NL-06-060, Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

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Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
ML061720091
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/08/2006
From: Dacimo F
Entergy Nuclear Indian Point 2, Entergy Nuclear Indian Point 3
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
+kBR1SISP20060621, GL-06-003, NL-06-060
Download: ML061720091 (12)
v • d • e


Text

t J Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 I lEntf Tel (914) 734-6700 Fred Dacimo Site Vice President Administration June 8, 2006 Indian Point Unit Nos. 2 & 3 Docket Nos. 50-247, 50-286 NL-06-060 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

Subject:

Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

References:

1. NRC letter dated April 10, 2006, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

Dear Sir or Madam:

Per Reference 1, the NRC issued Generic Letter (GL) 2006-03 requesting facilities to confirm compliance with existing applicable regulatory requirements regarding potentially nonconforming Hemyc and MT fire barrier configurations and, if appropriate, to take additional actions. Specifically, although Hemyc and MT fire barriers may be relied on to protect electrical and instrumentation cables and equipment that provide safe shutdown capability during a fire, the 2005 NRC Hemyc testing program has revealed that both materials failed to provide the protective function intended for compliance with existing regulations. The request for information is being made under the requt!rements of 10 CFR 50.54(f).

The Indian Point Unit 2 and Unit 3 responses to the requested information in GL 2006-03 are contained in Attachments I and 2, respectively, to this submittal. Attachment 3 contains the commitments made in this letter. If you have any questions or require additional information, please contact Patric W. Conroy, Manager, Licensing at 914-734-6668.

cc: see next page

NL-06-060 Docket Nos. 50-247, 50-286 Page 2 of 2 Ideýcl),eyunder penalty of perjury that the foregoing is true and correct. Executed on 2006.

"ncerely, Fred R. Dacimo Site Vice President Indian Point Energy Center : Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations : Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations : Commitments made in Response to NRC Generic Letter 2006-03 for Indian Point 2 and 3 cc:

Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. John Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspector's Office, Indian Point Energy Center Mr. Paul Eddy, New York State Public Service Commission Mr. Peter R. Smith, President, NYSERDA

ATTACHMENT 1 TO NL-06-060 Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 2 DOCKET 50-247

Docket No. 50-247 NL-06-060 Attachment 1 Page 1 of 3 Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Within 60 days of the date of this GL, provide the following:

a. A statement on whether Hemyc or MT fire barriermaterialis used at their NPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis,including whether Hemyc or MT is creditedin other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).

Indian Point 2 Response MT fire barrier material is not in use at this time.

Hemyc fire barrier material is used in the construction of several Electrical Raceway Fire Barrier Systems (ERFBS) relied upon for separation and/or safe shutdown purposes for compliance with the requirements of 10 CFR 50 Appendix R (see Table in response to 2.a). Exemptions from the requirements of Appendix R have been granted in each case and each requires a fire resistance rating of 30 minutes.

b. A description of the controls that were used to ensure that other fire barrier types relied on for separationof redundanttrains located in a single fire areaare capable of providing the necessarylevel of protection. Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

Indian Point 2 Response The only other fire barrier material used in the construction of ERFBS relied on for separation of redundant trains located in a single fire area is 3M Interam E54C.

Aspects of the design control process were used to ensure that the 3M Interam E54C ERFBS is capable of providing the necessary level of protection. An engineering evaluation was performed at the time the 3M Interam E54C material was considered for use and subsequently reevaluated following the issuance of NRC Information Notice 95-52, Supplement 1 (Fire Endurance Test Results for Electrical Raceway Fire Barrier Systems Constructed from 3M Company Interam Fire Barrier Materials).

Docket No. 50-247 NL-06-060 Attachment 1 Page 2 of 3

2. Within 60 days of the date of this GL, for those addresses that have installed Hemyc or MT fire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areas installed, systems protected),

Indian Point 2 Response Area System Protected Approximate Installed Linear Feet' Auxiliary 23 Auxiliary Feedwater Pump 2 Feedwater power cables Pump Room Piping Isolation valves associated with 50 Penetration alternate safe-shutdown 21 and Area 22 Steam Generator Wide Range Level and Pressurizer Pressure (one channel) and Level (one channel) pneumatic instrumentation. Note that the Hemyc ERFBS in this case provides protection for pneumatic instrument lines, not electrical cables.

CCW Heat 23 CCW Pump power cables 50 Exchanger and Pump areas in PAB The total linear feet identified is the amount of wrap for the raceway protected and does not include any interferences or supports that had to be wrapped.

b. Whether the Hemyc and/orMT installedin theirplants is conforming with their licensing basis in light of recent findings, and if these recent findings do not apply, why not, Indian Point 2 Response Based on NRC testing, conformance with the licensing basis has been considered indeterminate and the Hemyc installations have been declared inoperable.

Docket No. 50-247 NL-06-060 Attachment 1 Page 3 of 3

c. The compensatorymeasures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associatedwith Hemyc andMT installations,including evaluations to supportthe addressees'conclusions, and Indian Point 2 Response The following compensatory measures have been established in the areas containing Hemyc installations:

Instituted fire watch tours conducted at a frequency of once per hour; Ensured detection systems are operable.

d. A descriptionof, andimplementation schedules for, correctiveactions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensingbasis.

Indian Point 2 Response Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the existing Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports. The modification to accomplish this is scheduled to be installed prior to December 1, 2007. The modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP2 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation.

ATTACHMENT 2 TO NL-06-060 Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET 50-286

Docket No. 50-286 NL-06-060 Attachment 2 Page 1 of 3 Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Within 60 days of the date of this GL, provide the following:

a. A statement on whether Hemyc or MT fire barriermaterialis used at their NPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis, including whetherHemyc or MT is creditedin otheranalyses (e.g., exemptions, license amendments, GL 86-10 analyses).

Indian Point 3 Response MT fire barrier material is not in use at this time.

Hemyc fire barrier material is used in the construction of several Electrical Raceway Fire Barrier Systems (ERFBS) relied upon in several locations for separation and/or safe shutdown purposes for compliance with the requirements of 10 CFR 50 Appendix R (see Table in response to 2.a). Exemptions from the requirements of Appendix R have been granted for each location, relative to the separation requirements of 10 CFR 50, Appendix R, Section III.G.

In addition to Hemyc fire barrier material used in the construction of ERFBS, Hemyc fire barrier material is also used as a radiant energy shield for separation of redundant safe-shutdown trains within the containment building.

b. A description of the controls that were used to ensure that other fire barrier types relied on for separationof redundant trainslocated in a single fire area are capable of providing the necessarylevel of protection. Addressees may reference their responses to GL 92-08 to the extent that the responses addressthis specific issue.

Indian Point 3 Response No other fire barrier material is used in the construction of ERFBS relied on for separation of redundant trains located in a single fire area.

Docket No. 50-286 NL-06-060 Attachment 2 Page 2 of 3

2. Within 60 days of the date of this GL, for those addresses that have installed Hemyc or MT fire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areasinstalled, systems protected),

Indian Point 3 Response Area Installed System Protected Approximate Linear Feet1 Upper Electrical T-Hot/T-Cold (Loop 4), Steam 15 Penetration Area Generator Narrow Range Level (31, 32, 33, 34), Pressurizer Level (one channel), 34 Steam Generator Wide Range Level, RCS Pressure (Loop 4) instrumentation Upper Electrical Source Range instrumentation (one 240 Penetration Area channel) and Upper Electrical Tunnel Lower Electrical T-Hot/T-Cold (Loop 4), Steam 30 Tunnel Generator Narrow Range Level (31, 32, 33, 34), Pressurizer Level (one channel), 34 Steam Generator Wide Range Level, RCS Pressure (Loop 4) instrumentation, 31 & 34 Atmospheric Dump valves control cables CCW Pump Area 33 CCW Pump power cables 10 1 The total linear feet identified is the amount of wrap for the raceway protected and does not include any interferences or supports that had to be wrapped.

b. Whether the Hemyc and/orMT installedin theirplants is conforming with theirlicensing basis in light of recent findings, and if these recent findings do not apply, why not, Indian Point 3 Response Based on NRC testing, conformance with the licensing basis has been considered indeterminate and the Hemyc installations have been declared inoperable.

Docket No. 50-286 NL-06-060 Attachment 2 Page 3 of 3

c. The compensatory.measures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associatedwith Hemyc and MT installations,including evaluations to support the addressees'conclusions, and Indian Point 3 Response The following compensatory measures have been established in the areas containing Hemyc installations:

Instituted fire watch tours conducted at a frequency of once per hour; Ensured detection systems are operable.

d. A description of, and implementation schedules for, corrective actions, including a descriptionof any licensing actions or exemption requests needed to support changes to the plant licensing basis.

Indian Point 3 Response A review of the installed Hemyc ERFBS has been performed relative to the necessary protection required given the fire hazards of the areas. A request for revision of two existing exemptions will be submitted to change the fire resistive rating of the Hemyc ERFBS in the table in the response to item 2.a from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 30 minutes. This submittal should be made in July 2006.

Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports and certain metallic penetrating items.

The modification to accomplish this is not currently scheduled as it is contingent upon NRC approval of the revision to the exemption requests. It is anticipated that the modification would not be installed prior to December 1, 2007. To support the installation, the modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP3 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation.

ATTACHMENT 3 TO NL-06-060 Commitments made in Response to NRC Generic Letter 2006-03 for Indian Point 2 and 3 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 & 3 DOCKETS 50-247 AND 50-286

Docket Nos 50-247, 50-286 NL-06-060 Attachment 3 Page 1 of I This table identifies actions discussed in this letter for which Entergy commits to perform.

Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

Commitment Type Scheduled Completion Date Complete modification (including One-Time October 31, 2007 supporting engineering evaluation) Action to install additional protection of the electrical raceway supports associated with the existing Hemyc ERFBS at Indian Point 2 Maintain compensatory measures One-Time October 31, 2007 in place at Indian Point 2 until Action completion of the installation of additional protection of the electrical raceway supports.

Complete modification (including One-Time Contingent upon supporting engineering evaluation) Action NRC approval of to install additional protection of revision to existing the electrical raceway supports exemptions and certain metallic penetrating items associated with the existing Hemyc ERFBS located outside containment at Indian Point 3 Maintain compensatory measures One-Time Contingent upon in place at Indian Point 3 until Action NRC approval of completion of the installation of revision to existing additional protection of the exemptions electrical raceway supports and certain metallic penetrating items

Text

t J Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 I lEntf Tel (914) 734-6700 Fred Dacimo Site Vice President Administration June 8, 2006 Indian Point Unit Nos. 2 & 3 Docket Nos. 50-247, 50-286 NL-06-060 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

Subject:

Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

References:

1. NRC letter dated April 10, 2006, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

Dear Sir or Madam:

Per Reference 1, the NRC issued Generic Letter (GL) 2006-03 requesting facilities to confirm compliance with existing applicable regulatory requirements regarding potentially nonconforming Hemyc and MT fire barrier configurations and, if appropriate, to take additional actions. Specifically, although Hemyc and MT fire barriers may be relied on to protect electrical and instrumentation cables and equipment that provide safe shutdown capability during a fire, the 2005 NRC Hemyc testing program has revealed that both materials failed to provide the protective function intended for compliance with existing regulations. The request for information is being made under the requt!rements of 10 CFR 50.54(f).

The Indian Point Unit 2 and Unit 3 responses to the requested information in GL 2006-03 are contained in Attachments I and 2, respectively, to this submittal. Attachment 3 contains the commitments made in this letter. If you have any questions or require additional information, please contact Patric W. Conroy, Manager, Licensing at 914-734-6668.

cc: see next page

NL-06-060 Docket Nos. 50-247, 50-286 Page 2 of 2 Ideýcl),eyunder penalty of perjury that the foregoing is true and correct. Executed on 2006.

"ncerely, Fred R. Dacimo Site Vice President Indian Point Energy Center : Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations : Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations : Commitments made in Response to NRC Generic Letter 2006-03 for Indian Point 2 and 3 cc:

Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. John Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspector's Office, Indian Point Energy Center Mr. Paul Eddy, New York State Public Service Commission Mr. Peter R. Smith, President, NYSERDA

ATTACHMENT 1 TO NL-06-060 Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 2 DOCKET 50-247

Docket No. 50-247 NL-06-060 Attachment 1 Page 1 of 3 Indian Point 2 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Within 60 days of the date of this GL, provide the following:

a. A statement on whether Hemyc or MT fire barriermaterialis used at their NPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis,including whether Hemyc or MT is creditedin other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).

Indian Point 2 Response MT fire barrier material is not in use at this time.

Hemyc fire barrier material is used in the construction of several Electrical Raceway Fire Barrier Systems (ERFBS) relied upon for separation and/or safe shutdown purposes for compliance with the requirements of 10 CFR 50 Appendix R (see Table in response to 2.a). Exemptions from the requirements of Appendix R have been granted in each case and each requires a fire resistance rating of 30 minutes.

b. A description of the controls that were used to ensure that other fire barrier types relied on for separationof redundanttrains located in a single fire areaare capable of providing the necessarylevel of protection. Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

Indian Point 2 Response The only other fire barrier material used in the construction of ERFBS relied on for separation of redundant trains located in a single fire area is 3M Interam E54C.

Aspects of the design control process were used to ensure that the 3M Interam E54C ERFBS is capable of providing the necessary level of protection. An engineering evaluation was performed at the time the 3M Interam E54C material was considered for use and subsequently reevaluated following the issuance of NRC Information Notice 95-52, Supplement 1 (Fire Endurance Test Results for Electrical Raceway Fire Barrier Systems Constructed from 3M Company Interam Fire Barrier Materials).

Docket No. 50-247 NL-06-060 Attachment 1 Page 2 of 3

2. Within 60 days of the date of this GL, for those addresses that have installed Hemyc or MT fire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areas installed, systems protected),

Indian Point 2 Response Area System Protected Approximate Installed Linear Feet' Auxiliary 23 Auxiliary Feedwater Pump 2 Feedwater power cables Pump Room Piping Isolation valves associated with 50 Penetration alternate safe-shutdown 21 and Area 22 Steam Generator Wide Range Level and Pressurizer Pressure (one channel) and Level (one channel) pneumatic instrumentation. Note that the Hemyc ERFBS in this case provides protection for pneumatic instrument lines, not electrical cables.

CCW Heat 23 CCW Pump power cables 50 Exchanger and Pump areas in PAB The total linear feet identified is the amount of wrap for the raceway protected and does not include any interferences or supports that had to be wrapped.

b. Whether the Hemyc and/orMT installedin theirplants is conforming with their licensing basis in light of recent findings, and if these recent findings do not apply, why not, Indian Point 2 Response Based on NRC testing, conformance with the licensing basis has been considered indeterminate and the Hemyc installations have been declared inoperable.

Docket No. 50-247 NL-06-060 Attachment 1 Page 3 of 3

c. The compensatorymeasures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associatedwith Hemyc andMT installations,including evaluations to supportthe addressees'conclusions, and Indian Point 2 Response The following compensatory measures have been established in the areas containing Hemyc installations:

Instituted fire watch tours conducted at a frequency of once per hour; Ensured detection systems are operable.

d. A descriptionof, andimplementation schedules for, correctiveactions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensingbasis.

Indian Point 2 Response Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the existing Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports. The modification to accomplish this is scheduled to be installed prior to December 1, 2007. The modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP2 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation.

ATTACHMENT 2 TO NL-06-060 Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET 50-286

Docket No. 50-286 NL-06-060 Attachment 2 Page 1 of 3 Indian Point 3 Response to NRC Generic Letter 2006-03:

Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Within 60 days of the date of this GL, provide the following:

a. A statement on whether Hemyc or MT fire barriermaterialis used at their NPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis, including whetherHemyc or MT is creditedin otheranalyses (e.g., exemptions, license amendments, GL 86-10 analyses).

Indian Point 3 Response MT fire barrier material is not in use at this time.

Hemyc fire barrier material is used in the construction of several Electrical Raceway Fire Barrier Systems (ERFBS) relied upon in several locations for separation and/or safe shutdown purposes for compliance with the requirements of 10 CFR 50 Appendix R (see Table in response to 2.a). Exemptions from the requirements of Appendix R have been granted for each location, relative to the separation requirements of 10 CFR 50, Appendix R, Section III.G.

In addition to Hemyc fire barrier material used in the construction of ERFBS, Hemyc fire barrier material is also used as a radiant energy shield for separation of redundant safe-shutdown trains within the containment building.

b. A description of the controls that were used to ensure that other fire barrier types relied on for separationof redundant trainslocated in a single fire area are capable of providing the necessarylevel of protection. Addressees may reference their responses to GL 92-08 to the extent that the responses addressthis specific issue.

Indian Point 3 Response No other fire barrier material is used in the construction of ERFBS relied on for separation of redundant trains located in a single fire area.

Docket No. 50-286 NL-06-060 Attachment 2 Page 2 of 3

2. Within 60 days of the date of this GL, for those addresses that have installed Hemyc or MT fire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areasinstalled, systems protected),

Indian Point 3 Response Area Installed System Protected Approximate Linear Feet1 Upper Electrical T-Hot/T-Cold (Loop 4), Steam 15 Penetration Area Generator Narrow Range Level (31, 32, 33, 34), Pressurizer Level (one channel), 34 Steam Generator Wide Range Level, RCS Pressure (Loop 4) instrumentation Upper Electrical Source Range instrumentation (one 240 Penetration Area channel) and Upper Electrical Tunnel Lower Electrical T-Hot/T-Cold (Loop 4), Steam 30 Tunnel Generator Narrow Range Level (31, 32, 33, 34), Pressurizer Level (one channel), 34 Steam Generator Wide Range Level, RCS Pressure (Loop 4) instrumentation, 31 & 34 Atmospheric Dump valves control cables CCW Pump Area 33 CCW Pump power cables 10 1 The total linear feet identified is the amount of wrap for the raceway protected and does not include any interferences or supports that had to be wrapped.

b. Whether the Hemyc and/orMT installedin theirplants is conforming with theirlicensing basis in light of recent findings, and if these recent findings do not apply, why not, Indian Point 3 Response Based on NRC testing, conformance with the licensing basis has been considered indeterminate and the Hemyc installations have been declared inoperable.

Docket No. 50-286 NL-06-060 Attachment 2 Page 3 of 3

c. The compensatory.measures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associatedwith Hemyc and MT installations,including evaluations to support the addressees'conclusions, and Indian Point 3 Response The following compensatory measures have been established in the areas containing Hemyc installations:

Instituted fire watch tours conducted at a frequency of once per hour; Ensured detection systems are operable.

d. A description of, and implementation schedules for, corrective actions, including a descriptionof any licensing actions or exemption requests needed to support changes to the plant licensing basis.

Indian Point 3 Response A review of the installed Hemyc ERFBS has been performed relative to the necessary protection required given the fire hazards of the areas. A request for revision of two existing exemptions will be submitted to change the fire resistive rating of the Hemyc ERFBS in the table in the response to item 2.a from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 30 minutes. This submittal should be made in July 2006.

Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports and certain metallic penetrating items.

The modification to accomplish this is not currently scheduled as it is contingent upon NRC approval of the revision to the exemption requests. It is anticipated that the modification would not be installed prior to December 1, 2007. To support the installation, the modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP3 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation.

ATTACHMENT 3 TO NL-06-060 Commitments made in Response to NRC Generic Letter 2006-03 for Indian Point 2 and 3 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 & 3 DOCKETS 50-247 AND 50-286

Docket Nos 50-247, 50-286 NL-06-060 Attachment 3 Page 1 of I This table identifies actions discussed in this letter for which Entergy commits to perform.

Any other actions discussed in this submittal are described for the NRC's information and are not commitments.

Commitment Type Scheduled Completion Date Complete modification (including One-Time October 31, 2007 supporting engineering evaluation) Action to install additional protection of the electrical raceway supports associated with the existing Hemyc ERFBS at Indian Point 2 Maintain compensatory measures One-Time October 31, 2007 in place at Indian Point 2 until Action completion of the installation of additional protection of the electrical raceway supports.

Complete modification (including One-Time Contingent upon supporting engineering evaluation) Action NRC approval of to install additional protection of revision to existing the electrical raceway supports exemptions and certain metallic penetrating items associated with the existing Hemyc ERFBS located outside containment at Indian Point 3 Maintain compensatory measures One-Time Contingent upon in place at Indian Point 3 until Action NRC approval of completion of the installation of revision to existing additional protection of the exemptions electrical raceway supports and certain metallic penetrating items

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