NL-11-013, Revised Tables from Responses to Requests for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

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Revised Tables from Responses to Requests for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions
ML110540322
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 02/10/2011
From: Joseph E Pollock
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-013, TAC ME0799
Download: ML110540322 (80)
v • d • e


Text

{{#Wiki_filter:- Entergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President NL-1 1-013 February 10, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Revised Tables from Responses to Requests for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799) Indian Point Unit No. 3 Docket No. 50-286 License No. DPR-64

References:

1. Entergy letter NL-1 1-007, Response to December 16, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," 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-10-101, "Response to August 11, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated September 29, 2010
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-11-013 Docket No. 50-286 Page 2 of 3

5. Entergy letter NL-10-043, "Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated May 4, 2010
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-09-117, "Revision to Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated October 1, 2009
8. Entergy letter NL-09-032, "Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated March 6, 2009

Dear Sir or Madam:

By letter dated March 6, 2009 (Reference 8), Entergy Nuclear Operations, Inc, (Entergy) requested exemptions from the requirements of 10 CFR 50, Appendix R in accordance with the guidance contained in NRC Regulatory Issue Summary 2006-010 (Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions), and in accordance with 10 CFR 50.12, "Specific exemptions." A revision to the exemption request was submitted by letter dated October 1, 2009 (Reference 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-08.1-8 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-1 1-013 Docket No. 50-286 Page 3 of 3 There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, IPEC Licensing Manager at (914) 734-6710. Sincerely, JEP/gd Attachments:

1.

Revised Table RAI-06.1-1 from Entergy Letter NL-10-043 dated May 4, 2010

2.

Revised Tables RAI-08.1-1 through 08.1-8 from Entergy Letter NL-10-043 dated May 4, 2010

3.

Revised Table RAI-01.1-1 from Entergy Letter NL-1 1-007 dated January 19, 2011

4.

Revised Table RAI-01.1 -2 from Entergy Letter NL-1 1-007 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-11-013 Revised Table RAI-06.1-1 from Entergy Letter NL-1 0-043 dated May 4, 2010 ENTERGY NUCLEAR OPERATIONS, INC. Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-11-013 Docket No. 50-286 Page 1 of 18 Summary of Required Changes to Table RAI-06.1-1 from Entergy Letter NL-10-043 dated May 4, 2010 Change Reason for Change Letter with Change REVISE SSD Feature column to specify only Table RAI-06.1 discusses cables for all AFW Entergy Letter NL-10-101 33 AFW Pump in Fire Area/Zone AFW-6/23 pumps and flow control valves (implicitly) in Fire dated September 29, 2010 Area/Zone AFW-6/23, but the Required OMA per Table RAI-08.1-1 is only for the operation of 33 AFW Pump REVISE SSD Feature column to DELETE The response to RAI-1 1.1 in Entergy letter NL Entergy Letter NL-10-101 "/227" for the following Fire Areas/Zones: 043 incorrectly identified valve 227 as a motor-dated September 29, 2010 ETN-4{1}/60AS and PAB-2{5}/59A operated valve where in actuality it is a manual valve REVISE SSD Feature column to ADD These strainers were inadvertently omitted from Entergy Letter NL-1 1-013 Service Water Pump strainers 32, 34, and the table dated February 10, 2011 36 for Fire Area/Zone ETN-4{1}/60AN DELETE entry for Fire Area/Zone PAB-Cables associated with 32 Charging Pump have Entergy Letter NL-1 1-013 2{5}/4A been determined by field walkdown to not be dated February 10, 2011 routed in Fire Area/Zone PAB-2{5}/4A ADD entry for Fire Area/Zone PAB-2{5}1/17A This zone was inadvertently omitted from the table Entergy Letter NL-1 1-013 dated February 10, 2011 DELETE entry for Fire Area/Zone PAB-Cables associated with 32 Charging Pump have Entergy Letter NL-10-101 2{5}18A been determined by field walkdown to not be dated September 29, 2010 routed in Fire Area/Zone PAB-2{5}I/18A

NL-11-013 Docket No. 50-286 Page 2 of 18 Summary of Required Changes to Table RAI-06.1-1 from Entergy Letter NL-10-043 dated May 4, 2010 Change Reason for Change Letter with Change DELETE entry for Fire Area/Zone PAB-Cables associated with HCV-142 have been Entergy Letter NL-10-101 2{5}/62A determined by field walkdown to not be routed in dated September 29, 2010 Fire Area/Zone PAB-2{5}/62A REVISE SSD Feature column to DELETE This component was inadvertently included Entergy Letter NL-11-013 38 Service Water pump strainer for the dated February 10, 2011 following Fire Areas/Zones: TBL-5138A, TBL-5/43A, TBL-5/44A DELETE entry for Fire Area/Zone TBL-Cables associated with valves FCV-406A/B have Entergy Letter NL-10-101 5154A. While other cables for safe-been determined by field walkdown to not be dated September 29, 2010 shutdown components are located in this routed in Fire Area/Zone TBL-5/54A zone, none of these cables are associated with components for which III.G.2 OMAs are credited.

NL-11-013 Docket No. 50-286 Page 3 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-096.1-1 Proximity of Redundant Safe-Shutdown Cables/Components,. Fire Hazards, and Ignition Sources Within Fire Areas and Fre Zones of Concern Fire eaPrximity to Fir.Zoe~ SSD Feature. 4Significant Fixed Proxiitrtces~or Comments Lone Combustibles AFW-6 / All-three-Control Small quantities of The cable runs and Nonmechanistic ignition of control or instrument cables in the overhead 23 cables associated cable in overhead pump motors are the trays would present an immediate impact on redundant AFW trains, as with 33 AFW trays, with pumps credible ignition the trays contain (in part) control cables serving the AFW flow control pEumpe, fow- .entr-! and valves at floor sources. Cables valves elevation. The trays serving the AFW The remaining fixed combustibles, consisting of a minute quantity of a..e*oatd cablar. containing cables pumps and flow lube oil and electrical cabinets, present no credible challenge to the serving the AFW control valves are AFW components in the zone flow control valves located in or adjacent are also located in to overhead trays The smoke detection system provides assurance of early warning of a the overhead area. above the AFW fire condition, enabling brigade response prior to significant fire pumps. development. The automatic wet-pipe sprinkler system provides assurance of effective control of any significant fire that may occur, sharply limiting the scope of any fire damage.

NL-11-013 Docket No. 50-286 Page 4 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-06.11 -1 .ir, ~Proximity of Redundant Safe-Shutdown Cables/Components, K., Fi., reHazards,andIgnition Sources Within Fire Areasand Fire Zones ofConcern Proxi rnity to Fire Area// SSD Feature Sinf*cant Fixed Proximity to Ignition C .omments ZoeCombustibles Sources ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 7AS with: 32 CCW pump; combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, AFW flow control in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control South valves FCV-405B, D; in trays. The subject procedure. region of FCV-406B cables, in part, are The flame-retardant characteristics of the cables ensure that any fire Fire Zone located in these would be limited in scope and severity. 7A as trays. described The smoke detection system provides assurance of early warning of a herein .fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage. ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 7AN with: 31 AFW Pump; combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, 31 AFW Pump in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control North recirculation valve in trays. The subj3ct procedure. region of FCV-1 121; cables, in part, are The flame-retardant characteristics of the cables ensure that any fire Fire Zone AFW flow control located in these would be limited in scope and severity. 7A as valves FCV-405B, D; trays. described FCV-406B; The smoke detection system provides assurance of early warning of a herein 32 Charging Pump fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage.

NL-1 1-013 Docket No. 50-286 Page 5 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-06.1-1I Proximity of Reundant Safe-Shutdown Cables/Components, ..Fire Hazards, and Ignitio Sources Within Fire Areas and Fire Zones of Concern Fire Area* ,Proximity to Proximity to itio" Fore Ae/ SSD Featu.re Significan~t Fixed Ignitionment

  • . Zone S*.

SDFau~,

  • .Sgiiati~d::.

P Ourcesyt Coi!n**[;' Combustibles met ETN-4{1} / Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 60AS with: 32 AFW Pump combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, steam supply valve in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control PCV-1 139, steam in trays. The subject procedure. supply isolation valves cables, in part, are The flame-retardant characteristics of the cables ensure that any fire PCV-1310A, 1310B, located in these would be limited in scope and severity. and speed control trays. valve HCV-1118; 31 The smoke detection system provides assurance of early warning of a Charging Pump; AFW fire condition, enabling brigade response prior to significant fire flow control valves development. The automatic preaction sprinkler system for all cable FCV-405B, D, FCV-trays in the area provides assurance of prompt control of any credible 406B; Charging fire, sharply minimizing the potential area of damage. makeup path valve(s) HCV-142/22-; Charging suction path valves LCV-1 12B/C

NL-11-013 Docket No. 50-286 Page 6 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 .Table RAI-06.1-1 1 ".. 'I roximity of Redundart Safe-Shutdown Cables/Components, ...FireHaard, and Ignition Sources Within Fire Areas and.Fire Zonesof Concern Fire Area/ PFre oximityn to Poiiy¶oInto SSD Feature Significant Fixed ~Cmet ~ Z9 ~Ie ~Comblustibles ETN-4{1} Cables associated The dominant Ignition sources Combustibles other than cables in trays are minimal throughout the 60AN with: 32 AFW Pump combustible material consist only of cable zone. The credible fire scenario would involve transient combustibles, steam supply isolation in the zone is cable tray runs in the zone which are tightly controlled to "Level 2" limits, per administrative control valves PCV-1 31 OA, in trays. The subject procedure. I 13101B; 32. 34, 36, 38 cables, in part, are The f lame-retardant characteristics of the cables ensure that any fire Service Water Pump located in these wudb iie nsoeadsvrt strainers trays. wudb iie nsoeadsvrt The smoke detection system provides assurance of early warning of a fire condition, enabling brigade response prior to significant fire development. The automatic preaction sprinkler system for all cable trays in the area provides assurance of prompt control of any credible fire, sharply minimizing the potential area of damage.

NL-1 1-013 Docket No. 50-286 Page 7 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 "Table ,AI-06.1-1. Fir H:azards, and.Ignition Sources Within Fire Areas and Fire Zonesof Concern Fir H roximitytof +. Reudnt.... Shudwn CablesI +*o.....ents,* et++ +....i.. Proximtity to Fire Area. Fi+ Proximigy to Ignition Co.ments Zone s~ SSD Feature Significant FxdSucsCmet Sources ible ETN-4{3} Cables associated The dominant Principal ignition Combustibles other than cables in trays are minimal throughout the 73A with: 32 AFW Pump combustible material sources consist of zone The credible fire scenario would involve transient combustibles, speed control valve in the zone is cable cable tray runs, which are tightly controlled to "Level 2" limits, per administrative control HCV-1 118; 32 AFW in trays. The subject junction boxes, and procedure, or a fire initiating at the single transformer in the zone. Pump steam supply cables, in part, are electrical cabinets The flame-retardant characteristics of the cables ensure that any fire valve PCV-w 139; 32 located in these distributed throughout would be limited in scope and severity, whether the cables are involved AFW Pump steam trays. the zone, and one dry as primary or scope and b severtibles (ast the cafes are inftited isolation valves PCV-transformer, located at primary or secondary cornusibes (as in e case o a ire iniiae 1310A/B; AFW flow near the north end of at the transformer in the zone) control valves FCV-the zone. The cables The smoke detection system provides assurance of early warning of a 405C, D of concern are fire condition, enabling brigade response prior to significant fire !ocated in or adjacent development. The automatic preaction sprinkler system for all cable to trays that are trays in the area provides assurance of prompt control of any credible above one or more of fire, sharply minimizing the potential area of damage. the junction boxes and electrical cabinets. PAB-2{3} / Cables associated with Cables and valve The only credible There is no clear mechanism for ignition of the lubricating oil contained 6 Charging pump LCV-1 12B are ignition source, the within the pump suction path valves located adjacent to Charging pump The smoke detection system provides assurance of early warning of a LCV-1 12C/B the Charging pump, motor, is located at fire condition, enabling brigade response prior to significant fire containing the midpoint of the development Manual valve 288 is lubricating oil, the zone, while LCV-also located in this dominant 112B and cables are zone combustible in the located at the south zone end of the zone.

NL-11-013 Docket No. 50-286 Page 8 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TableRlAI-06.1-1 Fire Hazards, and Ignitin Sources Within Fire Aeas ad Fire Zones ofiConcern Fire Area. Proximity to Proximity to Ignition Zone SSD Feature Significant Fixed S ource. Commnt ~~Zone~j ~<: Com~bustibles I oref PASB2[5} 4A Cab!-ee associaotd with 32 Charging PuMW the zene ae small guanti"~o cable in trays, and "-'-'as aesocGate wih32-GIargiR7 Pp ae-rite-n Ignition sources are Gabies wdl spaced In the zone, transformer-, located ,n the southeast end of *hn zone. The c-ables. of conncern are routed above ono o~ermoeinto The open arrangement of the corridor and spacing between igition seuFces, and sm-all inventorn; of cables, provides I~be~ Minimal in sop*o of damage incu=rred MOM UP h

NL-11-013 Docket No. 50-286 Page 9 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 4 ~Table RA1-ut6.1 1 ~ .'Proximito Red**o "RedundantSafe-Shutdown Cables/Components,.," " Fire Hazards, and Ignition Sources Within Fire Areas'and Fire Zones of Concern Proxi mity to Fire Area./ SSD Feature Significat Fixed Prox i it to ignition Comments ~Zone SI aeSi Sources Cmet Combustibles PAB-2{51 / Cables associated Fixed This is a central The area wide smoke detection system located throughout the 17A with 32 Charging combustibles in corridor in the PAB corridor, and an additional localized smoke detection system Pump and LCV-1 12C the zone consist of 55' elev. Ignition located over and under the area of the MCCs, provides assurance cable in trays and sources are MCCs, of early warning of a fire condition, enabling brigade response incidental dry transformers, a prior to significant fire. cambleintrayesan sourer harer elcts ferywrigo iecniin nbiabiaersos combustibles. water heater, elect The flame-retardant characteristics of the cables ensure that any Cables associated cabinets, a lighting, fire would be limited in scope and severity, whether the cables are with 32 charging power supply panel wium3 andLC-Pow/ two y p l involved as the primary or secondary combustible. pump and LCV-w/ two dry 112C are routed transformers, and The open arrangement of the corridor, robust smoke detection through the an Instrument systems, and the generally wide sqacing between ignition overhead of the Panel. Except for sources, provides reasonable assurance that any fire occurring in zone. the MCCs and the zone will be minimal in scope or damage. lighting power A credible fire scenario would likely involve transient Supply Panel combustibles, which are tightly controlled in the zone to "Level 2" located at the west limits per administrative procedures and controls, minimizing the end of the zone, impact of such a scenario. electrical cabinets and other ignition sources are widely spaced throughout the zone. The cables of concern are routed above one or more of the ignition sources.

NL-11-013 Docket No. 50-286 Page 10 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-06.1-1 Proximity of Redundant SaafeShutdown Cables/Conmponerit,. Fire Hazards, and Ignition Sourc~es Within Fire Areas and Fire Zones of Concern Fire Area I ~Proximityto PoiiytoInto Zon SSD Feature .Significant Fixed SProxim'itytIgnition** Comments .Zo ~C~omibustibles 4 PAB-2{6)4 Cables associ12ate id Ignition sources are Than mianimal-igitoncUrcs and small netoyof ca-bleas 4iSA w.th*-* Charging Gembuetibles two-waste-gas P..v.de reaona-ble a.ssuran. e that any fire occurr..g In the zone PUMP thaanea 2e comproesor MOtoS will bhe minimal inscope of damage icre

minimal, and a Gable FRun oonalefing-f The Gables of small quanti'ty -*

concrn are routed cable in trays, and above ono or more Sna~dantal of the ignition combustibles. Seow~ee Cables aseocfated with 32 Chargihug Pump aro rFo t*ed th- -"-rhepd of th' zone.

NL-11-013 Docket No. 50-286 Page 11 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TableRA-611 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, andignition Sources Within Fire Areas and Fire Zones of Concern Fire Area/ Prxirt to Proximity t Ilgnition Zone SSD Feture Signi icant Fixed:... Soom 'Cmcents .Combustibles. Comments PAB-2{5} / Cables associated with Fixed combustibles Ignition sources The minimal ignition sources and small inventory of cables provide 19A 32 Charging Pump in the zone are include a cable run, reasonable assurance that any fire occurring in the zone will be minimal minimal, consisting electrical cabinets, in scope of damage incurred of a small quantity of and transformers cable in trays, and located in the incidental northeast and combustibles. northwest corners of Cables associated the zone. The cables with 32 Charging of concern are routed Pump are routed in above one or more of the overhead of the the ignition sources. zone. PAB-2{5}/ Cables associated with The fixed Ignition sources Combustibles other than cables in trays are minimal, throughout the 27A Charging pump combustibles in the consist of several zone. The credible fire scenario would involve transient combustibles, suction path valves zone are minimal, widely spaced which are tightly controlled to "Level 2" limits, per administrative control LCV-1 12B/C consisting principally electrical boxes, a procedure. of Operations and cable run, and a Raf Opromateials wnd catleruneat. Te Combustibles in this large zone are widely distributed, presenting minimal potential for significant involvement, in response to initiation by and supplies, and a cables of concern are small quantity of routed in the vicinity any single ignition source in the zone cables in trays of one or more of the ignition sources.

NL-11-013 Docket No. 50-286 Page 12 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 '.. "Table"RAI-061-1, FieHaads, and Ignition Sources Within Fire Aesand, ieZnso ocr Proximit tofRedundant.Safe-Sfutdown aD*Components, C,,... "t.FireaAneta Proximityoto Ignition Zorea SSD Feature Significant Fixed ~ ~ore ~ ~Comments [ __________________ Combustibles PAB-2{5} Cables associated with Combustibles in the The sole ignition The minimal ignition sources and small inventory of cables provide 30A. Charging pump zone consist of a source is the cable reasonable assurance that any fire occurring in the zone will be minimal suction path valves small quantity of tray run, presenting a in scope of damage incurred LCV-1 12B/C cables in trays and minimal potential for incidental materials, fire initiation The cables of concern are routed in or adjacent to the trays in the zone. PAB-2{5} Cables associated with Combustibles in the The sole ignition The minimal ignition sources and small inventory of cables provide 58A 32 Charging Pump zone consist of a source is the cable reasonable assurance that any fire occurring in the zone will be minimal small quantity of tray run, presenting a in scope of damage incurred cables in trays and minimal potential for The smoke detection system provides assurance of early warning of a incidental materials. fire initiation fire condition, enabling brigade response prior to significant fire The cables ofdelomn concern are routeddelomn in or adjacent to the trays in the zone. PAB-2{5} Cables associated with Combustibles in the The ignition sources The minimal ignition sources and small inventory of cables provide 59A Charging makeup path zone consist of a consist of the cable reasonable assurance that any fire occurring in the zone will be minimal valve(s) HCV-142/227 small quantity of tray run and a in scope of damage incurred cables in trays and junction box, The smoke detection system provides assurance of early warning of a incidental materials, presenting a minimal fire condition, enabling brigade response prior to significant fire The cables of potential for fire development concern are routed initiation in or adjacent to the trays in the zone.

NL-11-013 Docket No. 50-286 Page 13 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-06.1-1 Proximity of RedundantSafe,-Shtdown Cables/Components, S~§FireHazrs and Igition Sources Within Fire Areas and Fire Zones of Concern AFire Area Prroiimityt toInto Z SSD Feature Significant Fixed toue,, Comments-Combustibles Sourbes PA13B-2fE Cables as.ociated Cembuetiblitn e Tho m.nimal ignitin sour--es and sm.all inento; of c-able-s The sol ~ 62A with C the zone o sisnt of t source Is the Gable ProVide reasonable assurwanc that any Ire occurringi the zone makeup path va3ve(s) a small cuantitb of t cal

runs, prEAnting Will be Minimal in scope of damagerinaures SeV-1c 4/227 cabsi trays and a minimal potential Fnir d t

r etor fire initiatiogv Matericalc. Thm Gables of conce.r arge raudine OR r adedaent tothe trays in the zone. TBL-5 I Cables associated with Combustibles in the Ignition sources This zone contains 6.9kV switchgear, presenting the potential for a 37A all (31 through 36) zone include cables include cable runs, HEAF concern, if circuit breaker operational failures are postulated Service Water pump in trays, lube oil, and switchgear, MCCs, Fire detection provided in the 6.9kV switchgear area and above an strainers electrical cabinets transformers, and distributed electrical cabinets. Ma throughout the zone. The cables of prompt notification of a developing fire at these locations. The general A flammable liquids 'concern are in area coverage sprinkler system provides assurance of control of the storage cabinet is proximity to one or likely fire scenario involving transient materials, minimizing the scope located at the south more ignition sources and severity of any fire damage. end of the zone. The in the zone. cables of concern are routed in the overhead, above one or more of the combustible elements in the zone.

NL-11-013 .Docket No. 50-286 Page 14 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Proximity of RedundantrSafe-Shutdown CablesIComponents, Fire Hazards, and Ignition Sources Within Fire Aeas and Fe Zones of Concern Fire Area! Zone SSD Feature P.roximity to Significant Fixed Co mbustibles Proximity to Ignition Sources Comments' I I.............................I I TBL-5 / 38A Cables associated with all (31 through 36,48) Service Water pump strainers Combustibles in the zone include cables in trays, electrical cabinet, MCC, and flammable liquids storage cabinets, distributed throughout the zone, as well as a range of chemicals in the chemical storage area. The cables of concern are routed in the overhead, above one or more of the combutible elements in the Ignition sources include the MCC and electrical cabinet. The cables of concern are in proximity to one or more ignition sources in the zone. The minimal ignition sources and spatial separation of combustibles provide reasonable assurance that any fire occurring in the zone will be minimal in scope of damage incurred The sprinkler system in the chemical storage area and the smoke detection provided above the MCC located in the zone, provide reasonable assurance of annunciation and control of any fire development at either of these hazards zone.

NL-11-013 Docket No. 50-286 Page 15 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 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 Concern,. Fire Area Prroximity toIniin Zon :,SSD Featurne Significant Fixed " r yo Ignition Comments. Zon Cmbujstibles Souce TBL-5 / Cables associated with Combustibles in the Ignition sources This zone is provided with a full-area wet-pipe sprinkler system, 43A all (31 through 36:-8) zone include cables include the cable providing assurance of effective control of any fire that may occur in the Service Water pump in trays, electrical runs, switchgear, area. Water flow alarms received in the CCR upon actuation of the strainers cabinets, MCC, MCC, electrical sprinkler system provide effective notification to enable deployment of switchgear, and cabinets, and the fire brigade. Given the broad distribution of combustibles in the flammable liquids transformer, which area, there is reasonable assurance that a fire would be constrained to storage cabinets, are distributed a limited fire damage footprint within the zone. distributed throughout the zone. throughout the zone, The cables of as well as a range of concern are in chemicals in the proximity to one or chemical storage more ignition sources area. The cables of in the zone. concern are routed in the overhead, above one or more of the combustible elements in the zone.

NL-11-013 Docket No. 50-286 Page 16 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 S, Table RAI-06,1-1 Proximity of Redundant Safe-Shutdown Cabl Zomponents, Fire Hazards, and Ignition Sources Within Fire Areas and Fire ZonesoConcern ~Fire Area /rxmt trxiitt IgComment Zone SSD Feature ,,,nia:, t Fix Proximity to Igntition Combustibles~ ore TBL-5 / Cables associated with Combustibles in the Ignition sources The minimal combustibles in the zone, and the distribution of the 44A all (31 through 36,-8) zone include cables include the cable combustibles and ignition sources throughout the zone, provide Service Water pump in trays, electrical runs, electrical reasonable assurance that a credible fire scenario would be limited in strainers cabinets, one dry-cabinets, and scope and severity of fire damage type transformer, transformer, which and incidental are distributed combustibles. The throughout the zone. cables of concern The cables of are routed in the concern are in overhead, above proximity to one or one or more of the more ignition sources combustible in the zone. elements in the zone. TBL-5 / Cables associated The zone contains Motors on two This area is devoid of significant fixed combustibles, and a substantial 52A with: 31 AFW Pump negligible fixed penetration blowers, fire capable of challenging the integrity of the cables of concern is not recirculation valve combustibles and two electrical considered a credible event FCV-1 121; 31 AFW cabinets, represent Pump flow control the ignition sources in valves FCV-406A, B this zone. The ignition sources are located in the south end of the zone, as are the SSD cables listed as SSD Features.

NL-11-013 Docket No. 50-286 Page 17 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 Table RAI-06.1-1 Proximity of Redundant Sat e-Shut'dwn Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern FirZone A SSD Feature Significant Fixed P* -,oximit to Ini -Comments Combustibles to 'o.. TBL6-Cale asocatd Te on cotans Ignition sourcFTe iia cmutilsi the zione, and the distribution of the i4 ith 31I. AF Pump negligible-fixed consist of a cable cno mb, srtibles and ignition sources fthrughout the zone, proVIde floW control val'ves combustibles rFun, electriGca

reasonable a.ssur-ance-that - -a credible fire scen-.ario*
'-uld be FCV-406N 14 cabinet, and mo-tonr-s limited in scope and severity of fire damage on 9aveopeators.

The aMbleef I~~t t~tehe YARD-7 / Cables associated with The service water 1,..'!on sources Fire detection provided in the zone would annunciate any developing 22 (as well as the pumps and strainers consist of several fire condition, enabling fire brigade response for manual suppression of components are segregated from electrical boxes and the fire. The limited ignition sources and combustibles within the zone themselves): 31-36 the significant the SW pump motors do not present a significant fire challenge capable of rendering all SW SW Pump, 31-36 SW combustibles of the themselves pumps inoperable. Pump Strainer zone by a security barrier enclosure. Combustibles within the enclosure are insignificant.

NL-1 1-013 Docket No. 50-286 Page 18 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 F Proximity. of Redundant Safe-Shutdown Cables/Components, FireHazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area/ roximni to P roximity to Ignition ZoeSS eaueSignif icant4 Fixed Comet

  • ,one

.,'4S*D* Fe.ture Combustibles Sources Comments YARD-7 / Cables associated with This zone contains Ignition sources The fire challenge in the zone is insignificant, and any accumulation of 222 38 SW Pump Strainer only small quantities consist of the BU SW transient combustibles that could present a significant fire challenge of cables, consisting Pump and strainer would not concurrently challenge the redundant SW Pumps 31 through of the cables serving motors. A fire ignited 36, located in Zone 22 the backup SW by one of these pump and strainer, components would The required cables simply result in the for BU SW use of one of the Pump/SW System redundant operation are the pump/strainer combustibles in the combinations in the zone. area.

ATTACHMENT 2 TO NL-11-013 Revised Tables RAI-08.1-1 through RAI-08.1-8 from Entergy Letter NL-10-043 dated May 4, 2010 ENTERGY NUCLEAR OPERATIONS, INC. Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-11-013 Docket No. 50-286 Page 1 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-8 from Entergy Letter NL-1 0-043 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-2 OMA Initiator column This zone was inadvertently omitted from the Entergy Letter NL-1 1-013 to ADD Zone 60AN as an Initiator Zone for the table dated February 10, 2011 Required OMA of "Locally operate PCV-1 31 OA, 1310B to ensure steam supply to 32 AFW Pump" REVISE Table RAI-08.1-6 OMA Initiator column Cables associated with 32 Charging Pump have Entergy Letter NL-1 1-013 to DELETE Zone 4A as an Initiator Zone for the been determined by field walkdown to not be dated February 10, 2011 Required OMAs of "Locally close supply breaker routed in Fire Area/Zone PAB-2{5}/4A for 32 Charging [previously "CVCS"] Pump" AND "Locally control 32 Charging [previously "CVCS"] Pump using scoop tube positioner." REVISE Table RAI-08.1-6 OMA Initiator column This zone was inadvertently omitted from the Entergy Letter NL-1 1-013 to ADD Zone 17A as an Initiator Zone for tha table dated February 10, 2011 Required OMAs of "Locally close supply breaker for 32 Charging [previously "CVCS"] Pump" AND "Locally control 32 Charging [previously "CVGS"] Pump using scoop tube positioner." REVISE Table RAI-08.1-6 OMA Initiator column Cables associated with 32 Charging Pump have Entergy Letter NL-10-101 to DELETE Zone 18A as an Initiator Zone for the been determined by field walkdown to not be dated September 29, 2010 Required OMAs of "Locally close supply breaker routed in Fire Area / Zone PAB-2{5}/18A for 32 Charging [previously "CVCS"] Pump" AND "Locally control 32 Charging [previously "CVCS"] Pump using scoop tube positioner."

NL-11-013 Docket No. 50-286 Page 2 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-8 from Entergy Letter NL-1 0-043 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-6 OMA Initiator column Cables associated with HCV-142 have been Entergy Letter NL-10-101 to delete Zone 62A as an Initiator Zone for the determined by field walkdown to not be routed in dated September 29, 2010 Required Action "Open valve 227 to establish Fire Area/Zone PAB-2{5}/62A Charging flowpath to RCS around potentially failed closed HCV-142." Zone 62A continues to be an OMA Performance Zone. REVISE Table RAI-08.1-6 OMA Initiator column Cables associated with HCV-142 have been Entergy Letter NL-1 1-013 to DELETE Zones 27A and 30A and to ADD Zone determined by field walkdown to not be routed in dated February 10, 2011 60A as an Initiator Zone for the Required OMA of Fire Area/Zones PAB-2{5}/27A and /30A "Open valve 227 to establish Charging flowpath to RCS around potentially failed closed HCV-142" Zone 60A was inadvertently omitted REVISE Table RAI-08.1-6 OMA Initiator column Zone 21A was inadvertently included, zone 17A Entergy Letter NL-1 1-013 to DELETE Zone 21A and to ADD Zones 6, 17A, was inadvertently omitted, and zones 6, 20A, and dated February 10, 2011 20A, 60A as an Initiator Zone for the Required 60A were added as a result of response to OMA of "Locally close valve LCV-1 12C and open December 16, 2010 in Entergy letter NL-1 1-007 valve 288 to establish flowpath from RWST to Charging pump suction" REVISE Table RAI-08.1-7 OMA Initiator column Cables associated with valves FCV-406A/B have Entergy Letter NL-10-101 to DELETE Zone 54A as an Initiator Zone for the been determined by field walkdown to not be dated September 29, 2010 Required OMA of "Locally operate FCV-406A, routed in Fire Area / Zone TBL-5/54A 406B to control AFW flow to SGs"

NL-11-013 Docket No. 50-286 Page 3 of 17 Summary of Required Changes to Tables RAI-08.1-1 through RAI-08.1-8 from Entergy Letter NL-10-043 dated May 4, 2010 Change Reason for Change Letter with Change REVISE Table RAI-08.1-7 OMA Initiator column This is not a zone and was inadvertently included Entergy Letter NL-11-013 to DELETE "'YARD" as an Initiator Zone for the on the table dated February 10, 2011 Required OMA of "Locally start ARDG to supply MCC 312A in support of the use of SW Pump 38" REVISE Table RAI-08.1-7 OMA Initiator column Fire Area TBL-5 and its zones were inadvertently Entergy Letter NL-1 1-013 to DELETE Zones 37A, 38A, 43A, and 44A in Fire included on and Fire Area YARD-7 and its zones dated February 10, 2011 Area TBL-5 as Initiator Zones, and ADD Zones 22 were inadvertently omitted from the table and 222 for Fire Area YARD-7 as Initiator Zones for the Required OMA of "Locally/manually backwash SW pump strainer as required if power to strainer associated with selected SW pump is lost"

NL-11-013 Docket No. 50-286 Page 4 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 S... TABLERAI-08.1-1,. CREDITED III.G.2 OPERATOR MANUAL ACTIONS 4 4 Reurd

Actual, Actual Time Total Time to Initi Iator (1)

Teqmee toO lMPOAt~, ,~rp~t n Fire Area/Zone5 Comments RequioedplMAe Diagnose ~.Complete ~ ~Resultan~t Need for OMA3Magn4OAPerformanceMP ~OMA2 AFire Area/Zoneý Locally start 33 AFW 30 m 4.5 m 13 m TTC: 17.5 m I: Area AFW-6, Zone 23 Target: 33 AFW Pump control Pump from breaker on (a) cables Bus 6A Margin: 12.5 m; P: Area CTL-3, Zone 14 _________41% Locally operate valves-WITHDRAWN FCV-1 123, FO V.4060, See response to RAI-02.1 FCV-406D (a) The Total Time to Complete is revised to 13 minultes, whereas the previous submittals showed a value of 7 minutes for the Actual Time to Complete These notes apply to Tables RAI-08.1 -1 through RAI-08.1-8: 1. Represents the available time to complete the action to ensure fulfillment of the Appendix R performance goals

2. Elapsed time from start of announced fire event for operators in simulator environment to detect failure
3. Actual Time to Complete =travel time + time to execute OMA + time to report completion/validate action
4. Total Time to Complete (TTC) = Actual Time to Diagnose Need for OMA + Actual Time to Complete OMA Resultant Margin = 100 x (Required Time to Complete - TTC) / Required Time to Complete
5. Fire ArealZone in which the postulated tire 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-11-013 Docket No. 50-286 Page 5 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLERAI-08.1-1 FIRE AREA AFW-6 Reurd Actual Actual Time T~otal Time to OMA MA Time to Tmto to CopeeadInitiator (1)~ Required Corn Fir AeaZonCmmnt Coplete Dians Complete Resultant Fr rWoe~Cmet Need for 0MAg

Margin4, OMAPe!!rforance~

OMAý2 FlreA~rea/Zonpe'. Locally operate PCV-WITHDRAWN 1139, PCV-1310A, PCV-See response to RAI-02.1 13101B, HCV-11 118, FCV-4050 or FCV-405D (if 32 AEW Pump is used) Locally operate Steam WITHDRAWN Generator Atmospheric See response to RAI-02.1 Dump Valve (SGADV) PCV-1 134, PCV-1 135, PCV-1 136, or PCV-1 137

NL-1 1-013 Docket No. 50-286 Page 6 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 FI-FIRE AREA-N-4{1}: CREDITED 111.G..2 OPERATOR MANUAL ACTIONS Actual' OMA4*4 Req d Tm Actual TimeMA Reuieto Total Time to Initiator (I)

  • Ti e~o

,to "aRequired OMA Time'to Diagnoseo Complete andi iFire kione Comments

  • 4*/t.N'

..Complete oee n _Fe _o SFire .one Swap 32 CCW Pump to > 1 hour <lm 34 m TTC: 35 m I: Area ETN-4{1}, Zone 7AS Target: 32 CCW Pump cables alternate power supply (b) OR align city water to Margin: >25 m; P: Area TBL-5, Zone 37A Charging pumps >42% and Area PAB 2{2}, Zone 1; OR Area PAB-2{4}, Zone 17A Operate 480V Bus 3A 30 m 4.5 m 7 m TTC: 11.5 m I: Area ETN-4{1}, Zone Target: 31 AFW Pump control breaker locally to start 31 7AN cable AFW Pump Margin: 18.5 m; 61% P: Area CTL-3, Zone 11 Locally operate FCV-30 m 4.5 m 8 m TTC: 12.5 m I: Area ETN-4{1}, Zone Target: FCV-1121 control cable 1121 in support of use of 7AN 31 AFW Pump, OR Margin: 17.5 m; 58% P: Area AFW-6, Zone 23 Operate HCV-1118 30 m 4.5 m 17 m TTC: 21.5 m 1: Area ETN-4{1}, Zone Target: HCV-1118 control cable manually to control 32 60AS AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 (b) The Total Time to Complete is revised to 34 minutes, whereas the previous submittals showed a value of 10 minutes for the Actual Time to Complete

NL-11-013 Docket No. 50-286 Page 7 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-O8.1~-2, FIRE AREA ETN-4111 CREDITED lII.G.2 OPERATOR MANUAL ACTIONS ~ Actual Actua AculTime Reurd Timneto ~ to Total Time to Initiator (1) Required OMA Time to Diagniose. Comlt and Fire Area/Zone Comments. Complete Need for ~Complete .R pesuteant agndAPefrac P ~~OMA~ ~~atMri M efra~ P OMA F!T iera ne ~ Align Appendix R Diesel 75 m <1 m 50 m TTC: <51 mn 1: Area ETN-4{1 } Nonmechanistic Loss of Offsite Generator (ARDG) to Power can be postulated at outset 480V Buses 2A, 3A, 5A, Margin: 24 m; P: Area TBL-5, Zone 37A; of scenario, effectively eliminating and 312 (c) 32% Area YARD-7, Zones 131, diagnosis time 131 A; Area CTL-3, Zone 11 Swap 31 or 32 Charging 75 m 30 m 8 m TTC: 38 m 1: Area ETN-4{1}, Zone Target: 31 and 32 Charging Pump Pump to alternate power 7AN, 6OAS cables supply Margin: 37 m; ________49% P: Area PAB-2-{3} Start ARDG and align Not a separate OMA power to 480V Buses 2A, 3A, 5A, and 312 (d) Locally operate FCV-30 m 4.5 m 17 m TTC: 21.5 m 1: Area ETN-4{1 }, Zone Target: FCV-406A-D, FCV-405A-D 405B, FCV-405D, or 7AN, 7AS, 60AS control cables FCV-406B to control Margin: 12.5 m; AFW flow to Steam 37% P: Area AFW-6, Zone 23 Generators (c) Buses 3A and 312 were inadvertently omitted in previous submittals (d) This was a separate OMA in previous submittals but is herein correctly included in the OMA to "Align Appendix R Diesel Generator..."

NL-11-013 Docket No. 50-286 Page 8 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 ..TABLE RAI08.1-2 . FIREAREA ETN-4{1f} CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required OM ~44'. 'OMA ~ otal Time to Initiator (I).. ,omp.ete

and, FireAreaZone Comments sultantMargin OMA Performance (P)

Fire.Are/one, Locally open valve 227 to establish Charging [previously "CVCS"j makeup flowpath to RCS) 1: Area ETN-4{1}, Zone 60AS P: Area PAB-2{5}, Zone 62A Targets: Cables associated with. HCV-142 Travel time conservatively taken to be 10 minutes, from CCR to PAB. Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. Locally close valve LCV-112C; open valve 288 to align Charging pump suction to the RWST I: Area ETN-4{1}, Zone 60AS P: Area PAB-2{3}, Zone 6 and Area PAB-2{5}, Zone 30A Targets: cables associated with valves LCV-1 1 2B, LCV-1 120 Travel time conservatively taken to be 10 minutes, from OCR to PAB. Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. Locally control SGADVs PCV-1 135, PCV-1 136 WITHDRAWN See response to RAI-02.1

NL-11-013 Docket No. 50-286 Page 9 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 ~ TABLE RAI-08.1-2 ~ FIRE AREA ETN-4f1} CREDITED III:G.2 OPERATOR MANUALACTIONS- ~eui Actual~ OMAI RTime to

t.

Total Time to Initiator (I) Required 9MA Timeto

Diagnose, omplete and Fire Area/Zone Comments Cornet Needi for Complete
Resultant Margin OMA Performance (P)

OMA.. Fire a/Zone,* ;.o Locally operate PCV-30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1). Zone Target: PCV-1 139 control cables 1139 to ensure steam 60AS supply to 32 AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV-30 m 4.5 m 17 m TTC: 21.5 m 1: Area ETN-4{1}, Zones Target: PCV-1310A, B control 1310A, 1310B to ensure 60AS and 60AN cables steam supply to 32 AFW Margin: 8.5 m; Pump 28% P: Area TBL-5, Zones 52A and 57A Locally manually perform > 1 hour > 1 hour 15 m TTC: See 1: Area ETN-4{1}, Zone The need for periodic manual Service Water (SW) Comments 60AN backwash of the selected SW pump strainer backwash strainer is variable, depending on as required Margin: See P: Area YARD-7, Zone 222 ultimate heat sink conditions and Comments other factors. The Time to Diagnose shown is a nominal figure, and therefore TTC and Margin are not considered critical parameters for this occasional (as-needed) OMA.

NL-11-013 Docket No. 50-286 Page 10 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-3 ~ -FIRE.AREAETN-4{3}.x ' CREDITED lILGý2 OPERATOR MANA CIN K ~~ 1 OMA Requre Actual Time tuITie Total Time to Initiator (1)j ReuiedOM ~ Tmeto to Diagnos CoopComplete Fire AreaZone peqetee .OMA Tim Ctoilt~n to Compleete Comments? Need for ReulAn OM efrac ___________ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Fr Ar_ I~ea/Zone~ Operate HCV-1 1118 30 m 4.5 m 17 m TUG: 21.5 m 1: Area ETN-4{3}, Zone Target: HCV-1 118 control cables manually to control 32 73A AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV-30 m 4.5 m 17 m TUG: 21.5 mn 1: Area ETN-4{3}, Zone Target PCV-1 139 control cables 1139 to ensure steam 73A supply to 32 AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 Locally operate PCV-30 m 4.5 m 17 m TUG: 21.5 m 1: Area ETN-4{3}, Zone Target: PGV-1 31 QA, B control 1310OA, PGV-1310OB to 73A cables ensure steam supply to Margin: 8.5 m; 32 AFW Pump 28% P: Area TBL-5, Zones 52A and 57A Locally operate FCV-30 m 4.5 m 17 m TUG: 21.5 m 1: Area ETN-4{3}, Zone Target: FCV-405 control cables 405C, 4050 to control 73A AFW flow to SG Margin: 8.5 m; 28% P: Area AFW-6, Zone 23

NL-11-013 Docket No. 50-286 Page 11 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 S TABLE-RAI0.1-4~~ FIRE-AREA ETN-.4I41 CREDITED IiI.G.2 OPERATOR MANUAL ACTIONS ActualTieotal Tim oIiitr(1) ~Required to Diagnose <Actual Time Cmlt n Fr raZn Required OMA Time to Nedfr to Complete Result~eant Fir erformane Cmet PCV-1 136, or PCV-1 137 to support cooldown to RHR entry conditions

NL-11-013 Docket No. 50-286 Page 12 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-5s $.FIRE AREA PAB-2{3} CREDITED IIL.G.2 OPERATOR MANUAL ACTIONS Total~h~e OMA. Requred Actual Time ATttala Time to Ilnitiator (1) Required OMA I T ime to to Diagnosee t~oCoImplete Comnplete and Fire Area/Zone Cmet Need for Rslat OMA PerformanceCpnet Complete aAOMAReltn_____

  • MAMarginy (P

Fire Area/Zone7 Locally close valve LCV-75 m 30 mn 11 m TTC: 41 m I: Area PAB-2{3}, Zone Targets: cables associated with 11 20 and open valve 288 6 valves LCV-1 12B, LCV-1120 to align Charging pump Margin: 34 m; suction path to Refueling 45% P: Area PAB-2{3}, Travel time conservatively taken to Water Storage Tank Zone 6 and Area PAB-be 10 minutes, from OCR to PAB. (RWST) 2{5), Zone 30A Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario. I

  • + * * :
  • NL-11-013 Docket No. 50-286 Page 13 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010

, TABLE RAl-08.1-6 FIRE AREA PAB-25) CREDITED Ill G..2 OPERATOR MANUAL ACTIONS £ Required Actual Time~.Ata i Total Timne to Initiatoir (1)' RequiedreM to Diagnose Ato a Compee Complete and Fire'Area[Zone Cmet ReurdOATime to ~Need for toM Comlet Resultant OMA Performance. Comet Complete OMA OAMargin E Fire Area/Zone~ Locally close supply 75 m 30 m 7 m TTC: 37 m I: Area PAB-2{5}, Zone Target: 32 Charging Pump control breaker for 32 Charging ilAr4817,A, 1 9A, 58A cables [previously "CVCS"] Margin: 38 m; Pump 51% P: Area CTL-3, Zone Locally control 32 75 m 30 m 9 m TTO: 39 mn I: Area PAB-2{5}, Zone Target: 32 Charging Pump control Charging [previously ZA,-48-17A, 19A, 58A cables "CVCS"] Pump using Margin: 36 m; scoop tube positioner 48% P: Area PAB-2{3}, Zone 6 Open valve 227 to 75 m 30 m 9 m TTC: 39 m I: Area PAB-2{5}, tZone tTargets: Cables associated with establish Charging 27-Aj34Aq59A,6260A valve HCV-142 flowpath to RCS around Margin: 36 m; potentially failed closed 48% P: Area PAB-2{5), Travel time conservatively taken to HCV-1 42 Zone 62A be 10 minutes, from CCR to PAB. Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

NL-11-013 Docket No. 50-286 Page 14 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08. 1-6. FIRE AREA PeB-2{5} CREDITED llI.G.2 OPERATOR MANUAL ACTIONSk R ~~OMA ~ Required.. talT Actual Time Total Time to ~ Initiatorl (! ~. Rquied OA .Timto Dlagnomse. toCmle Complete and Fire"ArealZone Copete Nedo OMA Resultant OMA Performiiance ~ ~ M ~ ~Fire Are/Zon Locally close valve LCV-75 m 30 m 11 m TTC: 41 m 1: Area PAB-2{5}, Zone Targets: cables associated with 11 2C and open valve 288 6, 17A 62-1-20A, 27A, valves LCV-111213, LCV-1 112C to establish flowpath from Margin: 34 m; 30A., 60A RWST to Charging pump 45% Travel time conservatively taken to suction P: Area PAB-2{3}, be 10 minutes, from OCR to PAB. Zone 6 and Area PAB-Travel time is non-critical, since no 2{5}, Zone 30A attempt is made to perform the OMA for the initial 60 minutes of the scenario.

NL-11-013 Docket No. 50-286 Page 15 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 ~. .TABLE RAI-08.1-7 FIRE AREA TBL-51~ CREDITED uuI.G.2OPRATO MANUAL ACTIONS K ~~OMA ReqIied Actual Time Totall*Time to. Initiator (1) ~ReRequ~OA imedt to Dignose Ato a Timpet ~Complete and. Fire Area/Zone Coure ATmpe te Need for tComAlt Resu~ltant OMA Per'fbmance Comments Copee OMA OM Margin (E .Fire Area/Zone Locally operate [bypass 30 m 4.5 mn 8 mn TTC: 12.5 mn I: Area TBL-5, Zone Target: FCV-1 121 control cables valve for] FCV-1 121 AFW 52A Pump recirculation valve Margin: 17.5 m; during pump startup (e) 58% P: Area AFW-6 Zone 23 Locally operate FCV-30 m 4.5 m 17 m TTC: 21.5 m 1: Area TBL-5, Zone Target: FCV-406 control cables 406A, 406B to control (d) 52A, 54A AFW flow to SGs Margin: 8.5 m; 28% P: Area AFW-6 Zone 23 Locally operate SGADV WITHDRAWN PCV-1 134, PCV-1 135, See response to RAI-02.1 PCV-1 136, or PCV-1 137 to control secondary system cooldown (d) The Total Time to Complete is revised to 17 minutes, whereas the referenced submittals showed a value of 8 minutes for the Actual Time to Complete (e) Clarified that the bypass valve for FCV-1 121 is the component that is manually operated

NL-11-013 Docket No. 50-286 Page 16 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RA1-08.11-7 ~. CREDITED FIR ARE.A TL-5.- CREITD II..2OPERATOR MANUAL ACTIONS Required Actual Time rie Total Time to Initiator() Requied OMTime to* Danoeedfr Ata Complete and Fire Area/Zone~ ~ Cmet Required OMA Time to to Complete Cmet Complete NedfrOfA ~ Resultant OMA Performance ~OMA Margin ~Fire AreafZone Locally/manually > 1 hour > 1 hour 15 m TTC: See 1: Area TBL-5, Zone The need for periodic manual backwash SW pump Comments 37A, 38A, 43A,44A backwash of the selected SW strainer as required if strainer is variable, depending on power to strainer Margin: See P: Area YARD-7, Zone ultimate heat sink conditions and associated with selected Comments 222 other factors. The Time to SW pump is lost (use Diagnose shown is a nominal one of STR PMP-31 figure, and therefore TTC and through STR PMP-36) Margin are not considered critical parameters for this occasional (as-needed) OMA.

NL-11-013 Docket No. 50-286 Page 17 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-8 CR FIRE AREA YARD-r> CEDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Require Time Total Time to Initiator (1) Requiredan Acua Timee~~oe ~Required OMA Time to toDi~agnose 5 "to Complete Cmlt n ieAe/oeCmet Complie t e Need lfolm OM Resultant OMA Perormanceomet Locally start AROG to > 1 hour <1 m 25 m TTC: <26 m 1: Area YARD-7, Zone Nonmechanistic Loss of Off site supply MCC 312A in 22, YARD Power can be postulated at outset support of the use of SW Mri:>34 m; of scenario, effectively eliminating Pump 38 >56% P: Area YARD-7, diagnosis time Zones 131, 131A, Area TBL-5, Zone 37A Locally/manually > 1 hour > 1 hour 15 m TTC: See 1: Area YARD-7 TBL - The need for periodic manual backwash SW pump Comments 5, Zone 22. 222 37& backwash of the selected SW strainer as required if 38A,43A,44A strainer is variable, depending on power to strainer Margin: See ultimate heat sink conditions and associated with selected Comments P: Area YARD-7, Zone other factors. The Time to SW pump is lost 222 Diagnose shown is a nominal figure, and therefore TTC and Margin are not considered critical parameters for this occasional (as-needed) OMA.

ATTACHMENT 3 TO NL-11-013 Revised Table RAI-01.1-1 from Entergy Letter NL-1 1-007 dated January 19, 2011 ENTERGY NUCLEAR OPERATIONS, INC. Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-11-013 Docket No. 50-286 Page 1 of 17 Summary of Required Changes to Table RAI-01.1-1 from Entergy Letter NL-11-007 dated January 19, 2011 Change Reason for Change DELETE Area/Zone PAB-2{5}/17A from the Required OMA "Swap 31 or This zone was inadvertently included on the table 32 Charging Pump to alternate power supply" ADD cables "DK7-NV3/1" and "DK7-VN3/2" to the Cables of Concern These cables were inadvertently omitted from the column for Areas/Zones PAB-2{3}/6 and PAB-2{5}/17A for the Required table OMA "Locally close valve LCV-1 12C; open valve 288 to align Charging pump suction to the RWST" DELETE "STR PMP-33," "STR PMP-36," "STR PMP-37," and "STR PMP-These components were inadvertently included on 38" from the Component of Concern column for Area/Zone ETN-4{1}/60A the table for the Required OMA "Locally manually perform Service Water (SW) pump strainer backwash as required" For the Required OMA "Locally manually perform Service Water (SW) Clarification of layout pump strainer backwash as required," ASSOCIATE Zone 222 for Area YARD-7 with Component of Concern "STR PMP-38," and ADD "Area" before "YARD-7" For the Required OMAs "Locally close supply breaker for 32 Charging This cable was inadvertently included in the wrong Pump" and "Locally control 32 Charging Pump using scoop tube zone positioner," RELOCATE cable "K1 B-W1 B" to Area/Zone PAB-2{5}/58A

NL-11-013 Docket No. 50-286 Page 2 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 14A __________TABLE RAI-01.1-1~4 ... OlAInitlatorables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs Required

  • Xnit"ol Component of r; Cables of F3re..

.ote..lon D...e'..-"n 0MA , EieArea concern concern 2 FireProtec°tin ,Defense in Depth Fire Zonel* Cne~ Locally start Area AFW-6 33AFP AK3-PT2 Exemption granted for App R III.G.2 SER dated January 7, 1987 33 AFW Pump Zone 23 JB1-PT2/2 Area wide smoke detection from breaker JB1-X32/2 Area wide wet pipe sprinklers on Bus 6A LL7-X32 Low Fixed Combustible Loading LQ7-X32 Transient Combustible Controls X32-Y2J Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Swap 32 CCW Area ETN-4{1} 32CCP AS9-W1D Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Pump to Zone 7A January 7, 1987, and September 28, 2007 alternate Area wide smoke detection power supply Thermal detection in cable trays or align city Dry pipe/pre-action sprinklers in trays water to Low Fixed Combustible Loading Charging Transient Combustible Controls pumps Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Operate 480V Area ETN-4{1} 31AFP AI5-PT2 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Bus 3A breaker Zone 7A JB1-PT2/1 January 7, 1987, and September 28, 2007 locally to start JB1-X32/1 Area wide smoke detection 31 AFW Pump Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays I Low Fixed Combustible Loading 1

References:

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

Reference:

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

References:

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

NL-11-013 Docket No. 50-286 Page 3 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 TABLE RAI-O1.1-1~ OMA Initiator Cablesýof Concern and Mitioating Features' Minimizing the Potential to Require Use of Credited OMAs OMA. Required XInlItiato Comiponent of Cables of FiePoeeo~~esi et 3 QOMA 1' Fire Area Concern' conce~rn 2 Fr rtcinDfneIet ~WFire Zone' Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls ____________Portable Extinguishers in the zone Locally operate Area ETN-4{1} FCV-1121 JB1-X32/1 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-1121 in Zone 7A January 7, 1987, and September 28, 2007 support of use Area wide smoke detection of 31 AFW Thermal detection in cable trays Pump Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area TBL-5 3131-X32/1 Low Fixed Combustible Loading Zone 52A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls ____________Portable Extinguishers in zone Operate HCV-Area ETN-4{1} HCV-1118 JB1-TA5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, 1118 manually Zone 60A January 7, 1987, and September 28, 2007 to control 32 Area wide smoke detection AFW Pump Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls ___________Portable Extinguishers in the zone

NL-1 1-013 Docket No. 50-286 Page 4 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 TABLE. RAI-O,11. 1-1 OMA Initiator Cables of Concern and Mitigating Features;Minimizing the Potential to Require Use of Credited OMAs OMA Required Iniia.tor Component of Cables of 0M1Fire Area Concern'~, Concern 2 Fire Protection Defense in Depth3 .Fire Zone' Area ETN-4{3} JBI-TA5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Align Appendix Area ETN-4{1} 480V Bus 2A Cables of Exemption granted for ;.pp R III.G.2 - SERs dated February 2, 1984, R Diesel Zones 7A and 480V Bus SA concern are Januaiy 7, 1987, and September 28, 2007 Generator 60A not explicitly Area wide smoke detection (ARDG) to identified by Thermal detection in cable trays 480V Buses 2A the IP3 Safe-Dry pipe/pre-action sprinklers in trays and 5A, Shutdown Low Fixed Cornbustible Loading through 6.9kV Analysis Transient Combustible Controls Buses 2 and 5 Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zones Locally start Area YARD-7 SWS PMP-31 AQS-M59 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Appendix R Zone 22 SWS PMP-32 AT6-M61 Area wide smoke detection Diesel SWS PMP-33 AJ8-M62 Low Fixed Combustible Loading Generator SWS PMP-34 AQ7-M63 Transient Combustible Controls (ARDG) to SWS PMP-35 AH2-M64 Minimal Ignition Sources supply Bus SWS PMP-36 AJ7-M65 Hot Work & Ignition Source Controls 312, to Portable Extinguishers in zone support use of Hydrants in adjacent yard 38SWP

NL-11-013 Docket No. 50-286 Page 5 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 TABLE: RAI01A1-1 ~OMA Initiator Cables of Concern and Mitigating. Featu.res Minimizing the Potential to Require Use of Credited OMAs Required I Initiator ~Compnp&ent of C ;ables ofFiePoctn.DfseIDph3 OMA1I FireArea Cdoncern':' Concern2 ~Fr r~eto ees nDph Fire Zone' Swap 31 or 32 Area ETN-4{1} 32 Charging AH9-K1B Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Charging Pump Zone 7A Pump AH9-PL2 January 7, 1987, and September 28, 2007 to alternate JA4-PL-2/2 Area wide smoke detection power supply Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area PAB-AH9 P62 Exemption granted fa Ap -- GI..2 SER dated Januar,7 18 2+-+ A4 P62/2 Area wide smoke detcdi*On Zoe 191-A Low Fixcid Comb-hu-stibk Leading Tronsfient Comnbustibke Contrl's-Minimnal Ignition Soumes Hot Work & Ignition S8Urcc Controls Portable Extinguisher-s In the zone ____________I-Ise station in the-zone Area ETN-4{1} 31 Charging AQ3-KIC Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 60A Pump AQ3-PL2 January 7, 1987, and September 28, 2007 JA2-PL2/1 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls _______________________Portable Extinguishers in the zone

NL-11-013 Docket No. 50-286 Page 6 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 ~UNIT"3' STABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mlitigating Features Minimizing the Potential to Require Use of Credited OMAs. Required Initiator Component of Cables,f Fire Fi re A ea e ,.." <.... =.ire P ro te ctio n D efe n se In D e p th 3 FireonConcerne Concern. r A e ..,,,.*:.=.. :=... F:* o* * :.ire9,.* Z o ne*

,.:..£

.a.*. Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to Steam Generators Area ETN-4{1} Zone 7A FCV-406B JB1-SX1/1 JF5-KV4 JF5-LL8 K45-YM3 K47-YM3 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinauishers in the zone Area ETN-4{1} FCV-405B JB1-KV6 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 60A January 7, 1987, and September 28, 2007 FCV-405D JB1-KV8 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area ETN-4{3} Zone 73A FCV-405C FCV-405D JB1-KV8 JB1-KV7 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-11-013 Docket No. 50-286 Page 7 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNFT'3 TABLE RAI-01k OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OM QMA 7-Required Inrtiato Component of Cables ofm FireProtectlori~enseinDepth 3 OMA 1 F 'ire rea Concern' concern2 ~ Fire Zone'~_______ Locally open Area ETN-4{1} HCV-142 JB5-X1J Exemption granted for App R III.G.2 - SERs dated February 2, 1984, valve 227 to Zone 60A January 7, 1987, and September 28, 2007 establish Area wide smoke detection charging Thermal detection in cable trays makeup flow Dry pipe/pre-action sprinklers in trays to RCS Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area PAB-2{5} JB5-XlJ Area wide smoke detection Zone 59A VK4-X1J Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Locally close Area ETN-4{1} LCV-112B DD4-JB5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, valve LCV-Zone 60A LCV-112C DK7-JB5 January 7, 1987, and September 28, 2007 112C; open Area wide smoke detection valve 288 to Thermal detection in cable trays align Charging Dry pipe/pre-action sprinklers in trays pump suction Low Fixed Combustible Loading to the RWST Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-11-013 Docket No. 50-286 Page 8 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 ~UNIT 3 TABLE RAI-01.1-4 MA Initiator Cables of Concern and Mitigating Feat~ures Minimizing the Potential to Require Use of Credited OMAs OMA Required Initiator Component of Cables of

Fire Protect3on De en DeIth3 OMA' Fire Area concern'~

concern 2 FiePoeto Dfnei et Fire Zon'e1 i Exemption granted for App R III.G.2 - SER dated January 7, 1987 Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{3} DD4-VN3 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 6 DD7-VN3/1 Area wide smoke detection DD7-VN3/2 Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in adjacent zone Area PAB-2{5} DD4-VN3 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A DD7-VN3/1 Area wide smoke detection DD7-VN3/2 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-11-013 Docket No. 50-286 Page 9 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 ~UNIT, 3 .,TABLE RAI,-01.1-1 OMA Initiator. Cables of Concern and litigating Features Minimizing the Potential to Require Use of Credited OMAs.. M A....

  • Required Initiato Component of

.Cables o .3 .MA. Fire Area Concern. .:.concern. 2 F ire Protection Defense in Depth. Fire Zone' Area PAB-2{5} DD4-VN5/1 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A DD4-VN5/2 Area wide smoke detection DK7-VN5 Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} DK7-VN5 Moderate Fixed Combustible Loading Zone 20A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adjacent zone Area PAB-2{5} DK7-VN5 Low Fixed Combustible Loading Zone 27A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} Moderate Fixed Combustible Loading Zone 30A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adjacent zone

NL-11-013 Docket No. 50-286 Page 10 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT!T, OMA TABLE RAIh0l.l-l OMA Initiator Cables of Concern and litigating Features Minimizing the Potential to Require UseCof Credited OMAs OMA~ Required Initiator

  • °mponrent of*
    • Cables*of
  • Fir Po:*e*

3Defen 0MA1 Fire Area Concern1 concern2 se l**Depth 3 Fire Zone' Locally operate Area ETN-4{1} PCV-1139 JB1-PT2/3 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, PCV-1139 to Zone 60A January 7, 1987, and September 28, 2007 ensure steam Area wide smoke detection supply to 32 Thermal detection in cable trays AFW Pump Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area ETN-4{3} JB1-PT2/3 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area ETN-4{1} PCV-1310A JB1-SZ6 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, PCV-1310A, Zone 60A PCV-1310B JB1-S99 January 7, 1987, and September 28, 2007 1310B to JB1-X02 Area wide smoke detection ensure steam JB1-X02/1 Thermal detection in cable trays supply to 32 Dry pipe/pre-action sprinklers in trays AFW Pump Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone

NL-11-013 Docket No. 50-286 Page 11 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 UNIT3>.

  • .*.+/- OIMTA Initiator Cables of Concern IandMitigating T

RA" _ Initiator CFeatures Minimizing the Potential to Require Use of Credited OMAs ~Required Initiator Component of Cables of FrPotcinDefense inDph ~OMA' Fire Area Concern' Concern' rtcini et Fire Zone' Area ETN-4{3} JBI-X02 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A JB1-S99 January 7, 1987, and September 28, 2007 JB1-X02/1 Area wide smoke detection JBI-SZ6 Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally Area ETN-4{1} STR PMP-31 CW8-XV2 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, manually Zone 60A STR PMP-32 DE1-XV2 January 7, 1987, and September 28, 2007 perform SFR PMP-33 Area wide smoke detection Service Water STR PMP-34 Thermal detection in cable trays (SW) pump STR PMP-35 Dry pipe/pre-action sprinklers in trays strainer STR PMP 36 Low Fixed Combustible Loading backwash as SFR PMP 37 Transient Combustible Controls required STR PMP-38 Minimal Ignition Sources Hot Work & Ignition Source Controls ___________Portable Extinguishers in the zone

NL-11-013 Docket No. 50-286 Page 12 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 TABLE RAIj.jj OMA Initiator Cables of Concern and Iitigating Features Minimizing the Potential to Require Use of Credited OMAs ~OMA~> oRequired, .* Initiator Component of > Cables of Fr Protection Defense* -n reph 3

.. OMA.

Fire.Area Concern' Concem 2 Fire Protectio Defense in [

  • ..t" 3

Fire Zone4 Area YARD-7 Zone 22 STR PMP-31 STR PMP-32 STR PMP-33 STR PMP-34 STR PMP-35 STR PMP-36 STR PMP 38 AH2-WF6/2 AJ7-WF6 AQ7-WF6 AT6-WF6/2 MW6-P2K MW7-P2L MW8-P2M MW9-P2N MX7-P2P MX8-P2Q MY1-PYl P2K-P2M/1 P2K-WQ9 P2K-XL1 P2K-Z99 P2K-P2M/1 P2L-P2N/1 P2L-W14P2L-XL1 P2L-Z99 P2L-P2N/1 P2M-P2P/1 P2M-XL2 P2M-Z99 P2N-P2QJ1 P2N-XL2 P2N-Z99 P2P-XL3 P2P-Z99 P2Q-XL3 P2Q-Z99 Outside Transient Combustibic Contrels Minimal Ignition Sl urccs r1AF vvAr-1t M

  • RRIFIAR --%Awrr-P fzAnr-0 m i craic e*tinguisner-s in the zone H-ydrants in adjacent yar Exemption granted for App R III.G.2 - SER dated January 7, 1987 Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hydrants in adjacent yard

NL-1 1-013 Docket No. 50-286 Page 13 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 .~TABLE %RAI-O1. -1 OMA Initiator Cables of Concern and Mitigating* Features Miniimizing the Potential to Require Use of Credited OMAs

  • Requ.ied nitiato Component of Cables of Fire Protctio D

In Depth 3 OMA 1 Fire Area Concern'- " concern' P.otegon;Defensen Depth. Fire. Zone1 PYi-XV2/1 WF6-Z99 WK9-W14 WK9-XV8 WQ9-XV2 XL1-YW2 XL1-YW3 XL2-YW5 XL3-YW6 XL3-YW7 XV2-XV8 Area YARD-7 STR PMP-38 Outside Zone 222 Transient Combustible Controls Minimal Ignition Sources Hot Work & ]onition Source Controls Portable Extinguishers in the zone Hydrants In adjacent yard

NL-11-013 Docket No. 50-286 Page 14 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 .UNIT 3~ .....,...TABLE RAI-01*.,t-1~ * '*

.**=*

OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential t0o Require Use of Credited OMAs Required Initiator Component of

  • Cables of Fir Protection DefeneI et OMA' Flire Area concern' Concern 2~

e o e Fire Zone'~~___________________________ Area TBL-5 STR PMP-31 AH2-WF6/2 Smoke detection over MCC 34 and 6.9KV Swgr Zone 37A STR PMP-32 AJ7-WF6 Thermal detection in battery and charger room STR PMP-33 AQ7-WF6 Area wide wet pipe sprinkler STR PMP-34 AT6-WF6/2 Wet pipe sprinkler in battery and charger room STR PMP-35 WF6-Z99 Low Fixed Combustible Loading STR PMP-36 WK9-XV8 Transient Combustible Controls WQ9-XV2 Minimal Ignition Sources XV2-XV8 Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone Area TBL-5 Smoke detection over MCC 32 Zone 38A Area wide wet pipe sprinkler Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone Area TBL-5 Area wide wet pipe sprinkler Zone 43A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in zone

NL-1 1-013 Docket No. 50-286 Page 15 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 TABLE RAI-O1A-1 OMA InitiatorCables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs Required Initiator i Component

  • f Cables of 3

,ReMAie 2

  • Fi..Area Conern.\\,

Concern2* 2o ':'° FireZone 1 Lown .Fixedncern 2 Fire Protection D efn.se. in D epth 3 Fir 2 2e Area TBL-5 Low Fixed Combustible Loading Zone 44A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in adjacent zone Locally operate Area ETN-4{3} FCV-405C JB1-KV8 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-405C, Zone 73A FCV-405D JB1-KV7 January 7, 1987, and September 28, 2007 FCV-405D to Area wide smoke detection control AFW Thermal detection in trays flow to steam Dry pipe/pre-action sprinklers in trays generators Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area TBL-5 FCV-406A JB1-SX1/1 Low Fixed Combustible Loading FCV-406A, Zone 52A FCV-406B JF5-KV3 Transient Combustible Controls 406B to JF5-KV4 Minimal Ignition Sources control JF5-LL8 Hot Work & Ignition Source Controls AFW flow to K45-YM3 Portable Extinguishers in zone Steam Generators Locally close Area PAB-2{5} 32 Charging AH9-PL2 Low Fixed Combustible Loading supply breaker Zone 19A Pump JA4-PL2/2 Transient Combustible Controls for 32 KIB-W-B Minimal Ignition Sources Charging Hot Work & Ignition Source Controls Pump Portable Extinguishers in adjacent zone Hose station in adjacent zone

NL-11-013 Docket No. 50-286 Page 16 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 UNIT 3. TABLE RAI-01.1Pl OMA Initiator.Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs 0MA~~ SRequired ~ Initiator 'Component' of Cables of eph PMA1. Fire Area Concern' concern2 Fire Protection Defense In Depth ~FireZone1 "*l Area PAB-2{5} Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone Area PAB-2{5} KiB-WiB Area wide smoke detection Zone 58A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adjacent zone Locally control Area PAB-2{5} 32 Charging AH9-PL2 Low Fixed Combustible Loading 32 Charging Zone 19A Pump JA4-PL2/2 Transient Combustible Controls Pump using K-B-W-B Minimal Ignition Sources scoop tube Hot Work & Ignition Source Controls positioner Portable Extinguishers in adjacent zone Hose station in adjacent zone Area PAB-2{5} Exemption granted for App R III.G.2 - SER dated January 7, 1987 Zone 17A Area wide smoke detection Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Hose station in the zone

NL-11-013 Docket No. 50-286 Page 17 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 UNIT 3÷ t :

  • =

S TABLE RAI-01.1.1 OMA Initiator Cables of Concern and.Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA> .equired Initiato Component of Cables of e Prtection.Defense In Depth.. 3 OMA1~ Fire Area concer~n' Concern 2~ ________e uFirerZonee Area PAB-2{5} K1B-W1B Area wide smoke detection Zone 58A Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in adjacent zone Hose station in adjacent zone

ATTACHMENT 4 TO NL-11-013 Revised Table RAI-01.1-2 from Entergy Letter NL-11-007 dated January 19, 2011 ENTERGY NUCLEAR OPERATIONS, INC. Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-11-013 Docket No. 50-286 Page 1 of 21 Summary of Required Changes to Table RAI-01.1-2 from Entergy Letter NL-11-007 dated January 19, 2011 Change Reason for Change For Fire Area/Fire Zone ETN-4{1}/60A, DELETE "STR PMP-33", "STR These components were inadvertently included on PMP-36", and "STR PMP-38" the table For Fire Area PAB-2{5}, ADD cables "DK7-NV3/1" and "DK7-VN3/2" to the These cables were inadvertently omitted from the Associated Cables column for the OMA "Locally close valve LCV-1 12C and table open valve 288 to establish flowpath from RWST to charging pump suction"

NL-11-013 Docket No. 50-286 Page 2 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-,1.1-2... IP3 Fire Area AFW-6 Credited 0MM AndCable/Component FailuresThat May Require the Use of the Credited OMAs. ritd0 s A ssnType.of.cab.e.. Effect of cable OMA=

  • *~,I Affected AssociatedT failure(s) that may failure that c =nts"

= on:" Com ponent(s) Cables

  • cause need for leads ".need 7 :.

A ___________OMA: ~ for.OMA Locally start 33 33 AFW Pump AK3-PT2 Intra-cable fault, Remote The exemption granted for this area AFW Pump from JB1-PT2/2 ground fault, open control (see Table RAI-01.1-1) acknowledges breaker on Bus JB1-X32/2 circuit capability for the minimal fire hazards of the area, 6A LL7-X32 the 33AFP and the effectiveness of the fire LQ7-X32 circuit breaker detection system and automatic may be lost. sprinkler system, to minimize fire Pump may not damage in this area. The occurrence autostart or of a fire of sufficient severity and respond to scope to damage redundant AFW CCR controls. pump control cables and require implementation of this OMA is a low-likelihood event.

NL-11-013 Docket No. 50-286 Page 3 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Creidited OMAs And T~able'RAI-0il-2 IR3 Fire Aiea ETN-4,{lý Cable/Component Failures That May Require the Us I V Type oofcabi e iEffect of cable OM*IA 'Affected - Associated failure(s) that ma

f failure that

. Component(s) Cables cause need for l l.eads to need _______OMA ~ -~for OMA3/4 Swap 32 CCW Pump to alternate power supply or align city water to Charging pumps 32 CCW Pump AS9-W1D Intra-cable fault, ground fault, open circuit Presumes failures of cables serving redundant CCW pumps 31 and 33 due to fire damage to power cables in this a rea. This area is equipped with fire detection and automatic sprinkler systems as discussed in Table 01.1-1. The occurrence of a fire of sufficient severity and scope to damage all redundant CCW pump power cables, and thereby require implementation of this OMA, is a low likelihood event. Operate 480V 31 AFW Pump A15-PT2 Intra-cable fault, Presumes This area is equipped with fire Bus 3A breaker JB1-PT2/1 ground fault, open concurrent detection and automatic sprinkler locally to start 31 JB1-X32/1 circuit failures of systems as discussed in Table 01.1-1. AFW Pump cables serving The occurrence of a fire of sufficient redundant severity and scope to damage all AFW pumps redundant AFW pump power cables, 32 and 33 due and thereby require implementation of to fire damage this OMA, is a low likelihood event. to cables in this area. Locally operate FCV-1121 JB1-X32/1 Intra-cable fault, Miniflow This OMA is required only if a FCV-1121 in ground fault, open recirculation concurrent failure is sustained to all support of use of circuit, inter-cable flow may be AFW flow control valves FCV-406A 31 AFW Pump fault insufficient to through FCV-406D, resulting in prevent pump 31AFW pump potentially being overheating operated under minimum flow

NL-11-013 Docket No. 50-286 Page 4 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Table'RAI-bL.l-2 IP3 Fire Area ETN-4{1}, -, Credited OMAs And Cable/Component Failures That* May Require the Use of the Credited OMAs.- Tp AffectedEffect ofcable Afce Associated failure(s) that may failure that Component(s) Cables cause needror leads to needa..mP*nts °nC,.c!usI*n OMA ".forOMA'.~~~_ for conditions. The multiple concurrent failures necessary to render all AFW flow control valves failed closed is considered a low likelihood event, given the active fire protection features of the area, as described on Table RAI-01.1-1. Operate HCV-HCV-1118 JB1-TA5 Intra-cable fault, HCV-1118 loss This OMA is only required if 32 AFW 1118 manually to ground fault, open of control from pump is selected as the credited control 32 AFW circuit, inter-cable CCR controls pump. If the above listed OMAs Pump fault associated with 31 AFW pump are implemented, this OMA is unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump. Align Appendix 480V Bus 2A Cables of concern Intra-cable fault, Potential The use of the ARDG is credited for R Diesel 480V Bus 5A are not explicitly ground fault, open inability to supplying power to the 480V buses in Generator to identified by the circuit, inter-cable control offsite the event of a fire in Fire Area ETN-480V Buses 2A IP3 Safe-fault power supply 4{1}. The need for implementation of and 5A Shutdown breakers to this OMA would require loss of Analysis emergency function of 31 through 33 EDGs and a 480V concurrent loss of offsite power. switchgear and tie This area is equipped with fire breakers detection and automatic sprinkler between systems as discussed in Table RAI-

NL-11-013 Docket No. 50-286 Page 5 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 ,-TableRAI, 0.1-2 2 IP3.Fire Area ETN-4ý1} I I Credited OMAs And Cable/Component Failures That May Require *the Use of the-Credited OMAs ,,~*~..~Af~f~ctedAssc at cb Eect of* ce.......l..e.................... Affecte Associated failure(s) that may. failure that CommentsGon:ciusi Component~s) Cables causeneedfor leadsto need, OMA for OMA emergency 01.1-1. The occurrence of a fire of switchgear sufficient severity and scope to impair all redundant onsite power sources (other than the ARDG) and thereby require implementation of this OMA, is a low likelihood event. Swap 31 or 32 31 Charging AQ3-KIC Intra-cable fault, Damage to In accordance with the IP3 fire Charging Pump Pump AQ3-PL2 ground fault, open control and/or response procedure (3-ONOP-FP-1), to alternate 32 Charging JA2-PL2/1 circuit power cables 31 and 32 Charging Pumps are placed power supply Pump AH9-K1B for both in OFF/pullout upon detection of a fire AH9-PL2 charging in Fire Area ETN-4. This action can be JA4-PL2/2 pumps may expected to preclude spurious pump render both starting, pending suppression of the charging fire and alignment of the selected pumps 31 and pump to an alternate power supply. 32 inoperable Given the active fire protection features of the area (smoke detection and automatic sprinkler protection for all cable trays) and absence of combustibles other than cables in cable trays, the occurrence of a fire of sufficient severity and scope to cause the described cable damage is considered to be of low likelihood. It is therefore expected that this OMA is unlikely to be required, for any

NL-11-013 Docket No. 50-286 Page 6 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Table RAI-01.1-2: Credited .. P3 Fire Area ETN-41} .Credited OAsAndCable/Component.Failures That May Require the Use of the Credited OMAsL,. S"Typeof cable Effect of cable OMA Affected Associated failure(s) that may: failure that Cmet Conclusion Component(s) Cables cause need for leads to need Comments!.onclusion OMA for OMA Y credible fire scenario in Fire Area ETN-Locally operate FCV-405B JB1-KV6 Intra-cable fault, FCVs fail open, This OMA is only required if fire FCV-405B, FCV-FCV-405D JB1-KV8 ground fault, open fail closed, or damage occurs to cables serving ALL 405D, or FCV-FCV-406B JBI-SX1/1 circuit, inter-cable exhibit erratic AFW FCVs routed through this area. 406B to control JF5-KV4 fault operation. This area contains cables for FCV-AFW flow to JF5-LL8 405A through D and FCV-406A steam K45-YM3 through D. The multiple concurrent generators K47-YM3 failures necessary to render all AFW flow control valves inoperable is considered a low likelihood event, given the active fire protection features of the area, as described on Table RAI-01.1-1. Locally open HCV-142 JB5-XlJ Intra-cable fault, HCV-142 may If normally-open/throttled flow control valve 227 to ground fault, open spuriously valve HCV-142 is failed closed, the establish circuit, inter-cable close / fail normal makeup path to the RCS is charging fault

closed, restored by locally opening manual makeup flow to isolating the valve 227.

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

NL-11-013 Docket No. 50-286 Page 7 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 1P3 Fire Area ETN-4{t} Credited OMAS And Cable/Compone nt!Failures ThatMay Require ie,,Use of the Credited* MAs T ype of cable Effect ofcable "OMA Affected Associated failureos) thata'ay failuIre that "> " Comments. Conclusion Component(s) Cables cause need-for, <leads to need S QMAe for OMA Locally close LCV-112B DK7-JB5 Intra-cable fault, Valves may In the event of damage to one of valve LCV-LCV-112C DD4-JB5 ground fault, open spuriously these cables, it can be reasonably be 112C; open circuit, inter-cable open or close, expected that the redundant (VCT valve 288 to fault or fail open or outlet or RWST outlet) valve would align charging closed remain operable, to provide a pump suction to continued suction supply to the the RWST charging pumps. If both cables are damaged, causing maloperation of both valves, the OMA would require implementation. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of this cable - and the need to implement this OMA -- is considered a low-likelihood event. Locally operate PCV-1139 JB1-PT2/3 Intra-cable fault, PCV-1139 loss This OMA is only required if 32 AFW PCV-1139 to ground fault, open of control from pump is selected as the credited ensure steam circuit, inter-cable CCR controls pump. If the above listed OMAs supply to 32 fault associated with 31 AFW pump are AFW pump implemented, this OMA is unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump.

NL-11-013 Docket No. 50-286 Page 8 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-O1.1-2. ____________~114 CeieOMs4I3ire:Area'ETN-4{1}1 And Cable/Component Failures That May Require the Use of the-Credited OMAs Type of cable Effet o"fcable OMA* Affected Associated failure(s)that may failure that. C"" Conc C6monent(s), Cables Icause need for leds to need, A ~OMA for OMA Locally operate PCV-1310A JB1-S99 Intra-cable fault, Valves This OMA is only required if 32 AFW PCV-1310A, PCV-1310B 3B1-X02 ground fault, open spuriously pump is selected as the credited 1310B to JB1-SZ6 circuit close or fail pump. If the above listed OMAs ensure steam JB1-X02/1 closed associated with 31 AFW pump are supply to 32 implemented, this OMA is AFW pump unnecessary. Conversely, the use of this OMA would obviate the need for the above listed OMAs for 31 AFW pump. Locally STR PMP-31 CW8-XV2 Intra-cable fault, Loss of normal This OMA, if required, is limited to the manually STR PMP-32 DE1-XV2 ground fault, open power supply manual operation of only the single perform SW SFR-PMP3-3 circuit to all SW SW strainer associated with the pump strainer STR PMP-34 strainer selected/operating SW pump. backwash as STR PMP-35 control panels required STR PMP 36 The listed cables each provide power STR-PMP-38 to three SW pump strainer control panels, and provide redundant feeds, via a throwover switch, for the backup SW control panel. Consequently, both cables must fail as the result of fire damage to render all SW pump strainers inoperable, and requiring the use of the OMA. In light of the above described minimal hazards of the area and the active fire protection features, fire-

NL-11-013 Docket No. 50-286 Page 9 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 .Table RA IO 1..1-.

  • *=
  • ,:i@

P3 Fire Area ýETN-4ý*} I* I A..d.... _________Credited

.OMAs.n Cable/Component Failures-That May RequIre.-the-Use.,of the Credited OMAs
y.

ype of cable ..Effect of cable.

M

...Affected Associated failure(s) that may failure that. Component(s)_ Cabl*es cause need for leads to need Comments /Concluson ~ MA for OMA, induced failure of both cables - and the need to implement this OMA -- is considered a low-likelihood event.

NL-11-013 Docket No. 50-286 Page 10 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Credited OMAs And Table.RAI-01.1i2 .P3 Fire.Area ETN-4ý{3 Cable/Component Failures That May Require the Use of thi OMA .Affected Comnponent(s) Associated Cables Type of cable failure(s) thtat imay cause need for '.. OMA. Effect of cable failur~e that: lead.s to need.d .fo'rOA Operate HCV-1118 manually to control 32 AFW pump HCV-1118 JB1-TA5 Intra-cable fault, ground fault, open circuit, inter-cable fault HCV-1118 loss of control from CCR controls This OMA is only required if 32 AFW pump is selected as the credited pump. The IP3 Safe-Shutdown Analysis reports no cables associated with the 31 AFW pump, its flow control valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event. Locally operate PCV-1139 JB1-PT2/3 Intra-cable fault, PCV-1139 This OMA is only required if 32 AFW PCV-1139 to ground fault, open spuriously pump is selected as the credited ensure steam circuit, inter-cable closes or fails pump. The 1P3 Safe-Shutdown supply to 32 fault closed Analysis reports no cables associated

NL-11-013 Docket No. 50-286 Page 11 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 IP3 Fire ArdaEýTN-4{31) Credited OMAs And Cable/CornponentiEallures That May Require the Use of the Credited OMAs I ~AffctdType of c~abl~e 7 Effect of cble.

  • M*
  • ~~~~~~~~~~~failu're(s) that~ray faiiur~e~haft:.
      • ==:q'L MA Affected Associated aiurs need for Con that Comments Conclusion Compnet(s) cause need for leads to need Comments]

'for OMA~~ AFW pump with the 31 AFW pump, its flow control valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event. Locally operate PCV-1310A 31B1-S99 Intra-cable fault, PCV-1310A This OMA is only required if 32 AFW PCV-1310A, PCV-1310B 3B1-X02 ground fault, open and/or PCV-pump is selected as the credited PCV-1310B to JB1-SZ6 circuit 1310B (series pump. The IP3 Safe-Shutdown ensure steam JB1-X02/1 valves) Analysis reports no cables associated supply to 32 spuriously with the 31 AFW pump, its flow control AFW pump close or fail valves (FCV-406A, FCV-406B), or closed power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire

NL-1 1-013 Docket No. 50-286 Page 12 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 ... =

  • Table RAI-01.1-2...
    =.

thIrd3e Fir Are _T_4 Credited OMAs And Cable/ComponentFailures ohaf Ma RequiretheUse fthe`Credited OAs S, ,Type of cable' Effect of cablef b Affected Associated.. ifaure(s) that may 4failure that, OMA

" t, ece

° comments iConclusion :,

  • Component(s),

Cables 'cause~ need ford leads to ~need, OMA. rfor OMA area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire damage. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event. Locally operate FCV-405C .B1-KV7 Intra-cable fault, FCV-405C, This OMA is only required if 32 AFW FCV-405C, FCV-FCV-405D .JB1-KV8 ground fault, open FCV--405D pump is selected as the credited 405D to control circuit, inter-cable spuriously pump. The IP3 Safe-Shutdown AFW flow to fault close or open Analysis reports no cables associated steam with the 31 AFW pump, its flow control generators valves (FCV-406A, FCV-406B), or power source (BUS3A) routed through this fire area. However, the protected instrumentation credited in this fire area for monitoring SG level is that for 33 and 34 SG, rendering 31 AFW pump an unsuitable choice if all level instrumentation for 31 and 32 SG has been rendered inoperable by fire

NL-11-013 Docket No. 50-286 Page 13 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 ~~ " Table" RAI- .1 2 .1 r P3 FirIe Area ETN-4{3} Credited OMMAsAnd Cable/Component Failures That Ma Require the Use of-the Credited OMAs Type of cable Effect of cble OMA Affected Associated .failure(. ) that may failure thatC e ol Compoent(s) Cables cause, need for. leads to need

Comns/conclusion

.OMA forOQMA,, 9 damage. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

NL-11-013 Docket No. 50-286 Page 14 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Table RAI-01.1-2 .. P3. FireArea PAP-2{ 3}

  • "Credited OMAsAnd Cable/Component Failures:That May Require the Use of the Credited OMAs AffetedType of~cable Effect`of cable OMA :A ffected
Associated= ::

failure(s) that may failure that'o Component(s) Cables.. cause need fo** leads to :n'eed' OMA. for OMAK Locally close LCV-112C DK7-VN3/1 Intra-cable fault, Valves may Selective cable failure modes may valve LCV-112C LCV-112B DK7-VN3/2 ground fault, open spuriously result in a sustained functional and open valve DD4-VN3 circuit, inter-cable close or open charging pump suction path, or may 288 to align fault result in isolation of all charging pump charging pump suction. Control room operator action suction path to taken in accordance with fire response Refueling Water procedure 3-ONOP-FP-1 will secure 31 Storage Tank and 32 Charging Pumps in pullout, (RWST) upon detection of a fire in this area, precluding spurious pump starts, and ensuring pumps remain free of fire damage until a reliable suction path can be aligned. In light of the above described minimal hazards of the area and the active fire protection features, fire-induced failure of the listed cable - and the resultant need to implement this OMA -- is considered a low-likelihood event.

NL-11-013 Docket No. 50-286 Page 15 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 .. Table RAI-01.1-2 1P3 Fire Area PAB!-2{5} Crdted OMAs And Cable/Component Failures That May Require the Use of the Credited 0MMs .Type of cable~ Effect ofcable OMA. ~Affected Associated failure(s) that may failure that Cmnns ocuin Component(s) Cables cause need for> leads to-need OMA f'or:OMA Locally close 32 Charging AH9-PL2 Intra-cable fault, 32 Charging This OMA is required if a fire in this supply breaker Pump JA4-PL2/2 ground fault, open Pump is area causes damage to cables serving for 32 charging KiB-W1B circuit rendered both 31 and 32 Charging Pumps, pump inoperable which are both equipped with alternate from remote power source capabilities via transfer electrical switches. controls The defense in depth fire protection features of this area, in concert with S_____________ the Locally control 32 Charging AH9-PL2 Intra-cable fault, 32 Charging This OMA is required only if a fire in 32 charging Pump JA4-PL2/2 ground fault, open Pump electro-this area causes damage to cables pump using K1B-WiB circuit, inter-cable pneumatic serving both 31 and 32 Charging scoop tube fault speed Pumps, which are both equipped with positioner controller fails alternate power source capabilities via to maintain transfer switches. required pump speed Open valve 227 HCV-142 JB5-X1J Intra-cable fault, HCV-142 may If normally-open/throttled flow control to establish VK4-X1J ground fault, open spuriously valve HCV-142 is failed closed, the charging circuit, inter-cable close / fail normal makeup path to the RCS is flowpath to RCS fault

closed, restored by locally opening manual around isolating the valve 227.

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

NL-11-013 Docket No. 50-286 Page 16 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 As~ciaed IP3 Fire Area PAB-2{5} Crdtd MsAd al/omo tFailure~s yThatm Ma Req fr the Us-f h reied .~ A"fectType of W f .cable Effc ofcable.... Affctdssciables falres tha may -filur~e that OMA=; -;: ** *=**Afce*n;'=.... .s**,f .*, -*;Comments, / Conclusion*,=. MA.Components) Cb cause.need for. leads to need Conclusion ________ 1/2 0MA <~for OMA to the RCS charging makeup path to the RCS, it can be expected that limited makeup to the RCS would continue, via the RCP seal injection flowpath, which is not impacted by the closure of HCV-142. Locally close LCV-112C DK7-VN5 Intra-cable fault, Valves may Selective cable failure modes may LCV-112C and LCV-112B DD4-VN5/1 ground fault, open spuriously result in a sustained functional open valve 288 DD4-VN5/2 circuit, inter-cable close or open charging pump suction path, or may to establish DK7-VN3/1 fault result in isolation of all charging pump flowpath from DK7-VN3/2 suction. Control room operator action RWST to taken in accordance with fire response charging pump procedure 3-ONOP-FP-1 will secure 31 suction and 32 Charging Pumps in pullout, upon detection of a fire in this area, precluding spurious pump starts, and ensuring pumps remain free of fire damage until a reliable suction path can be aligned.

NL-11-013 Docket No. 50-286 Page 17 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 .Table RAI-01.1-2 1~~P3 Fire Area TBL-5 Credited OMAs And Cable/Component Failures That May Require theUse of the Credited OMAs SType of cabl'6e Effect..ocal A Affected Associated failure(s) that may. failure that, commnts f ision. Component(s) Cables cause need for leads to. need ___________OMA" for OMA< Locally operate FCV-1121 3B1-X32/1 Intra-cable fault, Valve This OMA is required only if FCV-1121 (bypass valve ground fault, open spuriously fails closed and all AFW flow control for) FCV-1121 circuit, inter-cable closes or fails valves FCV-406A through 406D fail AFW pump fault closed closed, as the result of fire damage to recirculation cables in this fire area. This valve during combination of failures would result in pump startup an inadequate recirculation flowpath to preclude AFW pump overheating, thereby requiring the OMA to be performed. The multiple concurrent failures necessary, and the minimal hazards and ignition sources of the zones traversed by these cables renders the need to implement this OMA a low-likelihood event. Locally operate FCV-406A JB1-SX1/1 Intra-cable fault, Valves This OMA is required only if all steam FCV-406A, FCV-406B JF5-KV3 ground fault, open spuriously generator level channels associated 406B to control JF5-KV4 circuit, inter-cable open or fail with SG 33 and 34 are rendered AFW flow to JF5-LL8 fault closed inoperable by fire damage, and/or Steam K45-YM3 both 33 AFW pump, its flow control Generators valves (FCV-406C and D), and 32 AFW pump, its steam supply, control valve (PCV-1310A, PCV-1310B, PCV-1139, HCV-1118) and flow control valves (FCV-405A through D) are also rendered inoperable by fire damage in

NL-11-013 Docket No. 50-286 Page 18 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19,2011 Table RAI-01~.1-2 .iP3 Fire Area TBL-5. _,CreditedOMAs And Cable/Component%Failures.That$Ma -Require the,Use of the Credited OMAs AffetedAssj .Type of cable Effect of cble AfetdAssociated fail.ures) that may "failure that m..t. ,..us,.. O-MA*"* C" .... *'::omments,, Conclusion=*,.< Component(s) Cables causeneed for leads to. need O.MA for OMA~ this area. Given the minimal fixed combustibles and ignition sources in the impact fire zones of Fire Area TBL-5, as described on Table RAI-01.1-1, a fire of sufficient severity and scope to cause the necessary extent of damage in this zone is considered a low-likelihood event. Locally /manually backwash SW pump strainer as required if power to strainer associated with selected SW pump is lost (use one of STR PMP-31 through STR PMP 36). STR PMP-31 STR PMP-32 STR PMP-33 STR PMP-34 STR PMP-35 STR PMP-36 AH2-WF6/2 AJ 7-WF6 AQ7-WF6 AT6-WF6/2 WF6-Z99 WK9-XV8 WQ9-XV2 XV2-XV8 Intra-cable fault, ground fault, open circuit Loss of normal power supply to all SW strainer control panels This OMA, if required, is limited to the manual operation of only the single SW strainer associated with the selected/operating SW pump. The multiple fire-induced cable failures necessary to disable all SW strainers, in consideration of the characteristics of the fire zones through which the cables are routed (reference Table RAI-01.1-1) renders the need to implement this OMA a low-likelihood event.

NL-11-013 Docket No. 50-286 Page 19 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-01.1-2~ Credited OMAs And Cable/Component Failures T~hat May Require the Use of the Credited 0MMs STypeo~f cable E ffect of cable Affected Associated ~failure(s)ta a alr ht ~OMA Comet thaonclfilueshiton Componen~t(s) Cables cause need for leads to ne~ed.Cmet Cnlso __________OMA: for OMA Locally start SWS PMP-31 AQ8-M59 Intra-cable fault, Pump may be The use of the 38 Service Water Pump ARDG to supply SWS PMP-32 AT6-M61 ground fault, open rendered is credited in the unlikely event that a MCC312A in SWS PMP-33 AJ8-M62 circuit inoperable fire in this area causes sufficient support of the SWS PMP-34 AQ7-M63 damage to cables and/or components use of SW SWS PMP-35 AH2-M64 to render all normal service water Pump 38 SWS PMP-36 AJ7-M65 pumps (31 through 36) inoperable. As a concurrent loss of offsite power is postulated, the ARDG (which has self-contained cooling) is credited to power 38 SWP, as this pump by design does not provide sufficient capacity for cooling of one of the safety-related diesel generators, 31, 32, or 33EDG. As this OMA is necessary only in the event of a large fire event that could disable all normal (31 through 36 Service Water Pumps, concurrent with a loss of offsite power, the need to implement this OMA is considered to be a low-likelihood event. Locally/manuall STR PMP-31 AH2-WF6/2 Intra-cable fault, Loss of normal This OMA, if required, is limited to the y backwash SW STR PMP-32 AJ7-WF6 ground fault, open power supply manual operation of only the single pump strainer if STR PMP-33 AQ7-WF6 circuit to all SW SW strainer associated with the power to STR PMP-34 AT6-WF6/2 _________strainer selected/operating SW pump.

NL-11-013 Docket No. 50-286 Page 20 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table kRi-01.1-2. IP3 Fire.AreaYARD.7. CeAnd.Cable/Component FailuresThat-May Require the Uise of the Credited OMAs T~ype of cable. Effect of cable~

OMA,

~ Affected A~ssocated failu~re(s) that may failure that Cmet/Cnlso Component(s) Cables cause:needfor leads to need e 7OMA for OMA strainer STR PMP-35 MW6-P2K control panels The multiple fire-induced cable failures associated with STR PMP-36 MW7-P2L necessary to disable all SW strainers, selected SW STR PMP-38 MW8-P2M in consideration of the characteristics pump is lost MW9-P2N of the fire zones through which the MX7-P2P cables are routed (reference Table MX8-P2Q RAI-01.1-1) renders the need to MYl-PYl implement this OMA a low-likelihood P2K-P2M/1 event. P2K-WQ9 P2K-XL1 P2K-Z99 P2K-P2M/1 P2L-P2N/1 P2L-W14 P2L-XL1 P2L-Z99 P2L-P2N/1 P2M-P2P/1 P2M-XL2 P2M-Z99 P2N-P20J1 P2N-XL2 P2N-Z99 P2P-XL3 P2P-Z99 P2Q-XL3 P2Q-Z99

NL-11-013 Docket No. 50-286 Page 21 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011

Table RAI-014. <

S> IP3 Fire Area YARD-7 4 Credited OAS And Cable/Component Failures That May Require the.Use of the Credited OMAs Type o~fcable ~Effed~of cable. AAfected Associated failure(s) that may failure that Commen Component(s) C s caue need foi. leads" leads. toneed

t.

C _OMA Jfor MA' PYI-XV2/1 WF6-Z99 WK9-W14 WK9-XV8 WQ9-XV2 XL1-YW2 XL1-YW3 XL2-YW5 XL3-YW6 XL3-YW7 XV2-XV8}}

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