NL-10-042, Response to January 20, 2010 Request for Additional Information Re Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

Response to January 20, 2010 Request for Additional Information Re Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

ML101320230
Person / Time
Site:	Indian Point
Issue date:	05/04/2010
From:	Joseph E Pollock Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-10-042, TAC ME0798
Download: ML101320230 (108)

Text

'Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 En t&W Tel (914) 734-6700 J.E. Pollock Site Vice President NL-10-042 May 4, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 2 (TAC No. ME0798)

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

References:

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

2. Entergy letter NL-09-116, "Revision to Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 2," dated October 1, 2009

3. Entergy letter NL-09-031, "Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 2," dated March 6, 2009

Dear Sir or Madam:

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

NL-1 0-042 Page 2 of 2 response would be provided within 60 days - this was changed to 104 days in discussions with the Senior Project Manager.

As explained in the response to RAI-02.1 it has been determined that the operator manual action involving the local operation of Steam Generator Atmospheric Dump Valves does not require an exemption from the requirements of Appendix R, Paragraph III.G.2. This action is performed in the event of a fire in one of three Fire Areas as shown in Tables RAI-08.1-1, RAI-08.1-2, and RAI-08.1-5 in Attachment 1. This operator manual action is herein withdrawn from the Request for Exemption.

Note that some of the information contained in Tables RAI-08.1-1 through RAI-08.1-7 of differs from the information previously provided in Tables 2 though 8 in of References 2 and 3, and notes in the tables explain those differences.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, IPEC Licensing Manager at (914) 734-6710.

Sincerely, JEP/gd

Attachment:

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

ATTACHMENT 1 Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-10-042 Docket 50-247 Attachment 1 Page 1 of 105 Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph Ill.G.2 for Use of Operator Manual Actions RAI-01.1 Provide a discussion of how the proposed arrangement achieves the underlying purpose of the rule.

RESPONSE

The underlying purpose of 10 CFR 50, Appendix R is to/provide reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a single postulated fire in any plant area. Circuits which could cause maloperation or prevent the operation of redundant trains for post-fire safe-shutdown (SSD) and which are located in the same fire area must be protected in accordance with Paragraph III.G.2 of Appendix R. The intent of Paragraph III.G.2 is to ensure that one SSD equipment train remains "free of fire damage," and several alternatives are provided to establish a level of protection that provides reasonable assurance that one SSD equipment train will remain "free of fire damage." If such protection is not provided, then Paragraph III.G.2 specifies that alternative or dedicated shutdown capability be provided or an exemption from Paragraph III.G.2 be granted.

For the fire areas for which this exemption is requested (Fire Areas C, F, H, J, K, P, and YD), the plant's fire protection licensing basis indicates that Indian Point Unit No. 2 (IP2) is committed to compliance with Paragraph III.G.2. The explicit requirements of Paragraph III.G.2 mandate that (using one of the options given by III.G.2) the redundant trains should be adequately separated and protected, such that in the event of a fire in that area, at least one train will remain free of fire damage, and therefore operator manual actions (OMAs) for mitigation or recovery should not be required. However, as contained in the IP2 Appendix R Safe-Shutdown Analysis, in the event of a fire in one of the fire areas that are the subject of this exemption request, certain local OMAs are credited to prevent or mitigate certain undesirable equipment operations that may occur due to fire damage to cables or components located in that fire area. In each case, the OMAs described are taken in another area (outside the area affected by the fire) or, in certain cases, are implemented in the affected fire area, after 60 minutes have elapsed, to conservatively ensure that reentry to the fire-affected area is feasible.

The NRC permits exemptions from Paragraph III.G.2, as described in Regulatory Information Summary (RIS) 2006-10 (Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions), via the use of OMAs as long as those actions are feasible and can be reliably implemented. Given that the OMAs can be shown to be performed feasibly and reliably, with the operating resources available, the underlying intent of Paragraph III.G.2 (i.e., of being capable of using one of the redundant SSD equipment trains to achieve and maintain hot shutdown conditions) is met. The required SSD function may be temporarily rendered non-functional due to fire damage, but the OMAs discussed herein are structured to recover the SSD function in a

NL-1 0-042 Docket 50-247 Attachment 1 Page 2 of 105 sufficiently timely manner to support the Appendix R performance goals and ensure that hot shutdown conditions are achieved and maintained.

The credited OMAs listed in Tables 08.1-1 through 0.8.1-7 have been confirmed to be feasible and reliable operator actions during the post-fire coping scenario. Therefore, since an acceptable alternative to the regulation that has been provided by the NRC has been demonstrated to be acceptable for the OMAs that are the subject of this Request for Exemption, no demonstrable fire/nuclear safety benefit would be gained by the installation of additional modifications to comply with Paragraph III.G.2 in lieu of the crediting of the defined OMAs as credible and reliable means of achieving and maintaining safe-shutdown conditions. Therefore, the underlying purpose of the rule, which is to provide reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a single postulated fire in any plant area, is satisfied and the application of the prescriptive requirements of Paragraph III.G.2 in these particular circumstances is not necessary to achieve the underlying purpose of the rule.

RAI-02.1 Confirm and state whether an Exemption from III.G.2 requirements is the appropriate request for all of the OMAs [Operator Manual Actions] in the request, since safe shutdown capability is provided independent of the fire area of origin for many of the fire areas.

RESPONSE

General The OMAs for which exemption is requested are credited for use in the event of fire events that require a predominantly Central Control Room (CCR) based shutdown.

Certain elements of the safe-shutdown (SSD) capability for each of these areas is independent of the fire area of origin, but not all of the features required to meet the Appendix R SSD performance goals are independent of the area. Hence, it was Entergy's understanding at the time of submittal of the Request for Exemption dated March 6, 2009 and the Revision to the Request for Exemption dated October 1, 2009, that an exemption from the literal requirements of Paragraph III.G.2 is necessary to restore Appendix R compliance. Post-fire safe-shutdown is principally accomplished for these areas by remaining in the CCR and conducting a normal (non-alternative) shutdown.

In response to RAI-02.1, Entergy has reviewed the initial request for exemption and researched whether several of the OMAs for which exemption was requested in predominantly III.G.2 areas may be properly classifiable as III.G.3 alternative shutdown actions, based on the specific alternative (not redundant) hardware that is utilized by these OMAs. However, the results of this review did not conclusively establish that an exemption from the requirements of Paragraph III.G.2 is not required for these actions.

NL-10-042 Docket 50-247 Attachment 1 Page 3 of 105 As such, a request for exemption from the requirements of Paragraph III.G.2 appears to be necessary for these OMAs, with one exceotion.

It has been determined that the OMA involving the operation of the Steam Generator Atmospheric Dump Valves (SGADVs) using local control racks does not require an exemption from the requirements of Paragraph III.G.2 to allow the continued crediting of this action. The SGADVs have two functional/operational requirements in the IP2 safe-shutdown model: (1) they are required to be closed during hot shutdown to minimize steam generator inventory loss, and (2) they are required to be operable, at slightly over 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into the scenario, to commence a controlled cooldown to permit reaching Residual Heat Removal shutdown cooling mode entry conditions. As such, the active function of the SGADVs is a cooldown/transition action, and not an action required to support achieving and maintaining hot shutdown conditions. Per the guidance of SECY 08-0093 dated June 30, 2008 (Resolution of Issues Related to Fire-Induced Circuit Failures), the passive hot shutdown function of the SGADVs is that of "components important to safety that could adversely affect safe shutdown," and therefore, exemption from the literal requirements of Paragraph III.G.2 is not required to maintain compliance.

Accordingly, the OMA to locally operate the SGADVs is withdrawn from the Request for Exemption as applicable to Fire Areas C, F, and K. This change is reflected in the data tables presented herein.

The specific elements of the safe-shutdown performance goals that necessitate the Request for Exemption in each of the affected fire areas are as follows:

Fire Area C Area C anticipates a predominantly CCR-based shutdown, and therefore is considered a III.G.2 area, with OMAs credited for restoration of Auxiliary Feedwater (AFW) functions following fire area reentry after one hour has elapsed in the Appendix R event scenario.

As described in Entergy letter NL-09-031 dated March 6, 2009 and Entergy letter NL 116 dated October 1, 2009, during the initial hour of a Fire Area C event, the capabilities provided by Emergency Operating Procedure EOP 2-FR-H.1 (Response to Loss of Secondary Heat Sink) can be used to provide the Reactor Coolant Heat Removal function. Given that damage to redundant AFW pumps and valves is not expected as a result of the insignificant fire hazards in Fire Area C, at least one AFW pump and valve train will remain available for local manual operation following the postulated fire.

Given that the OMAs credited for Fire Area C are used to recover the function of one of the redundant AFW trains, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate.

NL-1 0-042 Docket 50-247 Attachment 1 Page 4 of 105 SSD Performance Goal Impacted:

1. Reactor Coolant Heat Removal Components and/or cables associated with all three AFW Pumps (21-23), all AFW flow control valves (FCV-405A through D, FCV-406A through D), the turbine-driven 22 AFW Pump steam supply and isolation valves (PCV-1 139, PCV-1 31 OA, B) and speed control valve (HCV- 1118), as well as motor-driven AFW pump recirculation valves (FCV-1 121, FCV-1 123) may be impacted by a fire in this area.

The OMAs are structured to support local manual post-fire operation of these components, as needed. As shown on Table RAI-08.1-1, the OMAs to restore AFW functionality would be implemented, worst case, following an initial exclusion period of one hour following a Fire Area C fire event. During the initial hour of the scenario, the reactor coolant heat removal function can be accomplished via the methods given in EOP 2-FR-H.1 if necessary. As the operational objective is to accomplish reactor coolant heat removal by restoring at least one of the redundant AFW trains to operation, it is Entergy's belief that an exemption from the requirements of Paragraph III.G.2 is appropriate.

Fire Area F Area F anticipates a predominantly CCR-based shutdown, and is considered a III.G.2 area, with OMAs credited for restoration of Reactor Coolant Makeup and Reactivity Control functions, and for restoration of an instrumentation power source. Each of the credited OMAs is directed at the recovery of one of the redundant safe-shutdown trains, and therefore, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate.

SSD Performance Goals Impacted:

1. Reactor Coolant Makeup and Reactivity Control An action may also be required to manually open Charging makeup path bypass valve 227 to ensure a reliable Charging makeup path to the Reactor Coolant System (RCS), and to open manual valve 288 to ensure a reliable suction path to the Charging pumps. While the Reactor Coolant Pump (RCP) seal injection makeup path can be expected to be available in the event of an Area F fire, the above described path provides assurance of the capability to establish a normal full-capacity reactor coolant makeup path. There is no alternative capability to provide an equivalent reactor coolant makeup path, other than the above listed valve train.

Hence, the OMAs support the recovery of a credited (required) safe-shutdown path function, and it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to permit the continued use of this OMA.

NL-10-042 Docket 50-247 Attachment 1 Page 5 of 105

2. Support - Electrical Power Instrument Buses 23 and 23A may be deenergized by the loss of their normal power source, and an OMA is credited in Fire Area A to transfer these buses to their backup power source. Hence, the OMA supports the restoration of a credited "green" path function, and it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to permit the continued use of this OMA.

Fire Area H Area H anticipates a predominantly CCR-based shutdown, and is considered a III.G.2 area, with certain alternative (III.G.3) SSD features credited and requiring OMAs to implement.

SSD Performance Goals Impacted:

1. Reactor Coolant Makeup and Reactivity Control Normal reactor coolant makeup air-operated Charging system valves 204A and 204B, which may be spuriously closed, must be remotely failed open by deenergizing 125VDC control power in the CCR or by closing pneumatic supply isolation valve IA-501. There is no alternative capability independent of Fire Area H to provide an equivalent reactor coolant makeup path. Hence, the OMA supports the credited "green" path function, and it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to permit the continued use of this OMA.

2. Process Monitoring A postulated fire in Fire Area H (Reactor Containment) may cause the loss of one or more redundant channels of required process monitoring instrumentation.

In this event, it may be necessary to deploy alternative SSD instruments (provided by the alternate safe-shutdown system, ASSS) for local monitoring of key parameters, although for this scenario the CCR will remain staffed, and all controls and instrumentation that are undamaged by the Fire Area H event will remain in use by CCR operators.

Manual containment isolation valves for ASSS instrumentation must be opened in Fire Area A to place ASSS pneumatic instruments (Steam Generator level, Pressurizer pressure and level) in operation, and alternative power supplies must be aligned to supply electrically-powered ASSS instrumentation (source range neutron monitoring, RCS Loops 21 and 22 hot and cold leg temperatures). The ASSS pneumatic instrumentation can be expected to remain operable despite fire-induced failure of the redundant electrically-operated instrumentation, as the ASSS instruments do not utilize any electrical components or cables. The ASSS electrically-powered instrumentation can be expected to remain operable as the

NL-1 0-042 Docket 50-247 Attachment 1 Page 6 of 105 cables for the ASSS instrument channels are protected in Fire Area H with a radiant energy shield. However, OMAs outside of Fire Area H are required to place these alternative instruments in service. Therefore, it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to permit the continued crediting of the necessary OMAs.

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

SSD Performance Goals Impacted:

1. Support (Electrical Power) 480V Buses 5A and/or 6A may experience loss of power due to spurious circuit breaker trips, and Instrument Buses 23 and 23A may experience loss of their normal power source. OMAs in the Control Building to reclose circuit breakers and to swap Instrument Buses 23 and 23A to their backup power source may be required.

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

3. Reactor Coolant Heat Removal Fire-induced circuit damage may impact the operability of the motor-driven AFW pumps, thereby requiring the use of the turbine-driven AFW pump, via OMA performed in the AFW Pump Building.

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 7 of 105 request for an exemption from the requirements of Paragraph III.G.2 for the use of these OMAs is appropriate.

SSD Performance Goal Impacted:.

1. Reactor Coolant Heat Removal OMAs to align 21 AFW Pump to an alternative power supply, and to locally operate AFW pump flow control valves and AFW pump recirculation bypass valve Fire Area P The credited OMAs for Fire Area P, which include the potential starting and use of the Appendix R Diesel Generator, and the powering of 23 Component Cooling Water (CCW) Pump from its alternative SSD power source (provided by the ASSS), may appear to be considered alternative shutdown actions, and therefore should be considered as III.G.3 OMAs. However, Fire Area P has been previously designated a III.G.2 area by virtue of an exemption granted for separation between the redundant CCW pumps located in this area. While both of the OMAs are performed outside of Fire Area P and utilize ASSS components, it is Entergy's belief that these OMAs should be considered as III.G.2 actions and that a request for an exemption from the requirements of Paragraph III.G.2 for these OMAs is appropriate.

For Fire Area P, Entergy is seeking NRC concurrence that the previously granted exemption from the requirements of Paragraph III.G.2 for this area provides sufficient definition and evidence of prior NRC approval of the credited OMAs to meet current NRC expectations per RIS 2006-10. While the OMAs credited for Fire Area P may be viewed as alternative shutdown actions, and therefore not within the scope of Paragraph III.G.2, Entergy has classified Fire Area P as a III.G.2 area and it is Entergy's belief that a request for an exemption from the requirements of Paragraph III.G.2 is appropriate to continue the use of these OMAs. The potentially required OMAs appear to have been acknowledged by the NRC in a Safety Evaluation Report (SER) dated October 16, 1984, which granted an exemption from the requirements of Paragraph III.G.2. In that SER it was concluded that the credible fire scenario in Fire Area P would not be expected to render all redundant trains of the CCW function inoperable. However, the presence of a transfer switch to provide an alternative power supply to one CCW pump was acknowledged, and measures to provide protection/separation for this transfer switch were mandated by the SER. Therefore, it appears that the conditional use of the transfer switch via an OMA following a fire in the CCW pump area was acknowledged and accepted in this SER.

SSD Performance Goal Impacted:

1. Support (Component Cooling)

OMA to align one CCW pump to an alternate power supply, thereby recovering one of the redundant CCW trains.

NL-10-042 Docket 50-247 Attachment 1 Page 8 of 105 Fire Area YD The credited OMA for Fire Area YD, which is local manual alignment of the Charging makeup path to the RCS, is not an alternative shutdown action, although this same action is credited in the alternate shutdown sequence. It is Entergy's belief that consideration of the OMA as a III.G.2 action is the most appropriate classification of the action, and hence an exemption from the requirements of Paragraph III.G.2 is appropriate.

SSD Performance Goals Impacted:

1. Reactor Coolant Makeup and Reactivity Control An action may be required to manually open Charging makeup path bypass valve 227 to ensure a reliable Charging makeup path to the RCS.

RAI-02.2 State the specific requirements of III.G.2 that are not met for each of the requested OMAs, e.g., a lack of fire barriers, spatial separation, automatic suppression, etc.

RESPONSE

For each of the fire zones where OMAs are requested, the compliance with Paragraph III.G.2 is summarized in Tables RAI-GEN-1 through RAI-GEN-27. For each subject fire zone, the line item "App R III.G.2 Compliance" identifies compliance (Yes or No) for 3-hr Barrier, 20 ft Separation, or one-hour Enclosure. Also, the availability of suppression and/or detection in the fire zone is identified in the line item.

RAI-02.3 Provide a summary of the plant-specific features that compensate for the lack of III.G.2-required features, identified in RAI-02.2, for each of the requested OMAs. For example, note any enhanced defense-in-depth measures such as a lack of ignition sources or combustibles, more robust or supplemental detection and suppression systems and other physical or administrative controls.

RESPONSE

For each of the fire zones where OMAs are requested, Tables RAI-GEN-1 through RAI-GEN-27 provide a summary of plant-specific fire protection features in each fire zone.

The tables provide an account of combustible loading (both fixed and transient), ignition sources, detection, suppression, administrative controls, and any additional fire protection features in the fire zone.

NL-10-042 Docket 50-247 Attachment 1 Page 9 of 105 RAI-02.4 Appendix R establishes the concept of defense-in-depth and III.G.2 requires operators be able to safely and reliably achieve and maintain hot shutdown capability from the control room. Provide a technical explanation that justifies how the proposed methods will result in a level of protection that is commensurate with that intended by III.G.2.

RESPONSE

The intent of Paragraph III.G.2 is to ensure that one SSD equipment train remains "free of fire damage," and several alternatives are provided to establish a level of protection that provides reasonable assurance that one SSD equipment train will remain "free of fire damage." As elaborated in the response to Generic Letter 86-10 (Implementation of Fire Protection Requirements), Question 3, which clarifies the definition of "free of fire damage,'" the intent of the requirements of Paragraphs III.G.2.a, IIl.G.2.b, and III.G.2.c is to ensure that at least one of the redundant trains is capable of performing its intended function during and after the postulated fire, as needed. The supporting IP2 thermal-hydraulic analyses demonstrate that the operation of the affected components is not needed during the actual fire, but that timely restoration of the function via appropriate OMAs is adequate to ensure the requisite safe-shutdown capability. The timely recovery of the affected safe-shutdown functions to ensure that the required functions are available in sufficient time to support the Appendix R safe-shutdown performance goals, meets the intent of the train protection requirements of Paragraph Ill.G.2. Tables RAI-08.1-1 through 08.1-7 describe the required OMAs, the time required to diagnose and perform these actions, and the resultant available time margin, defining the basis for ensuring that at least one SSD train is capable of performing its function, post-fire, as needed. Table RAI-06.1-1 describes the hazards and ignition sources in each of the fire areas and fire zones containing the cables and/or components of concern, and their general proximity and the expected effects of the fire hazards on the SSD cables and components. In each case, the IP2 safe-shutdown analysis and safe-shutdown coping methodology accommodates the expected fire-induced failure of the cables/components of concern, and is structured to ensure the restoration of function in an adequately timely manner.

The underlying intent of Paragraph III.G.2 - which is to ensure that at least one SSD equipment train remains functional despite a postulated fire event - is met by virtue of strategic OMAs that are structured to prevent or recover from postulated fire damage to the credited SSD train, serving to ensure the train remains in service or is returned to service in a timely manner, to support achieving and maintaining safe, stable hot shutdown conditions. The requirement of Paragraph III.G.2 to maintain one train free of fire damage is intended to ensure that, despite a fire in an area containing both redundant safe-shutdown equipment trains, one of the redundant SSD equipment trains can be relied upon to perform the necessary safe-shutdown function, without need to rely on alternative shutdown measures. If the credited SSD train is maintained free of fire damage by one of the methodologies presented by Paragraph III.G.2, or if the credited SSD train is successfully restored to functionality by a feasible and reliable OMA method, there is no adverse impact on the required post-fire safe-shutdown capability.

NL-1 0-042 Docket 50-247 Attachment 1 Page 10 of 105 The potential fire challenges in each fire area and fire zone containing cables and/or components of concern are described in Table RAI-06.1-1 and Tables RAI-GEN-1 through RAI-GEN-27.

Given that the OMAs can be shown to be performed feasibly and reliably, with the operating resources available, the underlying intent of Paragraph III.G.2 (i.e., of being capable of using one of the redundant SSD equipment trains to achieve and maintain hot shutdown conditions) is met. As discussed above, the required SSD function may be temporarily rendered non-functional due to fire damage, but the OMAs discussed herein are structured to recover the SSD function in a sufficiently timely manner to support the Appendix R performance goals and ensure that hot shutdown conditions are achieved and maintained.

The benchmark timed procedural evolutions and supporting analyses performed by Entergy have provided confirmation (as discussed herein in the responses to RAI-07.1, RAI-08.1, RAI-08.2, and RAI-09.1) that the credited OMAs can indeed be relied upon to ensure the post-fire functionality of one of the redundant SSD equipment trains.

RAI-03.1 Provide a discussion of any other Exemptions or evaluations, including licensee-developed evaluations, e.g., Generic Letter 86-10 evaluations, which impact this request in any way and provide a justification for why such impact should be considered acceptable.

RESPONSE

For each of the fire zones where OMAs are performed, Tables RAI-GEN-1 through RAI-GEN-27 provide a listing of approved exemptions, engineering evaluations (i.e., 86-10 evaluations), and Fire Hazards Evaluations applicable to the fire zone. Line item "App R III.G.2 Exemptions" identifies if an exemption(s) is approved for the fire zone and cites the applicable SER letter that granted the approval. Line item "Other Evaluations (i.e.,

86-10)" lists applicable engineering evaluations by title and Entergy document number.

A summary discussion of the applicable SERs or engineering evaluations is provided below.

Fire Area C / Fire Zone 23 SER dated October 16, 1984 approved an exemption from the requirements of Paragraph III.G.2 for the AFW Pump Room (Fire Zone 23), based on low fire loading, widely dispersed fixed combustible materials, and limited access minimizing transient combustible materials that would preclude a fire of significant duration or magnitude.

Also, the installed smoke detectors would provide early warning of fire conditions before significant damage would occur. As prescribed in the SER, a partial height barrier (radiant energy shield) is installed between AFW Pumps 21 and 23 and the power supply cable for 23 AFW Pump is wrapped with a 30-minute rated Hemyc fire barrier.

NL-1 0-042 Docket 50-247 Attachment 1 Page 11 of 105 Engineering Report IP-RPT-04-00188 (Evaluation of Hemyc Wrap Fire Protective Systems) evaluated the fire endurance rating (equivalent rating by fire test comparison) of installed Hemyc electrical raceway fire barrier systems (ERFBS). The report incorporates the consideration and the integration of the results of the 2005 Hemyc fire testing program conducted under NRC sponsorship by Sandia National Laboratories.

The results of the NRC Hemyc fire testing program documented in Information Notice 2005-07 (Results of HEMYC Electrical Raceway Fire Barrier System Full Scale Fire Testing), and in two other referenced Hemyc test reports reviewed under this evaluation, provide sufficient basis to conclude that the Hemyc ERFBS installed on the power supply cable for 23 AFW Pump will provide at least a 30 minute fire resistance rating, consistent with the NRC-approved exemption.

Fire Area F / Fire Zones 5A and 7A Engineering Report IP-RPT-04-00227 (Evaluation of Fire Separation Between Fire Zone 30A (Fire Area A), Piping Bay and Tunnel and the Adjacent Primary Auxiliary Building (PAB) Fire Zones 5A, 7A, and 23A (Fire Area F)) evaluated the adequacy of the fire separation barriers between Fire Area A and Fire Area F at the interface of the vertical piping shaft (Fire Zone 30A in Fire Area A) and adjoining areas of the Primary Auxiliary Building (PAB Fire Zones 5A, 7A, and 23A in Fire Area F), in accordance with the guidance of GL 86-10.

The evaluation concluded that existing walls (iLe., barriers), as constructed, provide adequate separation between Fire Area A and Fire Area F, for the hazards present, to meet the requirements of fire area separation as defined by Appendix R. The evaluation established that the unsealed penetrations in the existing walls do not compromise the overall effectiveness of the fire barrier.

The elements examined by this evaluation support the conclusion that a fire of sufficient intensity, magnitude, or duration is not likely to develop that could challenge the subject barriers.

• Fires, if they were to occur, would be slow to develop and of minimal intensity because of the nature and quantity of combustible material in these fire zones.

• Fire detection would provide early warning and initiate Fire Brigade response to a fire event.

Fire Area F / Fire Zone 7A Engineering Report IP-RPT-04-00228 (Evaluation of Fire Separation of the Primary Auxiliary Building (PAB) Fire Zone 7A from the Adjacent IP1-1P2 Passageway Fire Zone 130) evaluated the adequacy of the fire separation barriers between Fire Area F and Fire Area J at the interface of the PAB Corridor (Fire Zone 7A in Fire Area F) and the adjacent IP1-IP2 Passageway (Fire Zone 130 in Fire Area J).

NL-10-042 Docket 50-247 Attachment 1 Page 12 of 105 The evaluation concluded that existing walls (i.e., barriers), as constructed, do not present a risk that could adversely impact the plant's ability to achieve and maintain safe shutdown. The barrier provides adequate separation between Fire Area F and Fire Area J, for the hazards present, to meet the requirements of fire area separation as defined by Appendix R.

Based on this evaluation, the overall effectiveness of the barrier to maintain fire separation between Fire Area F and Fire Area J was determined to be acceptable for the hazards present. Fire originating in either of the interfacing Fire Zones is not expected or likely to be of sufficient intensity, magnitude, or duration to propagate from one Fire Area to the other.

" Fire, if it were to originate in either zone, would be slow to develop and of minimal intensity because of the nature and quantity of combustible material in the fire zone.

• Installed detection in Zone 7A or personnel passing through the area will alert the CCR to initiate a Fire Brigade response.

• Rapid Fire Brigade response, manual fire fighting equipment, and minimal combustibles in the area preclude the development of a significant fire.

SER dated October 16, 1984 approved an exemption from-the requirements of Paragraph III.G.2 for Fire Zones 5 and 7A, for separation of redundant safe-shutdown equipment trains, and also an exemption from the requirements of Paragraph III.G.3 for provision of an automatic suppression system.

Engineering Report IP-RPT-04-00188 evaluated the fire endurance rating (equivalent rating by fire test comparison) of installed Hemyc ERFBS. The report incorporates the consideration and the integration of the results of the 2005 Hemyc fire testing program conducted under NRC sponsorship by Sandia National Laboratories.

The results of the NRC Hemyc fire testing program documented in Information Notice 2005-07, and in two other referenced Hemyc test reports reviewed under this evaluation, provide sufficient basis to conclude that the Hemyc ERFBS installed on the power supply cable for 23 CCW Pump will provide at least a 30 minute fire resistance rating, consistent with the NRC-approved exemption.

Fire Area H / Fire Zone 71A Engineering Evaluation PGI-00323 (Abandonment or Removal of Radiant Energy Shield on Selected Conduit in Containment (TE-5139, TE-5140, TE-5141, TE-5142))

evaluated the redundant safe-shutdown capability, independent of Fire Zone 71A, to establish the basis for the elimination of part of the radiant energy shields installed on conduits in containment which contain ASSS channels for RCS loops 21 and 22 hot and cold leg temperatures.

NL-1 0-042 Docket 50-247 Attachment 1 Page 13 of 105 The evaluation concluded that the radiant energy shield in Fire Zone 71 A may be removed or abandoned in place without adverse impact on safe-shutdown capability or the Fire Protection Program. This is based on adequacy of separation of redundant safe-shutdown equipment and cables (i.e., RCS Loops 23 and 24 instrumentation) from the ASSS equipment and cables that can be aligned and utilized in the event of a fire in Fire Zone 71A.

Fire Area J / Fire Area K Engineering Report IP-RPT-04-00226 (Evaluation of Fire Separation between AFPB Fire Zone 61A (Fire Area K), and Adjacent Turbine Building Fire Zones 42A and 52A (Fire Area J) evaluated the adequacy of the fire separation barriers between Fire Area K and Fire Area J at the interface of the AFW Pump Building (Fire Area K) and the Unit 2 Turbine Building (Fire Area J).

The evaluation concluded that existing walls (i.e., barriers), as constructed, provide adequate separation between Fire Area K and Fire Area J, for the hazards present, to meet the requirements of fire area separation as defined by Appendix R.

Fires originating in either of the interfacing Fire Zones is not expected or likely to propagate from one Fire Area to the other. A fire originating in Fire Zone 61A, 42A, or 52A is not likely to be of sufficient intensity, magnitude, or duration that could breach the subject barriers.

The primary combustible in the Turbine Building is lube oil associated with the turbine generator; however, lube oil is not stored in Fire Zones 42A or 52A. Notwithstanding, a lube oil fire could potentially impact fire barriers 61A/42A and 61A/52A. With the exception of the unsealed penetrations, the barrier is a robust masonry construction typically fire rated for 3-hours and is not expected to fail under fire conditions. An accumulation of heat near the barrier sufficient to breach the barrier is not expected due to the large open space of the Turbine Building above the barriers and the Turbine Building roof ventilators. The 40-ft long Pipe Bridge and 4-ft thick concrete AFW Pump Building Shield Wall separates critical equipment in the AFW Pump Building from the barrier. Cable tray penetrations through the barrier are fire stopped to prevent propagation of fire along the cable tray. There are no combustibles on either side of the barrier near the unsealed piping penetrations barrier such that a fire originating in the Turbine Building is not expected to propagate past the barrier into the AFW Pump Building.

Fire Area P / Fire Zone 1 SER dated October 16, 1984 approved an exemption from the requirements of Paragraph III.G.2 for the CCW Pump Room (Fire Zone 1) based on low fire loading, widely dispersed fixed combustible materials, and limited access minimizing transient combustible materials would preclude a fire of significant duration or magnitude. Also, the installed smoke detectors would provide early warning of fire conditions before significant damage would occur. As prescribed in the SER, a partial height barrier

NL-10-042 Docket 50-247 Attachment 1 Page 14 of 105 (radiant energy shield) is installed between CCW Pumps 22 and 23, the power supply cable for 23 CCW Pump is wrapped with a 30-minute Hemyc ERFBS, and a non-combustible barrier is installed behind transfer switch EDF-9 protecting the height and width of the switch.

Engineering Report IP-RPT-04-00188 evaluated the fire endurance rating (equivalent rating by fire test comparison) of installed Hemyc ERFBS. The report incorporates the consideration and the integration of the results of the 2005 Hemyc fire testing program conducted under NRC sponsorship by Sandia National Laboratories.

The results of the NRC Hemyc fire testing program documented in Information Notice 2005-07, and in two other referenced Hemyc test reports reviewed under this evaluation, provide sufficient basis to conclude that the Hemyc ERFBS installed on the power supply cable for 23 CCW Pump will provide at least a 30 minute fire resistance rating, consistent with the NRC-approved exemption.

RAI-04.1 Where fire protection features such as detection and suppression systems and fire rated assemblies are installed, describe the technical basis for such installations including the applicable codes, standards and listings.

RESPONSE

For each of the fire zones where OMAs are performed, Tables RAI-GEN-1 through GEN-27 provide a listing of the applicable Code of Record for the installed detection or suppression systems. A review of the installed systems was provided to the Staff in the evaluation of IP2 against the requirements of Appendix A to BTP 9.5-1 by letters submitted in 1976 through 1980. NRC SER dated January 31, 1979 and the Supplement dated October 31, 1980, subsequently approved the IP2 Fire Protection Program and related systems.

Within the fire zones of concern to this Request for Exemption, fire-rated assemblies are only used and credited for intra-zone separation of redundant safe-shutdown equipment trains in Fire Area F (Fire Zone 7A) and Fire Area P (Fire Zone 1). These assemblies consist of the Hemyc ERFBS, and the performance characteristics of this ERFBS have been determined to be adequate for the hazards of the areas of installation.

RAI-04.2 Provide a technical justification for any deviations from codes, standards and listings by independent testing laboratories in the fire areas that could impact this evaluation.

Where deviations from other applicable codes, standards, or listings have been identified, these are documented and dispositioned within the IP2 Corrective Action

NL-10-042 Docket 50-247 Attachment 1 Page 15 of 105 Program. Additional specific deviations have been addressed in individual engineering analyses, as documented on Tables RAI-GEN-1 through RAI-GEN-27.

RAI-04.3 Provide a technical justification for any non-rated fire protection assemblies.

RESPONSE

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

Fire Areas C. F. and P Engineering Report IP-RPT-04-00188 evaluated the fire endurance rating (equivalent rating by fire test comparison) of installed Hemyc ERFBS. The report incorporates the consideration and the integration of the results of the 2005 Hemyc fire testing program conducted under NRC sponsorship by Sandia National Laboratories.

The results of the NRC Hemyc fire testing program documented in Information Notice 2005-07, and in two other referenced Hemyc test reports reviewed under this evaluation, provide sufficient basis to conclude that the installed Hemyc ERFBS will provide at least a 30 minute fire resistance rating, consistent with the NRC-approved exemption. The Hemyc ERFBS is used in Area C to provide protection for the power cable for 23 AFW pump, and is used in Areas F and P to provide protection for the power cable for 23 CCW Pump.

Fire Area F / Fire Zone 5A and 7A Engineering Report IP-RPT-04-00227 evaluated the fire barrier interface between Fire Zone 7A (Fire Area F) and Fire Zone 30A (Fire Area A). The report concluded that:

• Although the barrier does not meet a 3-hour rating due to the presence of unsealed penetrations, the general construction of the barrier is adequate for the fire hazards present thereby meeting the requirements for fire area separation as required by Appendix R.

• The elements examined by the evaluation support the conclusion that a fire of sufficient intensity, magnitude, or duration that could challenge the subject barriers is not likely to develop.

• Smoke and hot gas development and its migration through the unsealed penetrations is not expected to be significant such that it would adversely impact the ability to perform the required manual operations in Fire Area F for a fire in Fire Area A.

NL-10-042 Docket 50-247 Attachment 1 Page 16 of 105

• SSD cables routed in Zone 30A are remotely located from the unsealed penetrations and would not be subjected to fire effects that might otherwise challenge the penetrations.

Engineering Report IP-RPT-04-00228 evaluated the adequacy of the fire separation barriers between Fire Area F and Fire Area J at the interface of the PAB Corridor (Fire Zone 7A in Fire Area F) and the adjacent IP1-IP2 Passageway (Fire Zone 130 in Fire Area J). The report concluded that:

" Although the barrier does not meet a 3-hour rating due to the presence of unsealed penetrations, the general construction of the barrier is adequate for the fire hazards present thereby meeting the requirements for fire area separation as required by Appendix R.

• A fire originating in Fire Zone 7A or 130A is not likely to be of a sufficient intensity, magnitude, or duration that could breach the subject barriers or propagate between the adjacent areas.

• Installed detection in Zone 7A or personnel passing through the area will alert the CCR to initiate a rapid Fire Brigade response.

Fire.Area J / Fire Area K Engineering Report IP-RPT-04-00226 (Fire Separation between AFW Pump Building (Fire Area K) and Turbine Building (Fire Area J)) evaluated the fire barrier interface between the AFW Pump Building (Fire Area K) and the Turbine Building (Fire Area J).

The report concluded that:

I

• Although the barrier does not meet a 3-hour rating due to the presence of unsealed penetrations, the general construction of the barrier is adequate for the fire hazards present thereby meeting the requirements for fire area separation as required by Appendix R.

• A fire originating in Fire Zone 61A, 42A, or 52A is not likely to be of a sufficient intensity, magnitude, or duration that could breach the subject barriers or propagate between the adjacent buildings.

" A lube oil fire originating in the Turbine Building, while significant, is not expected to breach the barriers or propagate through the barriers into the AFW Pump Building due to the construction features of the barriers and adjacent buildings, and the lack of combustibles near the barriers.

RAI-05.1 Provide critical details or assumptions regarding the in situ and transient fire hazards that could threaten redundant equipment for each fire area included in the requests.

This information may include, but is not limited to:

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

NL-10-042 Docket 50-247 Attachment 1 Page 17 of 105

• The number and types of equipment that may exhibit high energy arcing faults, and the relationship between this equipment and any secondary combustibles,

• The quantity of cables and other secondary combustibles and their relationship to potential ignition sources,

" The cable type, e.g., thermoplastic or thermoset. If thermoplastic cables are used, provide a discussion of self-ignited cable fires,

• Ratings for cables, e.g., IEEE-383, etc. If not rated, justify why fire spread would be assumed to be slow,

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

" Dimensions of the rooms including ceiling heights.

RESPONSE

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

• The number, type and location of potential ignition sources The potential ignition sources in each fire zone of concern within the fire areas identified in the Request for Exemption have been tabulated consistent with the guidance of NUREG/CR-6850 (EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities), Task 6. The ignition source information is presented for the fire areas of concern in Tables RAI-GEN-1 through RAI-GEN-27. The relationship of ignition source location to the safe-shutdown features of concern is discussed in Table RAI-06.1-1.

• The number and types of equipment that may exhibit high energy arcing faults (HEAFs), and the relationship between this equipment and any secondary combustibles The number and types of equipment that present the potential for HEAFs in each fire zone of concern within the fire areas identified in the Request for Exemption have been identified consistent with the guidance of NUREG/CR-6850, Task 6.

The ignition source information is presented for the fire areas of concern in Tables RAI-GEN-1 through RAI-GEN-27. Note that the potential for HEAFs only exists in Fire Zone 43A. The relationship of ignition source location to the safe-shutdown features of concern is discussed in Table RAI-06.1-1.

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

27. Cable in each fire zone is quantified by its British Thermal Unit (BTU)

NL-1 0-042 Docket 50-247 Attachment 1 Page 18 of 105 contribution to the fixed combustible loading for that fire zone. Table line item "Cable Insulation Quantity in BTU" lists the specific cable BTU contribution and loading in BTU/sq ft. Fire severity is given in minutes based on an equivalent fire severity of 80,000 BTU/sq ft/hour.

The cable type, e.g., thermoplastic or thermoset. If thermoplastic cables are used, provide a discussion of self-ignited cable fires Cable types installed at IP2 during original construction include both thermoplastic and thermoset cables, as described below. Cables installed via subsequent plant modifications and cable replacement/maintenance activities are of thermoset construction, as discussed below.

As noted below, one category of original plant cables is of thermoplastic (PVC-insulated) construction, but given the asbestos-glass braid outer jacket construction, the performance of this cable can be expected to more closely approximate that of a thermoset cable construction. Glass braid jacketed cable is marketed for use in factories where molten steel or glass may make contact with the cable, for use in high temperature equipment such as heaters and transformers, and as internal wiring for cooking appliances, typical - Bay Associated High-Temperature Wire and Cable. Cables with glass braid jacket material are also marketed for Appendix R as rated fire cables (i.e., 1-hour, typical - Rockbestos-Surprenant Corp. Firezone CRC Cable, Spec. RSS-5-142).

With respect to the significance of self-ignited cable fires involving the thermoplastic-insulated cables, these scenarios are considered to be of low likelihood based on overcurrent protection provided for power and control circuits and the current-limited characteristics of instrumentation cables, in addition to the substantial construction of the outer asbestos-glass fiber jacket on these cables. However, based on the consistent use of flame-retardant cables throughout IP2, there is reasonable assurance that any cable tray fire (whether self-ignited or externally initiated) will be limited in scope and severity.

Ratings for cables, e.g., IEEE-383, etc. If not rated, iustify why fire spread would be assumed to be slow Original IP2 Plant Cables The cable specified for low power and control applications for IP2 was described in a response dated May 19, 1981 to an NRC request for information dated February 20, 1981. The response described the cable originally specified for IP2 as follows:

a) Silicone rubber insulated cable with a lapped Mylar tape separator and an overall braid of closely woven asbestos and finished with a flame and moisture resistant saturant.

b) EPR, insulated cable with a neoprene or lead jacket.

NL-1 0-042 Docket 50-247 Attachment 1 Page 19 of 105 c) PVC insulated cable with a closely woven glass braid and overall covering of lapped Mylar tape and closely woven asbestos braid saturated with a flame and moisture resistant finish.

The fire retardant properties of the original IP2 cables were demonstrated by the following tests for flame retardance:

a) Standard vertical flame test in accordance with ASTM D-470-59T, "Tests for Rubber and Thermoplastic Insulated Wire and Cable" b) Five minute vertical flame test made with cable held in a vertical position and a 1750°F flame applied for 5 minutes, and Bonfire test which consisted of exposing the cable sample for 5 minutes. Bundles of three and six cables were exposed to a flame produced by igniting transformer oil in a 12-inch pail with the cable supported horizontally over the center of the pail and the lowest cable 3 inches above the top of the pail.

With these types of fire resistant cable, a fire will not propagate along the cable.

This characteristic was demonstrated by a fire which occurred at IP2 in November 1971 during plant construction. The fire was of such intensity that building structural steel and electrical equipment were damaged, yet the cable in overhead trays was not damaged beyond the exposure area, nor did it re-ignite after the external sources of combustion had been extinguished. New low power, control, and instrumentation cable is required to meet similar flame resistance requirements as the original cable, via qualification to IEEE 383 Flame Test requirements.

IP2 Cables Installed After Original Construction Cables installed after original plant construction were selected and qualified in accordance with Con Edison Specification EO-13, which requires the use of thermoset cables, qualified in accordance with the IEEE 383 Flame Test.

Specification EO-13, Section A.3, specifies that:

"Cables are to be insulated with flame retardant materials, either cross-linked polyethylene (XLP) or integral ethylene-propylene rubber (EPR). In addition ... the XLP cables shall conform to the latest revision of ICEA Publication S-66-524 and the EPR cables shall conform to ICEA Publication Number S 516."

Controls on hot work and transient combustibles in the area, and the proximity of secondary combustibles that could be impacted by a transient fire Hot work in all of the fire areas identified in the Request for Exemption is subject to control of hot work activities in accordance with procedure EN-DC-127 (Control of Hot Work and Ignition Sources). All hot work requires review and

NL-10-042 Docket 50-247 Attachment 1 Page 20 of 105 approval by a qualified Hot Work Supervisor and/or Fire Protection Engineering, and a hot work permit issued for such activities is not valid for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If required, the activity may be reevaluated by a Hot Work Supervisor and/or Fire Protection Engineering, and the permit may be extended on a daily basis to a maximum valid duration of 31 days. In summary, hot work activities are strictly controlled, and qualified Hot Work Supervisors and/or Fire Protection Engineering remain cognizant of all active hot work permits.

With the exception of Fire Areas J and YD, all of the fire areas identified in the Request for Exemption are subject to the Indian Point Energy Center Transient Combustible Control Program, as implemented via procedure EN-DC-161 (Control of Combustibles), and are controlled as "Level 2" combustible control areas. Small quantities of combustibles are permitted in these areas, but unattended combustibles exceeding any of the following quantities require formal prior review and approval by Fire Protection Engineering, with imposition of additional compensatory actions or protective measures, as determined to be required:

• 100 lbs of fire-retardant treated lumber

• 25 lbs of loose ordinary combustibles

• 5 gallons of combustible liquid in an approved container

• One pint of flammable liquid in an approved container

• One 20-oz flammable aerosol can With respect to the effects of the proximity of transient combustibles to "secondary combustibles," the guidance of procedure EN-DC-161 includes consideration by Fire Protection Engineering of any structures, systems, and components (SSCs) or other combustible materials in the affected area that could be impacted by the presence and staging of the transient combustibles.

Where the performance of the Transient Combustible Evaluation is indicated, these parameters are reviewed and additional guidance is provided in the Transient Combustible Evaluation, as needed, to protect adjacent combustibles, provide protection for combustibles located within a defined footprint, to constrain the staging location of the transient combustibles, or to specify other measures as deemed appropriate by Fire Protection Engineering.

Fire Area J, consisting of the Turbine Building and certain adjacent fire zones, does not contain safety-related SSCs and is not subject to the explicit transient combustible controls of EN-DC-1 61. However, procedure OAP-01 7 (Plant Surveillance and Operator Rounds) includes inspection guidelines for operator rounds, which include monitoring for general area cleanliness and for any housekeeping problems that may present a fire or safety concern.

Consequently, operator rounds performed each shift provide for the monitoring of Area J and other plant areas for accumulations of combustibles that could present an unacceptable fire safety challenge. Similarly, procedure EN-MA-132 (Housekeeping) includes guidance for monitoring general area cleanliness as well as monitoring for accumulations of combustibles.

NL-1 0-042 Docket 50-247 Attachment 1 Page 21 of 105 Dimensions of the rooms including ceiling heights Room dimensions (square footage), including ceiling heights, for the fire zones of concern within the fire areas identified in the Request for Exemption are presented in Tables RAI-GEN-1 through RAI-GEN-27.

RAI-06.1 Provide a description of the proximity of the redundant train equipment to in situ hazards and the spatial relationship between the redundant trains in the fire area such that if they are damaged, manual actions would be necessary. Note, that this question is distinct from the RAI addressing Ignition Sources and Combustible Loading, which is generally focused on the combustibles in an area, whereas, this RAI addresses the specific relationship between ignition sources and combustibles and the redundant trains.

RESPONSE

The Appendix R safe-shutdown analysis (SSA) evaluates the adequacy of train separation on a fire area basis, and where determined to be an appropriate means of protecting or recovering an affected equipment train, the SSA identifies OMAs that can be taken to mitigate a fire-induced failure of both trains. However, with few exceptions (e.g., Fire Area C), the IP2 fire areas are comprised of a number of fire zones, separated from each other by spatial separation and/or barriers of various types and construction. Table RAI-06.1-1 and supporting Tables RAI-GEN-1 through RAI-GEN-27 are based on the recognition, as established by the IP2 Fire Hazards Analysis, that the fire hazards, mitigating features, and resultant fire effects are fundamentally addressed at the fire zone level. For many fire zones, there is a reasonable expectation that the damage footprint from the credible fire scenario would be confined to the boundaries of the zone of origin, and not involve an all-consuming fire that would engulf all fire zones within a given fire area.

To that end, the referenced tables provide a view of the discrete challenges to the cables and/or components necessary to achieve and maintain safe hot shutdown conditions. In most cases, a fire in any given zone would create conditions that could require the invocation of only a small subset of the OMAs that have been credited for the affected fire area, as listed on Tables RAI-08.1-1 through RAI-08.1-7. As such, the operational challenge imposed by any given fire zone scenario can be expected to be less severe than the operator action set tabulated for the overall fire area. This reduced challenge, in turn, is supportive of enhanced feasibility and reliability of the credited OMAs.

NL-10-042 Docket 50-247 Attachment 1 Page 22 of 105 RAI-06.2 Provide a description of the suppression, detection and any other systems that are present and capable of mitigating the postulated events for the fire areas included in this request.

RESPONSE

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

NL-10-042 Docket 50-247 Attachment 1 Page 23 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

/Zone 50Combustibles C /23 All three AFW Small quantities of cable in The cable runs and pump Nonmechanistic ignition of control or instrument cables in pumps, flow overhead trays, with pumps and motors are the credible ignition the overhead trays would present an immediate impact on control valves, valves at floor elevation. The sources, in addition to an redundant AFW trains, as the trays contain (in part) control and trays containing cables serving alternative power transfer cables serving the AFW flow control valves associated the AFW flow control valves are switch located at the south end The remaining fixed combustibles, consisting of a minute cables also located in the overhead of the room quantity of lube oil and electrical cabinets, present no credible challenge to the AFW components in the zone The smoke detection system in the zone provides assurance of early warning of a fire condition, enabling fire brigade response prior to significant fire development F / 5A Cables The dominant combustible is The ignition sources, The flame-retardant characteristics of the cables ensure associated cable in overhead trays. The consisting of cable tray runs, that any fire would be limited in scope and severity with Charging cables of concern are located in junction boxes, and electrical No fire detection is installed in the zone, but given the suction valves or adjacent to the trays. cabinets, are in direct contact nogfictionisinstalledi insignificant ignition sources, the the occurrence one bu giveof a fire th of LCV-1 12C with, or in close proximity to the significance in the zone is a low-credibility event. Smoke 1128 cdetection in adjacent Fire Zone 7A may provide 112B annunciation of any smoke that may migrate out of Fire Zone 5A to the main corridor area.

F/6 Cables Cables and valve LCV-1 12B are The only credible ignition There is no clear mechanism for ignition of the lubricating associated located adjacent to the Charging source, the Charging pump oil contained within the pump with: Charging pump, containing lubricating oil, motor, is located at the suction valves the dominant combustible in the midpoint of the zone, while The smoke detection system in the zone provides LCV-1 12C zone LCV-1 12B and cables are assurance of early warning of a fire condition, enabling and LCV- located at the south end of the brigade response prior to significant fire development.

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

Buses 23 and 23A

NL-10-042 Docket 50-247 Attachment 1 Page 24 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

valves adjacent to these trays. directly above electrical 227/HCV-142; cabinets in the primary corridor Combustibles in this large zone are widely distributed, Instrument area of the zone. presenting minimal potential for significant involvement in Buses 23 and response to initiation by any single ignition source in the 23A Secondary combustibles in the zone area are dispersed, and substantial quantities of these The smoke detection system in the zone provides combustibles are not proximate assurance of early warning of a fire condition of any to the ignition sources in the significance, enabling fire brigade response prior to zone significant fire development F / 22A Cables The zone contains a negligible The ignition sources, defined Redundant SSD trains are not located in the zone, but associated quantity of fixed combustibles as electrical cabinets, do not damage to cables associated with LCV-1 12C requires an with Charging present the potential for ignition OMA to align an alternate Charging suction source, outside suction valve of secondary combustibles, this zone LCV-1 12C given the insignificant content and LCV- of the zone No fire detection is installed in the zone, but given the 112B insignificant ignition sources, and the absence of significant combustibles, the occurrence of a fire of significance in the zone is a low-credibility event

NL-1 0-042 Docket 50-247 Attachment 1 Page 25 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

/ Zone Combustibles F / 27A Cables The dominant combustible is The ignition sources consist of Combustibles other than cables in trays are minimal associated cable in overhead trays. The cable tray runs and a throughout the zone. The credible fire scenario would with Charging cables of concern are located in significant number of motor involve transient combustibles, which are tightly controlled suction valve or adjacent to the trays. control centers, located in the to "Level 2" limits per administrative control procedure.

LCV-1 12C southeast corner of the zone.

and LCV- Cable trays are in overhead Combustibles in this large zone are widely distributed, 112B proximity to one or more presenting minimal potential for significant involvement in MCCs. response to initiation by any single ignition source in the zone The smoke detection system provides assurance of early warning of a fire condition, enabling brigade response prior to significant fire development F / 33A Cables The dominant combustible is The ignition sources consist of While not contained within a rated barrier, the effects of a associated cable in overhead trays. The the cable tray runs themselves, fire in this zone can be expected to be largely confined to with Charging cables of concern are located in as well as a significant number the zone, which is enclosed by a partial-height (10 ft) makeup or adjacent to the trays of motor control centers. concrete block wall. In the event of a significant fire in the valves Cable trays containing the zone, smoke migration through the open ceiling of the 227/HCV-142 cables of concern are in zone to adjacent Fire Zone 27A, the adjacent main corridor overhead proximity to one or area, can be expected to be detected by the smoke more MCCs. detection system in Zone 27A.

NL-1 0-042 Docket 50-247 Attachment 1 Page 26 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

/Zone Combustibles H / 70A, Charging Significant fixed combustibles are Cables for valves 204A and RCP lube oil isnot considered to present a credible 75A, 76A, makeup cables in trays located inthe 204B and safe-shutdown hazard, in that the RCPs are provided with a lube oil 77A, 87A valves 204A annulus area proximate to the instrumentation are located collection system, ensuring that any leakage cannot and 204B and electrical penetrations in Fire within zones containing RCPs contact hot surfaces and present an ignition threat associated Zone 75A, and RCP lubricating and the associated lube oil.

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

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 27 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

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

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

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

23A concern. Other combustibles include cables in trays.

NL-10-042 Docket 50-247 Attachment 1 Page 28 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

112B/112C J / 45A Cables Cable trays are the dominant Ignition sources include The principal fuel source and ignition source exposure to associated combustibles in the zone, and electrical cabinets, MCCs, and the zone is the Main Boiler Feedwater pump oil equipment with: 480V cables of concern are located in motors distributed throughout located immediately beneath this zone, under a partially-Buses 5A and or in proximity to these trays the zone. Cables of concern open floor deck. The oil storage/handling area below is 6A; are routed through the provided with an automatic Aqueous Film Forming Foam IBUS23/IBUS overhead area of the zone. system.

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

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

406A; LCV- loading concern. Other 112B/112C combustibles include cables in trays.

NL-1 0-042 Docket 50-247 Attachment 1 Page 29 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

6A more of the identified ignition sources.

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

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

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

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

NL-10-042 Docket 50-247 Attachment 1 Page 30 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 31 of 105 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown Cables/Components, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area SSD Feature Proximity to Significant Fixed Proximity to Ignition Sources Comments

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

NL-10-042 Docket 50-247 Attachment 1 Page 32 of 105 RAI-07.1 Provide an analysis or technical justification that demonstrates that the ability to detect a fire is sufficient to provide notification of a postulated event before damage to the redundant trains occurs or provide an analysis or technical justification to evaluate scenarios where the redundant components are damaged before a fire has been reported.

RESPONSE

No credit has been taken for immediate and proactive OMA response by plant operators upon the receipt of a fire detection alarm in any of the identified fire areas or fire zones. Rather, the OMA responses are initiated upon the detection of operating abnormalities or failures caused by the postulated fire.

The evaluation of the feasibility of the credited OMAs for the fire areas addressed herein was conducted using the presumption that fire damage would occur to the cables/components of concern, and that symptomatic response to mitigate these failures would be required. While a fire was postulated and announced to plant operators at the outset of event simulations, no attempt was made to credit preventive actions; i.e., proactive actions that could be taken immediately upon receipt of a fire alarm. Exercises were conducted using the plant simulator, with a fire condition announced at the outset or a spontaneous reactor trip (caused by the fire) was presented at the outset, followed by the failure of discrete components that are subject to impairment due to fire damage to cables or components resulting from a fire in the area of concern. The component failures were selected from the Appendix R Safe-Shutdown Analysis list of component failures for a fire in the selected fire area. Using this evaluation approach, the operating team was observed and as the discrete failures were discovered by the operators the associated time values were recorded.

For purposes of the simulator exercises, the plant was assumed to be in Mode 1 (100% power) with no equipment out of service (except for that potentially failed by the postulated fire). The simulator model was modified to impair certain components prior to starting the exercise. The impairment flags in the simulator model database were applied so as to create no cues or advance warning to the operators that the affected components would be impaired or unavailable. The time values discussed in the response to RAI-08.1 reflect the diagnosis times developed through these exercises.

Conversely, the simulated performance of the OMAs, which by definition are actions outside the CCR, was accomplished in a separate set of evolutions, by dispatching operator(s) from the CCR (or where an operator is normally stationed in the Radiologically Controlled Area, dispatched from that location via radio). The operator(s) were dispatched to the OMA locations as directed by procedures, and the total time recorded was the time to travel from the dispatch location, perform the OMA, and communicate to the CCR that the action was completed.

The total of simulator-based Time to Diagnose was added to the field-based time to travel to the OMA location, complete the OMA, confirm the action, and notify the CCR of completion.

Note that the time values shown in the Request for Exemption dated March 6, 2009 and in the Revision to the Request for Exemption dated October 1, 2009 were only those associated with the Actual Time to Complete the OMA (travel time + performance time +

confirmation/notification time), as shown in Tables RAI-08.1-1 through RAI-08.1-7.

NL-10-042 Docket 50-247 Attachment 1 Page 33 of 105 Notwithstanding the reasonableness of expectation that a fire in the affected area would be detected and annunciated in the CCR well in advance of the occurrence of substantive cable/component damage, the OMA evaluation approach in all cases presumed that the postulated fire damage did in fact occur, and therefore the implementation of the OMA was required in all cases. No credit was taken for anticipation of the various component failures as the result of early warning fire detection alarms. Instead, the discrete failures were imposed by the simulator on the operating team and they were challenged to diagnose the failure, determine the appropriate response, and dispatch operators as applicable to perform OMAs in the field to mitigate the equipment maloperation.

RAI-08.1 For each of the OMAs contained in the requests, describe the circumstances and criteria needed to enter the OMA procedure and identify:

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

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

• obtaining any necessary equipment, procedures, or other devices,

• traveling to the necessary location,

" implementing the action, and

• confirming that the action has had its desired effect.

RESPONSE

The actions required to implement the subject OMAs are detailed in Tables 2 through 8 of to Entergy letter NL-09-031, dated March 6, 2009 and Entergy letter NL-09-116, dated October 1, 2009. The details of the time required to diagnose each of the failure scenarios requiring the use of the subject OMAs, as well as the time required to implement the OMAs, are herein provided in Tables RAI-08.1-1 through RAI-08.1-7. For each OMA sequence, the Required Time to Complete and the Total Time to Complete are provided, along with the Resultant Margin available for each OMA.

Note that in revisiting the timed validation data sets in developing the response to RAI-08.1, it was determined that in several cases the OMA-specific timing data as presented in the Request for Exemption dated March 6, 2009 and in the Revision dated October 1, 2009, required revision to accurately reflect the components of the timing elements and the overall completion times. In addition, the OMA descriptive text has been clarified in several cases from that shown in the referenced submittals. None of these changes impact Entergy's conclusions relative to the feasibility or reliability of the subject OMAs.

Also shown in Tables RAI-08.1-1 through RAI-08.1-7 are the fire area and fire zone(s) that contain cables and/or components presenting the fire vulnerability that may initiate the need to implement the credited OMA, along with the fire area and fire zone(s) in which the OMA is

NL-10-042 Docket 50-247 Attachment 1 Page 34 of 105 performed. For the few cases in which reentry to the fire-affected area is credited, the constraints of such reentry are described.

RAI-08.2 Provide a justification that demonstrates that the proposed OMAs are feasible as well as a technical justification for the times discussed in response to RAI-08.1 above.

RESPONSE

The credited OMAs have been demonstrated to be feasible through timed evolutions performed using a combination of simulator drills and dispatch of operators to (simulate) performance of the OMAs within the physical plant. In all cases, as shown by Tables RAI-08.1-1 through RAI-08.1-7, the OMAs are completed, with available margin, within the time constraints established by the supporting safe-shutdown thermal-hydraulic analyses.

The time values presented in Tables RAI-08.1-1 through RAI-08.1-7 have been shown to be consistently achievable, and the Operations resource demand to support any one of the fire area scenarios is a fraction of the 7-operator complement available to support a post-fire safe-shutdown scenario. Note that the time to diagnose and the resultant total time to complete OMAs were not shown in the Request for Exemption dated March 6, 2009 or in the Revision to the Request for Exemption dated October 1, 2009. Tables RAI-08.1-1 through RAI-080.1-7 expand on the timing information presented in the March 6, 2009 and October 1, 2009 submittals.

The accomplishment of the small OMA subsets for any of the III.G.2 fire areas for which exemption is sought is fully bounded by the limiting III.G.3 fire scenario, e.g., a Control Building fire. In the case of a III.G.3 scenario, involving CCR evacuation, the guidance of procedure 2-AOP-SSD-1 (Control Room Inaccessibility Safe-Shutdown Control) applies, and the ability to accomplish the key time-sensitive action set in 2-AOP-SSD-1 has been demonstrated repeatedly.

NL-1 0-042 Docket 50-247 Attachment 1 Page 35 of 105 TABLE RAI-08.1-1 FIRE AREA C CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete Complete and Fire Area/Zone 5 Comments Complete' for OMA 2 OMA 3 Resultant Margin4 OMA Performance (P)

Fire Area/Zone6 Implement FR-H.1 if N/A N/A NA - no OMAs N/A 1:Area C, Zone 23 Action performed from CCR, and not necessary to establish required an OMA, but described for alternate secondary heat (a) P: N/A completeness sink Operate Steam Generator WITHDRAWN Atmospheric (SGADV) Dump Valve(s) See Sersosresponse tooRI0.

RAI-02.1 (a) The Required Time to Complete for this potential action was shown in the previous submittals as 34 minutes. However, the 34-minute limitation refers to the Steam Generator (SG) boil-dry time in the absence of AFW flow to the SGs, and represents the time available to restore AFW flow. In the unlikely event that the EOP 2-FR-H.1 methodology would be necessary, the time to boil dry the SGs has no direct applicability, as actions within 2-FR-H.1 are driven to be implemented at substantially greater remaining SG inventories, and the boil-dry time does not have direct applicability given the multiple methods that 2-FR-H.1 provides for reactor coolant heat removal alternatives. The reference to "34 minutes" has therefore been deleted in this submittal.

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

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

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

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

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

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

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 36 of 105 TABLE RAI-08.1-1 FIRE AREA C CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete Complete and Fire Area/Zone 5 Comments Complete' for OMA2 OMA 3 Resultant Margin" OMA Performance Fire Area/Zone6 (P)

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

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

NL-10-042 Docket 50-247 Attachment 1 Page 37 of 105 TABLE RAI-08.1-2 FIRE AREA F CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete OMA Complete and Fire Area/Zone Comments Complete for OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Operate SGADVs - - - WITHDRAWN See response to RAI-02.1 Align Charging pump 75 m 14 m 14 m TTC: 28 m I: Area F, Zone 27 or 33 Targets: Cables associated with valve makeup path to RCS (b) Margin: 47 m; P: Area A, Zone 1A 227 63% 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.

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

NL-10-042 Docket 50-247 Attachment 1 Page 38 of 105 TABLE RAI-08.1-2 FIRE AREA F CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete and Fire Area/Zone Comments Complete for OMA Complete OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Align Charging pump 75 m 14 m 18 m TTC: 32 m I: Area F, Zone 6, 7A, or Targets: cables associated with suction source to Refueling 22A valves LCV-112B, LCV-112C Water Storage Tank (c) Margin: 43 m; (RWST) 57% P: Area F, Zone 6; Area Reentry to Area F to implement OMA F, Zone 22A is following extinguishment of and securing from fire, >1 hour from start of event Travel time conservatively taken to be 10 minutes, from 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. Note that time to diagnose the need for this OMA is measured from T=0, and not from the time of fire area reentry, at 60 minutes into the scenario.

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 39 of 105 TABLE RAI-08.1-2 FIRE AREA F CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need AComltule to Complete and Fire Area/Zone Comments Complete for OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Transfer Instrument Buses 30 m 5.5 m 2m TTC: 7.5 m I: Area F, Zone 6 or 7A Targets: Cables associated with 1B23, 23 and 23A to alternate IB23A power Margin: 22.5 m; P: Area A, Zone 11 75%

NL-10-042 Docket 50-247 Attachment 1 Page 40 of 105 TABLE RAI-08.1-3 FIRE AREA H CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete and Fire Area/Zone Comments Complete for OMA Resultant Margin OMA Performance (P)

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

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

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

NL-10-042 Docket 50-247 Attachment 1 Page 41 of 105 TABLE RAI-08.1-3 FIRE AREA H OMA Initiator (I)

Fire Area/Zone Comments OMA Performance (P)

Fire Area/Zone Activate/enable Alternate <1 m 13 m: ASSS TTC: I: Area H, Zone 70A, Loss of multiple channels of some key Safe Shutdown System (instruments pneumatic 75A, 76A, 77A, 87A instrumentation is assumed to occur at (ASSS) pneumatic assumed failed 13 m (ASSS T=O, and therefore the time-to-channels in pneumatics) instruments (Steam at T=0) service P: Area A, Zone 1A; diagnose is effectively considered to Generator level, Pressurizer 23 m (Th, Tc, Area J, Zone 270, 360; be <1 minute pressure and level) at Fan 10 m: ASSS source range) Area F, Zone 59A House local control panel. source range, Deployment of ASSS instruments Also enable ASSS source- Th, Tc channels Margin: involves parallel actions by two.

range channel and Loop 21 in service operators. PAB operator aligns ASSS and 22 hot (Th) and cold leg 21 m (ASSS pneumatic channel isolation valves (Tc) temperature channels pneumatics); 62% and manipulations necessary to energize ASSS source-range drawer; 11 m (Th, Tc, conventional operator enables ASSS (e) source range); 32% power supply to power up ASSS source-range channel and Loop 21/22 Th and Tc channels, located in Area F, Zone 59A Time to close supply breaker on ASSS switchgear 12FD3 to energize ASSS source range, Th and Tc channels conservatively taken to be 10 min, equivalent to the time required for the more complex breaker operation OMA taken for the Fire Area J scenario. In parallel with breaker closure, PAB operator installs fuses and closes knife switch to energize ASSS channels locally.

NL-10-042 Docket 50-247 Attachment 1 Page 42 of 105 TABLE RAI-08.1-3 FIRE AREA H CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required Time Actual to Actue TCmp e to Complete and Fire Area/Zone Comments Required OMAoTime to DiagnoSe Need Complete OMA Resultant Margin OMA Performance (P)

Fire Area/Zone (e) The description of this OMA has been revised to more completely describe the deployment of the ASSS instrument set, which includes not only the referenced pneumatic level and pressure channels, but also five electronic instrument channels, including RCS Loops 21 and 22 hot and cold leg temperatures, and source-range neutron monitoring. As now described in Table RAI-08.1-3, the most demanding time limit for placing any of these channels in service is the time required to place SG level channels in service, in support of the required restoration of AFW to the Steam Generators within 34 minutes to preclude SG boil-dry conditions being reached. Therefore, the Total Time to Complete is conservatively revised to 34 minutes, whereas the referenced submittals showed a nominal value of "30+" minutes for the Actual Time to Complete.

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

NL-10-042 Docket 50-247 Attachment 1 Page 43 of 105 TABLE RAI-08.1-4 FIRE AREA J CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (C)

Required OMA Time to Diagnose Need Complete OMA Complete and Fire Area/Zone Comments Complete for OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Trip breakers 52/5A and 52- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 0 10 m TTC: 10 m I: Area J, Zone 17, 19, Targets: Cables associated with Bus SAC on Bus 5A and 52/6A (Offsite power 39A, 43A, 45A, 46A, 6A supply breakers and 52/TAO at Bus 6A and assumed Margin: 50 m; 47A, or 50A remove control power fuses unavailable at 83% Actual time to complete in this case is T=0) P: Area A, Zone 14 based on equivalent breaker tripping actions in the 480V Switchgear Room that have been previously validated Transfer Instrument Buses 30 m 5.5 m 2m TTC: 7.5 m 1:Area J, Zone 24, 25, or Targets: Cables associated with 1B23, 23 and 23A to emergency 270 IB23A power source Margin: 22.5 m; 75% P: Area A, Zone 11 Align Charging pump 75 m 14 m 18 m TTC: 32 m I: Area J, Zone 19, 39A, Targets: Cables associated with suction source to RWST (f) Margin: 43 m; 43A, 45A, 46A, or 50A valves LCV-1 12B, LCV-1 12C 57% P: Area F, Zone 6; Area Travel time conservatively taken to be F, Zone 22A 10 minutes, from CCR to PAB Operate 22 AFW Pump.flow 34 m 4.5 m 17 m TTC: 11.5 m I: Area J, Zone 19, 39A, Targets: Cables associated with AFW control valves to align AFW 43A, 45A, or 50A flow control valves FCV-405A-D flow to selected Steam Margin: 22.5 m; Generator(s) 66% P: Area C, Zone 23 (f) The Total Time to Complete is conservatively revised to 18 minutes, whereas the referenced submittals showed a value of 8 minutes for the Actual Time to Complete

NL-10-042 Docket 50-247 Attachment 1 Page 44 of 105 TABLE RAI-08.1-5 FIRE AREA K t.RI=IlITFIl III E. 9 API=RATAR MAN.IIAI A(:TIAN.*

OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need to Complete and Fire Area/Zone Comments R dmeto D os Nee Complete OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Transfer 21 AFW Pump to 34 m 4.5 m 17 m TTC: 21.5 m I: Fire Area K, Zone 60A Targets: Cables associated with 21 ASSS power source or 65A AFW pump normal power (g) Margin: 12.5 m; 37% P: Fire Area C, Zone 23; Two discrete operations are performed Fire Area J, Zones 360 by an operator dispatched to Fire Area and 361 C and a second operator dispatched to ASSS switchgear 12FD3 in Fire Area J Operate SGADVs as WITHDRAWN required to control secondary system cooldown See response to RAI-02.I Open 21 AFW Pump 34 m 4.5 m 5 m TTC: 9.5 m 1: Fire Area K, Zone 60A Target: Cable associated with valve recirculation bypass valve or 65A FCV-1121 Margin: 24.5 m; 72% P: Fire Area C, Zone 23 Operate 21 AFW Pump flow 34 m 4.5 m 7m TTC: 11.5 m 1: Fire Area K, Zone 60A Targets : Cables associated with FCV-control valves to control or 65A 406A and FCV-406B AFW flow to Steam Margin: 22.5 m; Generators 21 & 22 66% P: Fire Area C, Zone 23 (g) The Total Time to Complete is revised to 17 minutes, whereas the referenced submittals showed a value of 5 minutes for the Actual Time to Complete

NL-10-042 Docket 50-247 Attachment 1 Page 45 of 105 TABLE RAI-08.1-6 FIRE AREA P CREDITED IllhG.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required Time Actual to Actus TCmpe to Complete and Fire Area/Zone Comments Required OMAoTime to DiagnoSe Need Complete OMA Resultant Margin OMA Performance (P)

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

>48%

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

NL-10-042 Docket 50-247 Attachment 1 Page 46 of 105 TABLE RAI-08.1-7 FIRE AREA YD CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time to Actual Time to Total Time to Initiator (I)

Required OMA Time to Diagnose Need Complete OMA Complete and Fire Area/Zone Comments Complete for OMA Resultant Margin OMA Performance (P)

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 47 of 105 RAI-09.1 Provide information that demonstrates that the actions are reliable including a justification that various uncertainties are accounted for in the time margins and that the margins are sufficient to ensure that they provide adequate time to cover potential variations in plant conditions and human performance. If a factor of safety or diagnosis time has been included in the stated times to complete the actions, provide an explanation for how it has been incorporated into the timelines. If not, justify why the stated times are sufficient to assure safety.

RESPONSE

The demonstration of the subject OMAs was accomplished via a two-phased effort, involving fire scenario modeling, failure diagnosis, and operator dispatch to perform the necessary OMAs using the plant simulator. This environment provided a realistic means of assessing operator response to the reported fire and response to the selected fire area-specific equipment failures that were flagged in the simulator model, and the assessment of the time necessary to reach the point at which operators were dispatched to perform the necessary mitigating OMAs.

The subject OMAs were separately field-validated, with operators dispatched from the CCR (or other locations, as applicable to normal plant operating stations). The time to travel to the OMA location was recorded, as was the time to complete the (simulated) action. In each case, the operator progressed through the simulation of the action, including appropriate time delays consistent with that required to actually implement the action. For example, time was allocated for the manual opening or closing of designated valves, given the approximate number of handwheel turns necessary to achieve full travel of the valve.

Note that the "diagnosis" times as presented in Tables RAI-08.1-1 through RAI-08.1-7 are based on actual operator response in simulator exercises as described in the response to RAI-07.1. Arbitrary estimates of time required for failure diagnosis were not used, nor were arbitrary factors of safety applied. The fact that the aggregate time to complete each OMA, as shown on Tables RAI-08.1-1 through RAI-08.1-7, is consistently bounded by the analytically-based "Required time to complete," with margin, is considered to adequately bound the range of uncertainties that could reasonably be postulated.

None of the OMA operating locations are difficult to access, and the required operations are simple manual actions that do not require any special tools, processes, or unique personal capabilities. The OMAs involve:

• Manual operation of valves (manual valves, as well as operation of AOVs and MOVs via handwheels or installed jacking devices)

• Local manual trip or closure of circuit breakers

" Manual control of turbine-driven AFW pump None of the OMAs involve complex instruction sets, the installation or removal of jumpers, the installation or removal of fuses, or any actions requiring uniquely specialized knowledge or fine motor skills. The OMA task assignments are within the capability of any licensed operator or nuclear plant operator, as applicable to his/her responsibility set. As such, the challenge presented for completion of these basic tasks within the prescribed time limits is within the capability of the standard IP2 operating crew. Uncertainties that would be introduced by smoke

NL-1 0-042 Docket 50-247 Attachment 1 Page 48 of 105 obscuration or fire suppression activities are also expected to be minimal, given the minimal fire challenge in the affected plant areas, and the nature of the combustibles.

The data presented in Tables RAI-08.1-1 through RAI-08.1-7 include the time required for diagnosis of the failure that initiates the need for the respective OMAs, the time to accomplish the OMA (dispatch, travel to the OMA location, perform the OMA, and confirm), and the resultant remaining time margin. The data originally provided in the Request for Exemption dated March 6, 2009 and in the Revision to the Request for Exemption dated October 1, 2009, only included the time-to-perform the OMAs, hence the available time margin could not be readily discerned from the data originally provided.

RAI-10.1 State whether operators are procedurally directed to don SCBAs [Self Contained Breathing Apparatus] and whether the time needed to don the SCBAs was included in the analysis of the time available to perform the action.

RESPONSE

The post-fire safe-shutdown procedures do not include explicit instructions for operators to don SCBAs if post-fire entry into affected plant areas is required. However, plant operator qualifications include the use of SCBAs for purposes of fire brigade response, licensed operator

qualification, and radiation worker qualification. All operators retain at least one of these SCBA qualifications. Successful SCBA qualification, per Entergy Instructor Lesson Plan IOLP-SAF-SCB01 (Self Contained Breathing Apparatus), requires an operator to demonstrate that they can don a SCBA within two minutes. As such, any operator that may be dispatched to perform local OMAs in fire-affected areas is prepared by training to don an SCBA, as appropriate, for entry into the affected plant area. Supplies of SCBAs for use by operators not dedicated to the fire brigade are located in the CCR and at a number of strategic locations throughout the plant.

These SCBAs are dedicated for operator use, and are separate and distinct from the SCBAs designated and staged for use only by the fire brigade. There is a sufficient number of SCBAs available at all times to equip all operators that may need to be dispatched from the CCR to perform OMAs. Supplies of spare air bottles are also available at several plant locations. The inventory of SCBAs and spare bottles is verified monthly.

Given the relatively minimal OMAs that are required for response to fires in the III.G.2 areas discussed herein, the need for reentry to the fire-affected area typically involves only a small number of operators. The maintained supplies of SCBAs in the CCR and other strategic locations provides assurance that operators will not be impeded from performing necessary post-fire OMAs as the result of smoke or toxic gas conditions resulting from the postulated fire.

Based on the ready availability of an adequate supply of SCBAs to operators who may be dispatched to perform OMAs, and also recognizing that none of the OMA travel paths or access locations present unusually difficult access conditions (i.e., that would be exacerbated significantly by wearing an SCBA), the field evaluations of OMA performance did not include the use of SCBAs.

NL-1 0-042 Docket 50-247 Attachment 1 Page 49 of 105 RAI-11.1 Provide critical details or assumptions of the analysis that demonstrates that the required safe shut down equipment or component located within the area is maintained free of fire damage and remains accessible and operable following the fire event.

RESPONSE

The equipment to be operated via OMA following fire area reentry is as follows:

Fire Area C Turbine-driven 22 AFW Pump and flow control valves FCV-405A throuah D:

The fire challenge represented by Fire Area C, given the minimal ignition sources and insignificant fuel load, is insufficient to present a credible threat to the mechanical functionality of the turbine-driven pump and the flow control valves, when operated manually. In the event of a credible fire scenario in this area, manual fire suppression activity would be minimal and common-mode component damage within the area resulting from suppressant discharge would not be expected. Consistent with the conclusions of the SER dated October 16, 1984 that granted an exemption from the requirements of Paragraph III.G.2 for this area, reasonable assurance has been established that 22 AFW Pump and a sufficient complement of the associated flow control valves would remain functional following a credible fire event in this

'area, Fire Area F

• Motor-operated valve LCV-1 12C: This valve is required to be manually closed to support alignment of Charging pump suction to the alternate source from the Refueling Water Storage Tank (RWST). The combustible loading in the zone (Fire Zone 22A) containing this valve, as well as the adjacent zones, is insignificant, and Fire Zone 22A is devoid of any ignition sources and does not present a substantive fire challenge to the integrity of the valve. Moreover, motor-operated valve LCV-1 12C has been evaluated for potential vulnerability to the fire-induced failure mode postulated by Information Notice 92-18 (Potential for Loss of Remote Shutdown Capability During a Control Room Fire), and the associated "weak link" analysis confirms that despite postulation of limit and torque switch failures as considered by Information Notice 92-18, the valve actuator is incapable of causing damage that would render LCV-1 12C inoperable by hand following the fire event. There is adequate assurance that LCV-1 12C will remain manually operable, following the credible fire scenario that may be encountered in Fire Zone 22A or any of the adjoining zones.

• Valve 288: Valve 288 is a manually-operated valve located in Fire Zone 6, which contains 22 Charging Pump and valve LCV-1 12B. This valve is required to be opened to support alignment of Charging pump suction to the alternate source (RWST), in the event that cable failures have rendered LCV-1 12B inoperable. The combustible load in this zone is low, and the credible ignition source is the 22 Charging Pump motor. Valves 288 and LCV-1 12B are located at the south end of this zone adjacent to the doorway, and are not immediately adjacent to the pump motor. Given the fire detection features

NL-10-042 Docket 50-247 Attachment 1 Page 50 of 105 in the room and the location of valve 288, there is reasonable assurance that this mechanical-only valve will remain operable following post-fire reentry. It should also be recognized that for a fire in Fire Zone 6 involving 22 Charging Pump, fire damage can be expected to be confined to the zone of origin, despite the lack of a door enclosing the room fully at the south end.

As the corridors of Fire Area F at El. 80' and 98' themselves are large and generally free of credible combustibles (with the exception of cables in overhead trays), there is reasonable assurance that access to valves LCV-1 12C and 288, at 60 minutes following the start of the fire event, will remain sufficiently unencumbered, with the conditional use of SCBA by the operator(s), in the event that smoke venting throughout the area is incomplete at the time access to the area is needed.

RAI-11.2 Provide a technical justification for why the assumed 60-minute reentry period is appropriate and an explanation for what is assumed to be included in this time.

RESPONSE

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

The same guidance relative to reentry to the affected fire area has also been applied by Entergy in consideration of the credible fire scenarios in Fire Area F, as discussed in to Entergy letter NL-09-031, dated March 6, 2009 and Entergy letter NL-09-116, dated October 1, 2009.

The low combustible loading and minimal ignition sources in the fire zones of concern (Fire Zones 6 and 22A) within Fire Area F provide reasonable assurance that reentry to the area after one hour following the postulated fire provides ample time for securing from the fire condition and allowing operators unencumbered access to the area. Note that none of the credited OMAs is reliant upon reentry to an affected fire area within one hour of initiation of the postulated fire event. Moreover, for those actions requiring reentry to the affected fire area after one hour has elapsed, the demonstrated time necessary to perform these actions is approximately 50% or less of the time available to complete the action. The affected OMAs are in Fire Areas C and F, and are described in Tables RAI-08.1-1 and RAI-08.1-2, respectively.

NL-1 0-042 Docket 50-247 Attachment 1 Page 51 of 105 TABLES RAI-GEN-1 through RAI-GEN-27 Characteristics of Fire Areas

NL-10-042 Docket 50-247 Attachment 1 Page 52 of 105 TABLE RAI-GEN-1 CHARACTERISTICS OF FIRE AREA C / FIRE ZONE 23 Fire Area/ Description C / Auxiliary Boiler Feed Pump Room, Elevation 18'-6" of the Auxiliary Feed Pump Building Fire Zone / Description 23 / Auxiliary Boiler..Feed Pump (ABFP) Room, Elevation 18'-6" Fire Zone Dimensions 1210 sq ft w/ 14 ft Ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions Yes - SERs dated Oct 16,1984 and March 4,1987 Fixed Combustible Materials Cable, lube oil, electrical panels Cable Insulation Quantity in BTU 3.256E+07 BTU Total Fixed Combustible Loading / Fire Severity 32,170 BTU/sq ft / 24 minutes Transient Combustible Materials Trash, lube oil, paint Transient Combustible Loading / Fire Severity 1,433 BTU/sq ft / 1 minute Combustible Loading - Rating Low (Fixed + Transient loads = < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2-Motors & Pumps, 4-Electrical Cabinets Detection Type / Coverage Ionization / Area Wide Code of Record NFPA 72D-1 975

NL-10-042 Docket 50-247 Attachment 1 Page 53 of 105 TABLE RAI-GEN-1 CHARACTERISTICS OF FIRE AREA C / FIRE ZONE 23 Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type C02 extinguishers Adjacent Zone Manual Suppression 2 hydrants in adjacent yard Non-rated Fire Protection Assemblies North wall - Approved Exemption Radiant Energy Shield installed between 21 AFW Pump and 23 AFW Pump Additional FP Features 23 AFW.Pump power cables wrapped with 30 min Hemyc barrier Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) Hemyc Wrap Fire Protective Systems (IP-RPT-04-00188)

Pneumatic Supply System Potential Fire Vulnerability in ABFP Building (IP-RPT-04-00187)

NL-1 0-042 Docket 50-247 Attachment 1 Page 54 of 105 TABLE RAI-GEN-2 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 5A Fire Area / Description F / Primary Auxiliary Building and Fan House Fire Zone I Description 5A / Sampling Room, Elevation 80'-0" Fire Zone Dimensions 150 sq ft w/14 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Hydrogen Cable Insulation Quantity in BTU 1.978E+07 BTU Total Fixed Combustible Loading / Fire Severity 132,500 BTU/sq ft / 99 minutes Transient Combustible Materials Trash, Painting, Rad boundaries Transient Combustible Loading / Fire Severity 10,870 BTU/sq ft / 8 minutes Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2 - Electrical Cabinets Detection Type / Coverage None Code of Record NA

NL-10-042 Docket 50-247 Attachment 1 Page 55 of 105 TABLE RAI-GEN-2 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 5A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02 and 150 lb DC (Dry Chemical) extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) Fire Separation Between Fire Zones 30A, 5A, 7A, and 23A (IP-RPT-04-00227)

NL-10-042 Docket 50-247 Attachment 1 Page 56 of 105 TABLE RAI-GEN-3 CHARACTERISTICS OF FIRE AREA F I FIRE ZONE 6 Fire Area / Description F /Primary Auxiliary Building and Fan House Fire Zone Description 6 / 22 Charging Pump Room, Elevation 80'-0" Fire Zone Dimensions 282 sq ft w/ 15'-6" ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions Yes - SER letter dated March 4,1987 Fixed Combustible Materials Lube oil, Plastic Cable Insulation Quantity in BTU None Total Fixed Combustible Loading / Fire Severity 24,201 BTU/sq ft / 18 minutes Transient Combustible Materials Trash, Lube oil, Painting, Rad Boundaries Transient Combustible Loading Fire Severity 26,983 BTU/sq ft / 20 minute Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources 1 Motor & Pump Detection Type / Coverage Ionization smoke detection / Area Wide Code of Record NFPA 72D-1975

NL-10-042 Docket 50-247 Attachment 1 Page 57 of 105 TABLE RAI-GEN-3 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 6 Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression NA Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-042 Docket 50-247 Attachment I Page 58 of 105 TABLE RAI-GEN-4 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 7A Fire Area / Description F / Primary Auxiliary Building and Fan House Fire Zone / Description 7A / Corridor, Elevation 80'-0" Fire Zone Dimensions 6000 sq ft w/ 16 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R Ill.G.2 Exemptions Yes - SER letter dated October 16, 1984 Fixed Combustible Materials Cable, Wood, Anti-C's, Plastic, Welding Lead, Cellulose, Control Cabinet & Panel Cable Insulation Quantity in BTU 3.615E+08 BTU Total Fixed Combustible Loading / Fire Severity 72,439 BTU/sq ft / 54 minutes Transient Combustible Materials Trash, Flammable Liquid Cabinets, Plastic, Cellulose, Rad Boundaries Transient Combustible Loading / Fire Severity 4,793 BTU/sq ft / 4 minute Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable Run, Junction boxes, 26-Electrical Cabinets Detection Type / Coverage Ionization Smoke Detection / Area Wide Code of Record NFPA 72D-1 975

NL-10-042 Docket 50-247 Attachment 1 Page 59 of 105 TABLE RAI-GEN-4 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 7A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (water), C02 &150 lb DC extinguishers Adjacent Zone Manual Suppression None The power cable from transfer switch EDF-9 to 23 CCW Pump motor is wrapped with a 30 minute Hemyc barrier A partial separation barrier constructed of noncombustible materials and extending beyond the Additional FP Features width and height of the transfer switch has been installed behind transfer switch EDF-9 A 11/2 hour rated roll up fire door is installed at the entrance to Fire Zone 5 (21 Charging Pump) from Fire Zone 7A, the open transom area above the roll up door is sealed, and a 11/2hour rated damper is provided in the ventilation duct penetration Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Evaluation of Fire Separation of the Piping Bay and Tunnel (FIRE ZONE 30A) from the Adjacent Primary Auxiliary Building Fire Area F Fire Zones 5A, 7A AND 23A (IP-RPT-04-00227)

Other Evaluations (i.e., 86-10) Evaluation of Fire Separation of the Primary Auxiliary Building Corridor (FIRE ZONE 7A) from the Adjacent IPI-IP2 Passageway Fire Zone 130 (IP-RPT-04-00228)

Evaluation of HEMYC Wrap Fire Protective Systems (IP-RPT-04-00188)

NL-10-042 Docket 50-247 Attachment 1 Page 60 of 105 TABLE RAI-GEN-5 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 22A Fire Area / Description F / Primary Auxiliary Building and Fan House Fire Zone / Description 22A / Valve Corridor, Elevation 98'-0" Fire Zone Dimensions 115 sq ft w/ 14 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R IIl.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials None Cable Insulation Quantity in BTU None Total Fixed Combustible Loading / Fire Severity NA Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources 2-Electrical Cabinets Detection Type / Coverage None Code of Record NA

NL-10-042 Docket 50-247 Attachment 1 Page 61 of 105 TABLE RAI-GEN-5 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 22A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (water) and C02 extinguishers Additional FP Features None Administrative Controls Transient Combustibles Control - Level 2 Area Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 62 of 105 TABLE RAI-GEN-6 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 27A Fire Area I Description F / Primary Auxiliary Building and Fan House Fire Zone / Description 27A / Corridor, Elevation 98'-0" Fire Zone Dimensions 5,450 sq ft w/ 15 ft ceiling a) 3-hr Barrier:. No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Vinyl covers, Control Cabinets and Panels, Plastic, Office Cable Insulation Quantity in BTU 2.342E+08BTU Total Fixed Combustible Loading I Fire Severity 53,244 BTU/sq ft / 40 minutes Transient Combustible Materials Trash, Rubber, Air Monitor, Painting, Rad Barriers Transient Combustible Loading I Fire Severity 68,683 BTU/sq ft / 52 minutes Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000- 200,000 BTU/sq ft)

.Ignition Sources Cable run, Junction Boxes, 2-Transformers (dry), 36-MCC vertical panels, 34-Electrical Cabinets Detection Type / Coverage Ionization / Area Wide Code of Record NFPA 72D-1 975

NL- 10-042 Docket 50-247 Attachment 1 Page 63 of 105 TABLE RAi-GEN-6 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 27A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (water) and C02 extinguishers Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 64 of 105 TABLE RAI-GEN-7 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 33A Fire Area / Description F / Primary Auxiliary Building and Fan House Fire Zone / Description 33A / MCC 26AA & MCC 26BB Room, Elevation 98'-0" Fire Zone Dimensions 1,122 sq ft w/ no ceiling, open to FZ-27A a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, electrical panel Cable Insulation Quantity in BTU 9.553E+07 BTU Total Fixed Combustible Loading / Fire Severity 141,300 BTU/sq ft / 106 minutes Transient Combustible Materials Trash, Painting, Rad Barriers Transient Combustible Loading / Fire Severity 1,245 BTU/sq ft / 1 minute Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000- 200,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 27-MCC panels, 12-Electrical cabinets, 2-Transformers (dry)

Detection Type / Coverage None Code of Record NA

NL-10-042 Docket 50-247 Attachment 1 Page 65 of 105 TABLE RAI-GEN-7 CHARACTERISTICS OF FIRE AREA F / FIRE ZONE 33A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02 extinguishers Additional FP Features Barrier separation from other fire zones Administrative Controls Transient Combustibles Control - Level 2 Area Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 66 of 105 TABLE RAI-GEN-8 CHARACTERISTICS OF FIRE AREA H/ FIRE ZONE 70A Fire Area / Description H / Containment Building Fire Zone / Description 70A / 23 & 24 Reactor Coolant Pump Area, Elevation 46-0" Fire Zone Dimensions 3,320 sq ft wI 258 ft ceiling (VC dome) a) 3-hr Barrier: No b) 20 ft Separation: No App R lIlI.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, RCP lube oil Cable Insulation Quantity in BTU 5.2E+07 BTU Total Fixed Combustible Loading / Fire Severity 33,041 BTU/sq ft / 25 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2 - RCP Motors & Pumps Detection Type / Coverage Ionization detectors / Over RCPs 23 and 24

NL-1 0-042 Docket 50-247 Attachment 1 Page 67 of 105 TABLE RAI-GEN-8 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 70A Code of Record NFPA 72D-1 975 Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water)

Additional FP Features Oil collection system on 23 & 24 RCPs Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Abandonment or Removal of Radiant Energy Shield on Selected Conduit in Containment (PGI-Other Evaluations (i.e., 86-10) 00323)

Approved Exemption from App R 111.0 for RCP Oil Collection System (SER - October 16, 1984)

NL-10-042 Docket 50-247 Attachment 1 Page 68 of 105 TABLE RAJ-GEN-9 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 71A Fire Area I Description H / Containment Building Fire Zone Description 71A /21 & 22 Reactor Coolant Pump Area, Elevation 46'-0" Fire Zone Dimensions 3,320 sq ft w/ 258 ft ceiling (VC dome) a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, RCP lube oil, miscellaneous combustibles Cable Insulation Quantity in BTU 8.5E+07 BTU Total Fixed Combustible Loading / Fire Severity 43,976 BTU/sq ft / 33 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2 - RCP Motors & Pumps Detection Type / Coverage Ionization detectors / Over RCPs 21 and 22 Code of Record NFPA 72D-1 975

NL-10-042 Docket 50-247 Attachment 1 Page 69 of 105 TABLE RAI-GEN-9 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 71A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water)

Additional FP Features Oil collection system on 21 & 22 RCPs Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Abandonment or Removal of Radiant Energy Shield on Selected Conduit in Containment (PGI-Other Evaluations (i.e., 86-10) 00323)

Approved Exemption from App R 111.0 for RCP Oil Collection System (SER - October 16,1984)

NL-10-042 Docket 50-247 Attachment 1 Page 70 of 105 TABLE RAI-GEN-10 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 75A Fire Area / Description H / Containment Building Fire Zone / Description 75A / Outer Annulus, Elevation 46-0 Fire Zone Dimensions 1,100 sq ft w/ 22 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable Cable Insulation Quantity in BTU 1.165E+08BTU Total Fixed Combustible Loading / Fire Severity 105,455 BTU/sq ft / 79 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sq ft)

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

NL-1 0-042 Docket 50-247 Attachment 1 Page 71 of 105 TABLE RAI-GEN-10 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 75A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water)

Additional FP Features ASSS instrumentation cabling protected with a Radiant Energy Shield Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Installation of 3M Interam E-54A Mat Passive Fire Protection System for Penetration H20 (FCX-Other Evaluations (i.e., 86-10) 00045-00)

NL- 10-042 Docket 50-247 Attachment 1 Page 72 of 105 TABLE RAI-GEN-11 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 76A Fire Area / Description H / Containment Building Fire Zone / Description 76A / Outer Annulus Fire Zone Dimensions 1250 sq ft w/ 22 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable Cable Insulation Quantity in BTU 1.69E+08 BTU Total Fixed Combustible Loading Fire Severity 135,200 BTU/sq ft / 101 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 1 - MOV Motor Detection Type / Coverage None Code of Record NA

NL-10-042 Docket 50-247 Attachment 1 Page 73 of 105 TABLE RAI-GEN-11 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 76A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose Station (water)

Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 74 of 105 TABLE RAI-GEN-12 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 77A Fire Area / Description H / Containment Building Fire Zone/ Description 77A / Outer Annulus Fire Zone Dimensions 950 sq ft w/22 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable Cable Insulation Quantity in BTU 8.201 E+07 BTU Total Fixed Combustible Loading/ Fire Severity 155,063 BTU/sq ft / 116 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

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

NL-10-042 Docket 50-247 Attachment 1 Page 75 of 105 TABLE RAI-GEN-12 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 77A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose station (water)

Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 76 of 105 TABLE RAI-GEN-13 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 87A Fire Area / Description H / Containment Building Fire Zone / Description 71A / Outer Annulus, Elevation 46'-0" Fire Zone Dimensions 434 sq ft w/ 27 ft ceiling, partially open to Containment dome above El. 95' a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials MCCs, instrument racks Cable Insulation Quantity in BTU None Total Fixed Combustible Loading Fire Severity 31,106 BTU/sq ft / 23 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Motor control centers (2)

Detection Type / Coverage None

NL-1 0-042 Docket 50-247 Attachment 1 Page 77 of 105 TABLE RAI-GEN-13 CHARACTERISTICS OF FIRE AREA H / FIRE ZONE 87A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water)

Additional FP Features None A Transient Combustibles Control - Level 2 Area Adm inistrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 78 of 105 TABLE RAI-GEN-14 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 17 J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area /Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 17 / Turbine Oil Reservoir Area, Elevation 15'-0" Unit 2 Turbine Building Fire Zone Dimensions 968 sq ft w/ 37 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: Yes App R IIl.G.2 Exemptions None Fixed Combustible Materials Lube Oil, Fuel Oil, Welding Leads Cable Insulation Quantity in BTU 1.013E+07 BTU Total Fixed Combustible Loading/ Fire Severity 17,984 BTU/sq ft / 13.5 minutes Transient Combustible Materials Trash, Cardboard, Lube oil, Fiberglass, Rubber, Wood, Plastic Transient Combustible Loading / Fire Severity 81,614 BTU/sq ft / 61 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources 2-Electrical Cabinets Detection Type / Coverage Thermal detection / Zone Wide

NL-1 0-042 Docket 50-247 Attachment 1 Page 79 of 105 TABLE RAI-GEN-14 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 17 Code of Record NFPA 72D-1 967 Fixed Suppression Type / Coverage Foam Spray System / Zone Wide Code of Record NFPA 16-1968 Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (foam and water) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 80 of 105 TABLE RAI-GEN-15 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 19 J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 19/ Station Air Compressor Area, Elevation 15'-0" Unit 2 Turbine Building Fire Zone Dimensions 798 sq ft w/ 21 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Lube oil Cable Insulation Quantity in BTU None Total Fixed Combustible Loading / Fire Severity 15,059 BTU/sq ft / 11 minutes Transient Combustible Materials Trash, Cleaning rags, Lube oil, Painting Transient Combustible Loading / Fire Severity 8,710 BTU/sq ft / 7 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources 1-Motor & Compressor, 1-Electrical Cabinet Detection Type / Coverage None

NL-10-042 Docket 50-247 Attachment 1 Page 81 of 105 TABLE RAI-GEN-15 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 19 Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose stations (foam and water) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 82 of 105 TABLE RAJ-GEN-1 6 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 25 J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 25 / 23 Battery Room, Elevation 33'-0" of the Unit 1 Superheater Building Fire Zone Dimensions 92 sq ft w/10 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Batteries Cable Insulation Quantity in BTU None Total Fixed Combustible Loading Fire Severity 64,130 BTU/sq ft / 48 minutes Transient Combustible Materials None Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Batteries Detection Type / Coverage None

N L- 10-042 Docket 50-247 Attachment 1 Page 83 of 105 TABLE RAI-GEN-16 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 25 Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water) and C02 extinguisher Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL- 10-042 Docket 50-247 Attachment 1 Page 84 of 105 TABLE RAI-GEN-17 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 39A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 39A / Mezzanine Floor, Elevation 36'-9" Unit 2 Turbine Building Fire Zone Dimensions 7,592 sq ft w/ 16 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: , No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Plastic, Cellulose Cable Insulation Quantity in BTU 3.626E+08 BTU Total Fixed Combustible Loading / Fire Severity 58,827 BTU/sq ft / 44 minutes Transient Combustible Materials Trash, Wood, Lube oil Transient Combustible Loading / Fire Severity 116,516 BTU/sq ft / 87 minutes Combustible Loading - Rating Moderate (Fixed + Transient loads = 100,000 - 200,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 4-Electrical Cabinets, 3-Motors Detection Type / Coverage None

N L-10-042 Docket 50-247 Attachment 1 Page 85 of 105 TABLE RAI-GEN-17 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 39A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose station (water) and C02 extinguishers Adjacent Zone Manual Suppression Hose station (water) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-042 Docket 50-247 Attachment 1 Page 86 of 105 TABLE RAI-GEN-18 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 43A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 43A / Ground Floor, Elevation 15-0" Unit 2 Turbine Building Fire Zone Dimensions 6,600 sq ft w/ 21 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Lube oil, Plastic, Wood, Electrical Panels and Cabinets Cable Insulation Quantity in BTU 3.153E+08 BTU Total Fixed Combustible Loading Fire Severity 67,808 BTU/sq ft / 51 minutes Transient Combustible Materials Trash, Cardboard Drums, Cleaning rags, Lube oil, Plastic, Fiberglass ladders, Painting Transient Combustible Loading / Fire Severity 11,382 BTU/sq ft / 8.5 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 37-MCC vertical panel, 2-Motors & Pumps, 12 Electrical Cabinets, High Voltage Arcing Fault, 1-Air Dryer

NL-10-042 Docket 50-247 Attachment 1 Page 87 of 105 TABLE RAI-GEN-18 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 43A Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (water and foam), C02, DC extinguishers Adjacent Zone Manual Suppression Hose stations (water and foam), C02, DC extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) Evaluation of Modification to Manhole 23 to Provide Protection for Electrical Cables (PGI-00576)

NL-10-042 Docket 50-247 Attachment 1 Page 88 of 105 TABLE RAI-GEN-19 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 45A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 45A / Ground Floor, Elevation 165-0" and 3'-3" of the Unit 2 Turbine Building Fire Zone Dimensions 5,380 sq ft w/ 21 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Lube oil, Vinyl insulation, Hydrogen Cable Insulation Quantity in BTU 1.303E+07 BTU Total Fixed Combustible Loading / Fire Severity 8,478 BTU/sq ft / 6 minutes Transient Combustible Materials Trash, Cardboard drums, Lube oil, Fiberglass ladders, Painting, Rad Boundaries Transient Combustible Loading / Fire Severity 12,070 BTU/sq ft / 9 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 9-MCC vertical panel, 2 Motors & Pumps, 14 Electrical Cabinets Detection Type / Coverage None

NL-1 0-042 Docket 50-247 Attachment 1 Page 89 of 105 TABLE RAI-GEN-19 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 45A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (water and foam) and C02 extinguishers Adjacent Zone Manual Suppression Hose stations (water and foam) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-042 Docket 50-247 Attachment 1 Page 90 of 105 TABLE RAI-GEN-20 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 46A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 46A/ Ground Floor, Elevation 12'-0" and 3'-3" of the Unit 2 Turbine Building Fire Zone Dimensions 12,350 sq ft w/ 124 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Lube oil Cable Insulation Quantity in BTU 2.274E+08BTU Total Fixed Combustible Loading / Fire Severity 19,399 BTU/sq ft / 15 minutes Transient Combustible Materials Trash, Cleaning rags, Lube oil, Painting Transient Combustible Loading / Fire Severity 36,689 BTU/sq ft / 27.5 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sqft)

Ignition Sources Cable run, Junction boxes, 13-Electrical Cabinets, 1-Motor & Pump Detection Type / Coverage None

NL-1 0-042 Docket 50-247 Attachment 1 Page 91 of 105 TABLE RAI-GEN-20 CHARACTERISTICS OF FIRE AREA J I FIRE ZONE 46A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose station (water)

Adjacent Zone Manual Suppression C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 92 of 105 TABLE RAI-GEN-21 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 47A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 47A / Ground Floor, Elevation 165-0" Unit 2Turbine Building Fire Zone Dimensions 5,175 sq ft w/ 37 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable Cable Insulation Quantity in BTU 1.286E+07 BTU Total Fixed Combustible Loading / Fire Severity 2,486 BTU/sq ft / 2 minutes Transient Combustible Materials Trash, Lube oil, Rubber hose, Painting Transient Combustible Loading / Fire Severity 11,075 BTU/sq ft / 8 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2-Electrical Cabinets, 7-MCC vertical panels Detection Type / Coverage None

NL-1 0-042 Docket 50-247 Attachment 1 Page 93 of 105 TABLE RAI-GEN-21 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 47A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type Hose stations (foam) and C02 extinguishers Adjacent Zone Manual Suppression Hose stations (foam & water) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 94 of 105 TABLE RAI-GEN-22 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 50A J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 50A / Mezzanine Floor, Elevation 36'-9" Unit 2 Turbine Building Fire Zone Dimensions 15,550 sq ft w/ 16 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Cable, Plastic, Cellulose, Office Cable Insulation Quantity in BTU 4.121 E+08 BTU Total Fixed Combustible Loading / Fire Severity 27,052 BTU/sq ft / 20 minutes Transient Combustible Materials Trash, Vinyl covers, Lube oil, Painting Transient Combustible Loading / Fire Severity 31,031 BTU/sq ft / 23 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Cable run, Junction boxes, 2-Transformers (dry), 8-Motor & Pumps, 18-Electrical Cabinets Detection Type / Coverage None

NL-10-042 Docket 50-247 Attachment 1 Page 95 of 105 TABLE RAI-GEN-22 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 50A Code of Record NA Fixed Suppression Type Coverage None Code of Record NA Manual Suppression Type Hose stations (water) and C02 extinguishers Adjacent Zone Manual Suppression Hose stations (water) and C02 extinguishers Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 96 of 105 TABLE RAI-GEN-23 CHARACTERISTICS OF FIRE AREA J I FIRE ZONE 270 J / Unit 1 Control Room, Turbine Building, Superheater Building, Nuclear Service Building, Fire Area / Description Chemical Systems Building, Administration Building, Screenwell House, and Unit 2 Turbine Building Fire Zone / Description 270 / General Area of the 33' Elev. of the Unit 1 Superheater Bldg Fire Zone Dimensions 13,000 sq ft w/ 19 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R IIl.G.2 Exemptions None Fixed Combustible Materials Cable Cable Insulation Quantity in BTU 7.236E+07 BTU Total Fixed Combustible Loading / Fire Severity 5,566 BTU/sq ft I 4 minutes Transient Combustible Materials Trash, Cardboard drums, Flammable Liquid Cab, Plastic, Wood, Painting Transient Combustible Loading / Fire Severity 8,037 BTU/sq ft / 6 minutes Combustible Loading - Rating Low (Fixed + Transient loads < 100,000 BTU/sq ft)

Ignition Sources Igniton Sorcespanel, panl, junction boxes, 12-Transformers (dry), 4-motors, 3-Battery Charger, 4-MCC vertical 37-Electrical Cabinets

NL-1 0-042 Docket 50-247 Attachment 1 Page 97 of 105 TABLE RAI-GEN-23 CHARACTERISTICS OF FIRE AREA J / FIRE ZONE 270 Detection Type / Coverage None Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type C02 and DC extinguishers Adjacent Zone Manual Suppression Hose stations (water)

Additional FP Features None Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

NL-1 0-042 Docket 50-247 Attachment 1 Page 98 of 105 TABLE RAI-GEN-24 CHARACTERISTICS OF FIRE AREA K / FIRE ZONE 60A Fire Area / Description K / Auxiliary Feed Pump Building (not including the AFW Pump Room)

Fire Zones / Description 60A / Chemical Addition Area, elev 33' Fire Zone Dimensions 1,210 sq ft wl8 1/2 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials None Cable Insulation Quantity in BTU None Total Fixed Combustible Loading Fire Severity NA Transient Combustible Materials Trash, Fiber drums, Painting Transient Combustible Loading /Fire Severity 1,818 BTU/sq ft / 1 minute Combustible Loading - Rating Low (Fixed + Transient loads = < 100,000 BTU/sq ft)

Ignition Sources 2-Motors & Blowers, 2-Electrical Cabinets Detection Type / Coverage None Code of Record NA

N L-10-042 Docket 50-247 Attachment 1 Page 99 of 105 TABLE RAI-GEN-24 CHARACTERISTICS OF FIRE AREA K / FIRE ZONE 60A Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type C02 extinguisher Adjacent Zone Manual Suppression None Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) None

N L-10-042 Docket 50-247 Attachment 1 Page 100 of 105 TABLE RAI-GEN-25 CHARACTERISTICS OF FIRE AREA K / FIRE ZONE 65A Fire Area / Description K / Auxiliary Feed Pump Building (not including the AFW Pump Room)

Fire Zones / Description 65A / Main Steam and Feedwater Valve Area 43'-0", 65-0", and 74'-0" Fire Zone Dimensions 1,210 sq ft w/ 43 ft ceiling a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials Wood Cable Insulation Quantity in BTU None Total Fixed Combustible Loading / Fire Severity 5,363 BTU/sq ft / 4 minutes Transient Combustible Materials Trash, Painting Transient Combustible Loading / Fire Severity 1,034 BTU/sq ft / <1 minute Combustible Loading - Rating Low (Fixed + Transient loads = < 100,000 BTU/sq ft)

Ignition Sources 2-Electrical Cabinets Detection Type / Coverage None

NL-10-042 Docket 50-247 Attachment 1 Page 101 of 105 TABLE RAI-GEN-25 CHARACTERISTICS OF FIRE AREA K / FIRE ZONE 65A Code of Record NA Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type C02 extinguishers Adjacent Zone Manual Suppression Yard Hydrants, C02, 150 lb DC extinguishers Additional FP Features None Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other. Evaluations (i.e., 86-10) None

NL-10-042 Docket 50-247 Attachment 1 Page 102 of 105 TABLE RAI-GEN-26 CHARACTERISTICS OF FIRE AREA P / FIRE ZONE 1 Fire Area / Description P / Component Cooling Pump Room, Elevation 68'-0" PAB Fire Zones / Description 1 / Component Cooling Pump Room, Elevation 68'-0" PAB Fire Zone Dimensions 710 sq ft / 12 ft grating overhead a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: Yes

-- Suppression: No App R III.G.2 Exemptions Yes - SER dated Oct 16, 1984 Fixed Combustible Materials None Cable Insulation Quantity in BTU None Total Fixed Combustible Loading Fire Severity NA Transient Combustible Materials Trash, Painting, Rad Boundaries Transient Combustible Loading / Fire Severity 2,462 BTU/sq ft / 1.8 minutes Combustible Loading - Rating Low (Fixed + Transient loads = < 100,000 BTU/sq ft)

Ignition Sources 3 - Electric Motors & Pumps Detection Type / Coverage Ionization / Area Wide Code of Record NFPA 72D-1 975

NL- 10-042 Docket 50-247 Attachment 1 Page 103 of 105 TABLE RAI-GEN-26 CHARACTERISTICS OF FIRE AREA P / FIRE ZONE 1 Fixed Suppression Type / Coverage None Code of Record NA Manual Suppression Type None Adjacent Zone Manual Suppression Hose station (water), C02, 150 lb DC extinguisher Additional FP Features 23 CCW Pump power conduit wrapped with 30 minute Hemyc barrier Transient Combustibles Control - Level 2 Area Administrative Controls Control of Hot Work and Ignition Sources Other Evaluations (i.e., 86-10) Hemyc Wrap Fire Protective Systems 23 CCW Pump (IP-RPT-04-00188)

NL-10-042 Docket 50-247 Attachment 1 Page 104 of 105 TABLE RAI-GEN-27 CHARACTERISTICS OF FIRE AREA YD / FIRE ZONE 900 Fire Area / Description YD / Exterior Yard Fire Zone / Description 900 / Yard NA - exterior yard general areas Fire Zone Dimensions a) 3-hr Barrier: No b) 20 ft Separation: No App R III.G.2 Compliance c) 1-hr

Enclosure:

No

-- Detection: No

-- Suppression: No App R III.G.2 Exemptions None Fixed Combustible Materials NA Cable Insulation Quantity in BTU None Total Fixed Combustible Loading/ Fire Severity NA Transient Combustible Materials NA Transient Combustible Loading / Fire Severity NA Combustible Loading - Rating NA Ignition Sources NA Detection Type / Coverage NA

NL-10-042 Docket 50-247 Attachment 1 Page 105 of 105 TABLE RAI-GEN-27 CHARACTERISTICS OF FIRE AREA YD / FIRE ZONE 900 Code of Record NA Fixed Suppression Type / Coverage NA Code of Record NA Manual Suppression Type NA Adjacent Zone Manual Suppression NA Non-rated Fire Protection Assemblies NA Additional FP Features NA Administrative Controls NA Other Evaluations (i.e., 86-10) NA