus area, away from any hot surfaces and ignition sources. The potential for a fire within this area, during plant power operation, sufficient to cause damage to both 204A and 204B cables, is considered to be low. Either valve 204A OR 204B remaining open is sufficient to support normal RCS makeup from the CVCS charging pump selected for use.

Open IIP-50OX All normal All cables Intra-cable short, Loss of all The fire challenge within Fire Area H to enable ASSS safe-shutdown associated with open circuit, normal (reactor containment) is minimal pneumatic instrument the following ground fault, or (electronic) during plant power operation. The instruments channels for normal inter-cable hot instrument principal hazard, the RCP lube oil steam instrumentation short channels for inventories, are secured by virtue of oil generator level, channels for the any of the collection systems that capture and pressurizer parameters primary or conduct any oil leakage to collection

NL-11-014 Docket No. 50-247 Attachment 4 Page 9 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 7e O d T61a5iuRAI-eo.1h 2 I PIF2 Fire Area H Credited OMAs And Cable/CoMDonent Failures That May Require the Use of the Credited OMAs

~. ~Type of cable o Effectof cable

,OMA ,*Affected Associated

failure(s) thatmay, ,failure that , . Cl.

Component(s) Cables cause need fr .leads..o need o ., oncusion

_______ MA_ Kfor OMA level, and listed at left: secondary tanks located in the containment pressurizer EPC3-H39/4 system annulus area, away from any hot pressure EPC4-H41/4 parameters surfaces and ignition sources. The EPC4-H41/3 listed at left. principal area of common routing of EPC3-H39/3 normal instrument channel cables is in PN8-H39/2 the electrical penetration area of PR3-H41/2 containment. The cables in this area PR4-H33/2 are of asbestos/glass braid jacket PR4-H33/3 construction (or other IEEE 383 Flame ETC5-EZC9 Test qualified construction), the area is EZC9-H27 devoid of ignition sources, and the ETD4-EZA5 area is equipped with a smoke EZA5-H52 detection system. The potential for a ETC6-EZD1 fire within this area, during plant EZD1-H30 power operation, sufficient to cause ETD5-EZA6 damage to multiple trains of normal EZA6-H20 instrument channel cables, is ETC7-EZD2 considered to be low.

EZD2-H20 ETD6-EZA7 EZA7-H21 ETC8-EZD3 EZD3-H23 ETD7-EZA8 EZA8-H22

NL-11-014 Docket No. 50-247 Attachment 4 Page 10 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 o,*

=*;*

,*

o .... s .o* . : :Table. RAI-01.1-;2*, : . .. .. ... *,. .. ' , :: i iR2 Fire'Area 3

___________ tCredited OMAs And Cable/Component Failures That May Require the Use of the Credited OMAs Type of cable Efect o ci~iable MA*

.Affected Associated fcailure(s) that may

ailure that .. . .

Component(s) Cables IM cause needforo ledCo edomments leadsto need, Conclso

_____ ___ ____ _____ ___ ____ __ ~ OMA forOMA _ _ _ _ _ _ __ _ _ _ _ _

Open breakers, 480V Bus 5A BUS5A: Intra-cable short, Affected circuit A loss of offsite power may occur as pull fuses at 480V Bus 6A AD1-BA8 open circuit, breakers may the result of a fire in this area, given two breakers on AG5-XA5 ground fault, or not trip on that the switchgear and cables Bus 5A and 6A PC9-XA5/1 inter-cable hot command associated with offsite power PC9-XA5/2 short distribution are located in this area.

XA5-WU9 The EDGs, which are not located in this fire area, and which have no BUS6A: cables routed through this area, can AC4-BA6 be expected to automatically repower JC2-YA9 480V BUS5A and BUS6A.

The cables listed for BUS5A include the incoming normal 6.9kV feeder cable (AD1-BA8), which is connected to the Bus 5A Station Service Transformer (SST) Supply Breaker, and control cables associated with the Service Air Compressor. The cables listed for BUS6A include the incoming normal 6.9kV feeder cable (AC4-BA6), which is connected to the Bus 6A SST Supply Breaker, and control cables associated with the main turbine auxiliary oil pump.

NL-11-014 Docket No. 50-247 Attachment 4 Page 11 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 Table.RAI-01.1-2 IP2,Flre'Area I A . Credited 0MAs And Cable/Component Failures That Maa Require the Use of the Credited OMAs

." 'Type of cable Effect of cable OMA Affecte Associated ,failure(s) that may failure that ,,,,,s' Conclusion Cbles

.Component(s) . cause neefor leads toneed .... .........

0MOf1A for OMA"'I With respect to the OMA to manually trip breakers for the Station Air Compressor and Turbine Auxiliary Oil Pump, the OMA need only be implemented at Operations discretion, to secure the described loads, if desired. The nominal load imposed by these components would not be expected to challenge EDG load capacity, given the minimal equipment set associated with the post-fire safe-shutdown model.

With respect to the potential OMA to manually trip the Station Service Transformer Supply Breakers, the IP2 SSD analysis identified a potential concern that if the SST Supply Breaker remains closed and a fault occurs on the incoming feeder cable, the 480V bus could back-feed into the fault through the associated SST. However, the SST supply breakers, which are located in Fire Area A, can be expected to automatically trip on undervoltage (which would be caused by faulting of

NL-11-014 Docket No. 50-247 Attachment 4 Page 12 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

..... .IP2 Fire Area I

__,_________ *Credited OMAs And.Cable/Component Failures That May Require theUse of the Credited OMAs-Tyeo al Effect of cable:

, .. Affected Associadted failure(s)* that may failure thatm Component(s) Cables cause-need for leads to nee

~ OMAf for OMA>

the incoming power supply cable).

The circuits and control power associated with the SST Supply Breaker undervoltage trip function are located in Fire Area A, and would not be expected to be impacted by a fire in Fire Area J. Therefore the need to manually trip the SST Supply Breaker in such a scenario is of extremely low likelihood.

This OMA is NOT necessary to enable the restoration of power to the safety-related 480V buses, or to ensure the operability of the EDGs. Therefore, the likelihood of need to perform this OMA is considered to be low.

Repower PPNL23 EDB8-EPB3 Intra-cable short, Loss of normal The success logic for IBUS23 and instrument BUS3A AA3-BA5 ground fault, or power source IBUS23A requires a power source from buses IBUS23 EGA9-EDB8/4 open circuit to Instrument EGA8 (Static Inverter 23), which is and IBUS23A EGA9-EDB8/5 Buses 23/23A normally fed from PPNL23, which is fed from backup 3131-L91 from BATTCHG23, which in turn is fed source from 480V MCC26C, which is fed from BUS3A. The alternate power source for IBUS23 and IBUS23A is MCC29A,

NL-11-014 Docket No. 50-247 Attachment 4 Page 13 of 20 ORIGINALLY PROVIDED INENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

'Table 201..1-2 SIP2 Fire Area']

______Credited OMAs And Cable/Component Failures That May* Require the Use of the Credited OMAs Type of cable Effect"of cable' .

Affected Associated s) that may: faailure that .. o MA AC..

. . . .. omments.Conclusi ..

Component(s) Cables cause, nedo forr,, lead's to nee d :%..

_________ p OMA for OMA A

which is fed from BUS5A.

Cable AA3-BA5 is the normal 6.9 kV power feeder to BUS3A. Failure of this cable will result in deenergization of BUS3A, and the emergency diesel generators can be expected to resupply power to BUS3A. However, it can be expected that Static Inverter 23 will remain operable for a significant time, backed by 125VDC Battery 23, until the manual action to transfer to the alternate power source can be accomplished.

Cable EDB8-EPB3 is the power supply cable to 125VDC PPNL23 from Battery

23. PPNL23 is located in Fire Area A, and Battery 23 is located in a masonry enclosure, identified as Fire Zone 25, in Fire Area J. The cable route traverses from Fire Zone 25 on the 33' elevation of the Superheater Building through adjoining Fire Zone 270, to PPNL23, which is located in the Cable Spreading Room, Fire Area A, also on

NL-11-014 Docket No. 50-247 Attachment 4 Page 14 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011

'Table RAI-OL11-2.

TP2 Fire Area J SCredited OMAs And Cable/Component Failures That Ma Re uire the Use of the Credited OMAs'

'*,u. * ... *..** ....

AffeAcetedd..Asssso teci ...

ted f SType cable~

.ofthat may.

uefaitalayurefdu~~t Effect of that.

failur.e cable at .... .:,. ;:.::

()fetdO sMcaed dA~ L d n~ Commhents /Conclusion

.. . .. Compponent(s) .... C ables cau se need for leads to need DMA' ýforOMA the 33' elevation. The area of Fire Zone 270 traversed by the cable is characterized by minimal fixed combustibles and ignition sources.

Cables EGA9-EDB8/4 and EGA9-EDB8/5 are located entirely within Fire Zone 25, and are not subject to fire damage other than a potential fire at Battery 23. This room is a restricted access area, not subject to routine personnel access, and devoid of combustibles or ignition sources other than the battery cells. A fire within the Battery 23 room (Fire Zone 25) can be expected to be confined within the room, and present no impact to other plant equipment.

Given the low likelihood of loss of BUS3A or PPNL23 due to fire damage to cables in this fire area, the need to implement this OMA is considered to be low likelihood.

6eee4+y eperate FGV 405B Gables intra cablc fault, Le~ssof-peweF The listed eables are eonservatively AFW-w FV-4G asscited wih 1 AsAb i

NL-11-014 Docket No. 50-247 Attachment 4 Page 15 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011 STable RA-O1-1.i-2 ** r

> PFire Area J .-

Credited, OMAs And .3able/Component Failures.That May Require the Use of the Credited OlMAs Type of cable Effect ofcable Affctd ssoiaed sCables, t- failure(s~) that miay~ failure that CMA CGomponent(s) cause need for*1/4 leads to peed* .

< , C- O, fl. S hcConclunAffete.

US.p KOMA ~ for. OMA control va,, ,GV-O*4e pstr.e.. .. ,oruit; Ointcr able renders the impct thc availability of the FGV 405113 peweF supplies fatlk aiF operated upstrcam pewer supplies to IBUS2-2 405G, or FC... to BUS22 and valvetnable and which are MGG24A and

.BUS23.

4G6 1e,*: ,be r.emetelly MG.29A, whieh arc On turn supplied eent~elle by 480Y Buses 2A and 5A-,

MGG24A rspetively. MGG24A is ll-ated 1.n (Ieeated in -FiFe thiS firc arca EGE18 GG5101 Helwever, eables AE2 BA7 and A91 EWF61 A9101 BA8 are the normal 6.9k--l fcLder EWF61-AG9102 eables supplying the station ser~cee t sWF64, rrs

-ansf*o on 48 buses

2A and EGE19101 SA, respectively. Faiiurc of the 6.9 EWF64- powcr supply eablc to either bus-EGE19102 would be mitigated by resupplying power to the buses via the ED~s.

480'. Buses 2A able AC5 X-5 is associated with the (BUS.2A)-n Station Air ComnprcSS0r on Bus SA, SA fBUS!5A)-- and failurcs of this cable de net present thc potentiall to disable the AE2 BA91 asselatd 8 us i ight f te AD! BA8 above, the likellihood of need te AGS XAS pecfermf the OMA to locally epcratc l of the listed ARl flow lontrol valves is eonsidered to be a low-.

NL-11-014 Docket No. 50-247 Attachment 4 Page 16 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 IP22Fire Area

... ___"_______ . Credited OMAsAnd Cable/Component Failures Thiat May Require the Use of theCre~dited OMAs Type of cable'- . Effect'of cable OMAAffected Associated failure(s) that may failuire hat Co:,ments /

Component.s) Cables

.to cause need for lads need

________ ________OMA' for OMA?

Open valve 288 LCV-112B Cables Intra-cable fault, Loss of power The IP2 SSD analysis conservatively and close valve LCV-112C associated with ground fault, open to LCV-112B, provides for the listed OMA, to provide LCV-112C upstream circuit, inter-cable rendering it a means to mitigate a potentially failed supply to LCV- fault inoperable for LCV-112B. LCV-112B provides a 112B power automatic or backup suction source for the charging source, 125V remote pumps, from the RWST. However, DC Distribution manual normal charging pump suction valve Panel 22 opening (VCT outlet valve) is not impacted by A (DPNL22): potential spurious closure resulting from a fire in Fire Area 3, and hence MCC24A there would be no expectation of need (located in Fire for the automatic or remote manual Area 3) use of LCV-112B. As a result, the ECE18-CC5/01 implementation of this OMA is EWF61-AG9/01 considered to be of low likelihood.

EWF61-AG9/02 EWF61-ECE19/01 EWF61-ECE19/02 ECE19-MN3/01 480V Bus 2A (BUS2A)

AE2-BA7

NL-11-014 Docket No. 50-247 Attachment 4 Page 17 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011

~Table RAI~O1~

CreditedOMAs And Cable/ComponentFailures That Ma Require the Use of the Credited OMAs STypeof cab~le Effect of cable, AAffectd Associated failurb(s) that may .failure thmatm".. " Conclus"on Cmoets Cables cause need for' leads to need Transfer 21AFW 21AFP JB1-PT1/2 Intra-cable fault, 21AFP circuit The cables are routed in rigid steel Pump to ASSS PT1-A16 ground fault, open breaker is conduit, along the south wall of the power source circuit rendered area. They are routed vertically from inoperable by the AFW Pump Room below the area remote control and exit through the south wall of the area. The exposure within the area is minimal, and fixed combustibles and ignition sources in the area of the conduits are minimal. Given the minimal potential fire challenge to the cables, the likelihood of need for implementation of this OMA is considered to be low.

Open 21 AFW FCV-1121 JB1-YN9 Intra-cable fault, FCV-1121 may The cable is routed in rigid steel Pump ground fault, open spuriously conduit, along the south wall of the recirculation circuit, inter-cable open or close area. The conduit is routed vertically bypass valve fault from the AFW Pump Room below the area and exit through the south wall of the area. The exposure within the area is minimal, and fixed combustibles and ignition sources in the area of the conduit are minimal.

Given the minimal potential fire challenge to the cable, the likelihood of need for implementation of this OMA is considered to be low.

NL-11-014 Docket No. 50-247 Attachment 4 Page 18 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011

.. =.. * * ' ....

= =: o* ÷ , ....... '*o, TableRAM -01. 1-2=* ,* , . . .. i , *:, j=

IP2 FireAr~ea ..

Credited OMAs And Cable/Component Failures That aaRequire the Use of tbe Credited OMAs Type of cable .. *Effect 6f cable

.... .Affected "Associated .aralure(s),that may fafilure that ,." " .

Comnponent(s) Cables cause, need for{ leads to~needComns/Cpuio

.OMA <for OM~A j Operate 21 FCV-406A LL8-JF5 Intra-cable fault, FCV-406A, The cables are routed in rigid steel AFW Pump flow FCV-406B PU9-JG2 ground fault, open FCV-406B may conduit, along the south wall of the control valves PU9-JH1 circuit, inter-cable spuriously area. They are routed vertically from for 21 and 22 fault open or close the AFW Pump Room below the area steam and exit through the south wall of the generators area. The exposure within the area is minimal, and fixed combustibles and ignition sources in the area of the conduits are minimal. Given the minimal potential fire challenge to the cables, the likelihood of need for implementation of this OMA is considered to be low.

NL-11-014 Docket No. 50-247 Attachment 4 Page 19 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19, 2011 Table RAI-01. 12 .

IP2 Fire Area P . .

Cr~edited OMAs And~Cable/Cornponent Failures That May Require the Use of the Credited OMAs

~Typeof cable ~Effect of cable 7 Aff~,eted) A~ lssoiae fajilure(s) that may$ failur~e that ~ s c 1 QMA ~ Compoented) ,sCiableds cause need for leads to need .o ~~cso K~. OMA Jfor OMA V Transfer 23 21CCP AG4-M43 Intra-cable fault, CCW pumps Separation features within the area, an CCW Pump to 22CCP AG9-M44/01 ground fault, open are rendered ERFBS installed on the 23CCP power ASSS power 23CCP EZG3-M45 circuit inoperable supply conduit, insignificant fixed feed if normal EZG2-AJ3/01 combustibles and ignition sources, as power/control is EZG2-EDF9 acknowledged by a previously granted lost exemption for this area, make loss of all three CCW pumps, and therefore the need to implement this OMA, a

____________ ____________low-likelihood event.

Start Appendix 21CCP N/A N/A N/A Further review has confirmed that Fire R Diesel 22CCP Area P presents no impact to cables or Generator 23CCP components associated with the onsite (ARDG) if power supplied by the safety-related normal power EDGs (21EDG, 22EDG, 23EDG). For and offsite the fire scenarios that may be power are lost postulated for Fire Area P, there is no credible event that would require

___________ ___ ___ ___ ___ _ ___________ implementation of this OMA.

NL-11-014 Docket No. 50-247 Attachment 4 Page 20 of 20 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-006 DATED JANUARY 19,2011

.4K ~~~IP2 Fire Area YD j ~ 9*~*

!. Credited 0MAs And Cable/Component Failures That May Require the Use of the Credited OMAs: . I IA*Type ofcable -Effect of cable OMA . ected Component(s)-

A..sociated Ca:bles failure(s)that may failure that

.aulse need for.lead*t*o need, Comments/ Conclusion OMA - for OMA Align charging Valve 227 ECD3-EXF6/2 Intra-cable fault, Valve 227 may The described OMA (manually open makeup path to ground fault, open be rendered MOV 227) is only required if it RCS circuit inoperable by becomes necessary to bypass a failed-remote closed normal charging path flow control, or control valve, HCV-142. While may normally-closed valve 227 may be spuriously rendered inoperable, or may open/close spuriously open or close in response to cable failure, normal charging flowpath valve HCV-142 has no cables routed through Fire Area YD. Hence, HCV-142 can be expected to continue to operate normally, and there is no need to implement the OMA to manually operate valve 227.

v t e Letter Sequence Response to RAI
TAC:ME0798, (Approved, Closed)
Initiation Request, Request, Request, Request, Request Acceptance... Administration Questions Answers 10 February 2011 Results Approval, Approval Other: ML112010672
MONTHYEAR2011-11-21 [Table View]

NL-11-0141, Revised Tables from Responses to Requests for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

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NL-11-0141, Revised Tables from Responses to Requests for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

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