NL-11-059, Revised Tables from Entergy Letter NL-11-013 Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

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Revised Tables from Entergy Letter NL-11-013 Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions
ML11158A196
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 05/26/2011
From: Joseph E Pollock
Entergy Corp, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-059, TAC ME0799
Download: ML11158A196 (27)
v • d • e


Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 SEntergy Tel (914) 734-6700 J.E. Pollock Site Vice President NL-1 1-059 May 26, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Revised Tables from Entergy Letter NL-1 1-013 Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No.

ME0799)

Indian Point Unit No. 3 Docket No. 50-286 License No. DPR-64

References:

1. Entergy letter NL-1 1-013, "Revised Tables from Responses to Requests for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated February 10, 2011
2. Entergy letter NL-1 1-007, "Response to December 16, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated January 19, 2011
3. NRC letter dated December 16, 2010, "Indian Point Nuclear Generating Unit Nos. 2 and 3 - Request for Additional Information Regarding Request for Exemption (TAC Nos. ME0798 and ME0799)"

NL-1 1-059 Docket No. 50-286 Page 2 of 3

4. Entergy letter NL-1 0-101, "Response to August 11, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated September 29, 2010
5. NRC letter dated August 11, 2010, "Indian Point Nuclear Generating Unit Nos. 2 and 3 - Request for Additional Information Regarding Request for Exemption (TAC Nos. ME0798 and ME0799)"
6. Entergy letter NL-10-043, "Response to January 20, 2010 Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3 (TAC No. ME0799)," dated May 4, 2010
7. 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)"
8. Entergy letter NL-09-117, "Revision to Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated October 1, 2009
9. Entergy letter NL-09-032, "Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3," dated March 6, 2009

Dear Sir or Madam:

References 1 through 9 identify the Entergy and NRC letters involving the request for exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for the use of operator manual actions. The purpose of this letter is to provide revised pages to Tables RAI-06.1-1, RAI-08.1-2, RAI-08.1-6, RAI-01.1-1, AND RAI-01.1-, with additions indicated by bold underline and deletions by bold strikethrough. These pages replace the pages previously provided in Reference 1. Note that the replacement pages may contain changes made in previous letters, with additions also indicated by bold underline and deletions by bold strikethrough. A summary of the changes and the reasons for the changes provided in each enclosure indicates which changes are made in this current letter.

NL-1 1-059 Docket No. 50-286 Page 3 of 3 There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, IPEC Licensing Manager at (914) 734-6710.

Sincerely, JEP/gd

Enclosures:

1. Revised Page for Table RAI-06. 1-1 from Entergy Letter NL-1 1-013 dated February 10, 2011
2. Revised Pages for Tables RAI-08.1-2 and RAI-08.1-6 from Entergy Letter NL-1 1-013 dated February 10, 2011
3. Revised Pages for Table RAI-01 .1-1 from Entergy Letter NL-1 1-013 dated February 10, 2011
4. Revised Pages for Table RAI-01 .1-2 from Entergy Letter NL-1 1-013 dated February' 10, 2011 cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point Energy Center Mr. Paul Eddy, New York State Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA

ENCLOSURE 1 TO NL-1 1-059 Revised Page for Table RAI-06.1-1 from Entergy Letter NL-1 1-013 dated February 10, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-1 1-059 Docket No. 50-286 Enclosure 1 Page 1 of 1 Summary of Required Changes to Table RAI-06.1-1 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change 1-ADD entry for Fire Area/Zone TBL-5154A Fire Area/Zone TBL-5/54A was inadvertently deleted from the table in Entergy Letter NL-10-101 dated September 29, 2010 (based on field walkdown of cables for valves FCV-406A1B that omitted 1 associated circuit) and is also shown as deleted from the table in Entergy Letter NL-11-013 dated February 10, 2011. Note that Entergy Letter NL-1 1-013 also indicated a change to Table RAI-08.1-7 OMA Initiator column to DELETE Zone 54A as an Initiator Zone for the Required OMA of "Locally operate FCV-406A, 406B to control AFW flow to SGs." This change was not made to that table and it has subsequently been confirmed that Zone 54A is an Initiator Zone for this previously requested OMA.

NL-11-013 Docket No. 50-286 Attachment 1 Page 17 of 18 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4, 2010 Table RAI-06.1-1 Proximity of Redundant Safe-Shutdown CableslComponents, Fire Hazards, and Ignition Sources Within Fire Areas and Fire Zones of Concern Fire Area / Proximity to Proximity to Ignition Comments ZoneSSD Feature Significant Fixed Sources Combustibles TBL-5 I Cables associated The zone contains Ignition sources The minimal combustibles in the zone, and the distribution of the 54A with 31 AFW Pump negligible fixed consist of a cable combustibles and ignition sources throughout the zone, provide flow control valves combustibles run, electrical reasonable assurance that a credible fire scenario would be FCV-406A, B cabinet, and motors limited in scope and severity of fire damage on valve operators.

The cables of concern are proximate to the cable runs.

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

Pump Strainer zone by a security barrier enclosure.

Combustibles within the enclosure are insignificant.

REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

ENCLOSURE2 TO NL-1 1-059 Revised Pages for Tables RAI-08.1-2 and RAI-08.1-6 from Entergy Letter NL-1 1-013 dated February 10, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-11-059 Docket No. 50-286 Enclosure 2 Page 1 of 2 Summary of Required Changes to Tables RAI-08.1-2 and RAI-08.1-6 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change REVISE Table RAI-08.1-2 OMA wording from "Locally "Bypass valve for" was inadvertently omitted from this OMA wording; operate FCV-1 121 in support of use of 31 AFW Pump, OR" "OR" is not necessary to "Locally operate bypass valve for FCV-1121 in support of use of 31 AFW Pump" REVISE Table RAI-08.1-2 OMA Initiator column to ADD This column correctly contained the Initiator Area but the specific Zones 7A and 60A as Initiator Zones for the Required OMA Initiator Zones were not specifically listed of "Align Appendix R Diesel Generator (ARDG) to 480V Buses 2A, 3A, 5A, and 312" REVISE Table RAI-08.1-2 OMA Initiator column to ADD This column correctly contained the Performance Area but the Zones 5 and 6 as Performance Zones for the Required OMA specific Performance Zones were not specifically listed of "Swap 31 or 32 Charging Pump to alternate power supply" REVISE Table RAI-08.1-2 OMA Initiator column to DELETE Additional walkdown has confirmed that the target cables are Zone 62A and to ADD Zone 59A as a Performance Zone for located in Zone 59A and not in Zone 62A the Required OMA of "Locally open valve 227 to establish Charging [previously "CVCS"] makeup flowpath to RCS" REVISE Table RAI-08.1-6 OMA Initiator column to DELETE Zone 60A is in Fire Area ETN-4{1) which already had the same Zone 60A as an Initiator Zone for the Required OMA of OMA - it was inadvertently added to the OMA in Fire Area PAB-2(5)

"Open valve 227 to establish Charging flowpath to RCS in Entergy Letter NL-1 1-013 dated February 10, 2011 around potentially failed closed HCV-142"

NL-11-059 Docket No. 50-286 Enclosure 2 Page 2 of 2 Summary of Required Changes to Tables RAI-08.1-2 and RAI-08.1-6 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change REVISE Table RAI-08.1-6 OMA Initiator column to DELETE Additional walkdown has confirmed that the target cables are Zone 62A and to ADD Zone 59A as a Performance Zone for located in Zone 59A and not in Zone 62A the Required OMA of "Open valve 227 to establish Charging flowpath to RCS around potentially failed closed HCV-142" REVISE Table RAI-08.1-6 OMA Initiator column to DELETE Zone 6 is in Fire Area PAB-2{3) which already had the same OMA -

Zone 6 as an Initiator Zone for the Required OMA of "Locally it was inadvertently added to the OMA in Fire Area PAB-2{5) in close valve LCV-1 12C and open valve 288 to establish Entergy Letter NL-1 1-013 dated February 10, 2011 flowpath from RWST to Charging pump suction" REVISE Table RAI-08.1-6 OMA Initiator column to DELETE Zone 60A is in Fire Area ETN-4{1) which already had the same Zone 60A as an Initiator Zone for the Required OMA of OMA - it was inadvertently added to the OMA in Fire Area PAB-2{5)

"Locally close valve LCV-1 12C and open valve 288 to in Entergy Letter NL-1 1-013 dated February 10, 2011 establish flowpath from RWST to Charging pump suction" The field walkdown of the cables for valves FCV-406ANB inadvertently omitted 1 associated circuit

NL-11-013 Docket No. 50-286 Attachment 2 Page 6 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-2 FIRE AREA ETN-4(1)

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Actual Actual Actual Time OMAM Required Time to to Total Time to Initiator (I)

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

OMA Fire ArealZone Swap 32 CCW Pump to > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> <1m 34 m TTC: 35 m I: Area ETN-4{1}, Zone 7AS Target: 32 CCW Pump cables alternate power supply (b)

OR align city water to Margin: >25 m; P: Area TBL-5, Zone 37A Charging pumps >42% and Area PAB 2{2}, Zone 1; OR Area PAB-2{4}, Zone 17A Operate 480V Bus 3A 30 m 4.5 m 7 m TTC: 11.5 m I: Area ETN-4{1}, Zone Target: 31 AFW Pump control breaker locally to start 31 7AN cable AFW Pump Margin: 18.5 m; 61% P: Area CTL-3, Zone 11 Locally operate bypass 30 m 4.5 m 8 m TTC: 12.5 m I: Area ETN-4{1}, Zone Target: FCV-1 121 control cable valve for FCV-1 121 in 7AN support of use of 31 AFW Margin: 17.5 m; Pump,--OR 58% P: Area AFW-6, Zone 23 Operate HCV-1118 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1}, Zone Target: HCV-1118 control cable manually to control 32 60AS AFW Pump Margin: 8.5 m; 28% P: Area AFW-6, Zone 23 (b) The Total Time to Complete is revised to 34 minutes, whereas the previous submittals showed a value of 10 minutes for the Actual Time to Complete REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-1 1-013 Docket No. 50-286 Attachment 2 Page 7 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-2 FIRE AREA ETN-4{1)

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Actual Actual Actual Time OMAM Required Time to to Total Time to Initiator (I)

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

OMA Fire Area/Zone Align Appendix R Diesel 75 m <1 m 50 m TTC: <51 m I: Area ETN-4{1}. Zones Nonmechanistic Loss of Offsite Generator (ARDG) to 7A. 60A Power can be postulated at outset 480V Buses 2A, 3A, 5A, Margin: 24 m; of scenario, effectively eliminating and 312 (c) 32% P: Area TBL-5, Zone 37A; diagnosis time Area YARD-7, Zones 131, 131A; Area CTL-3, Zone 11 Swap 31 or 32 Charging 75 m 30 m 8m TTC: 38 m I: Area ETN-4{1}, Zone Target: 31 and 32 Charging Pump Pump to alternate power 7AN, 60AS cables supply Margin: 37 m; 49% P: Area PAB-2-(3}, Zones 5.6 Start ARDG and align - - - Not a separate OMA power to 480V Buses 2A, 3A, 5A, and 312 (d)

Locally operate FCV- 30 m 4.5 m 17 m TTC: 21.5 m I: Area ETN-4{1}, Zone Target: FCV-406A-D, FCV-405A-D 405B, FCV-405D, or 7AN, 7AS, 60AS control cables FCV-406B to control Margin: 12.5 m; AFW flow to Steam 37% P: Area AFW-6, Zone 23 Generators (c) Buses 3A and 312 were inadvertently omitted in previous submittals (d) This was a separate OMA in previous submittals but is herein correctly included in the OMA to "Align Appendix R Diesel Generator...

REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 2 Page 8 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-2 FIRE AREA ETN-4(1)

Actual OMA Actual Time T i_

Required Time to to Total Time to Initiator (I)

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

OMA Fire Area/Zone Locally open valve 227 to 75 m 30 m 9m TTC: 39 m I: Area ETN-4{1}, Zone Targets: Cables associated with establish Charging 60AS HCV-142

[previously "CVCS"] Margin: 36 m; makeup flowpath to RCS) 48% P: Area PAB-2{5}, Zone Travel time conservatively taken to 59A62A be 10 minutes, from CCR to PAB.

Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

Locally close valve LCV- 75 m 30 m 11 m TTC: 41 m I: Area ETN-4{1}, Zone Targets: cables associated with 112C; open valve 288 to 60AS valves LCV-112B, LCV-112C align Charging pump Margin: 34 m; suction to the RWST 45% P: Area PAB-2{3}, Zone 6 Travel time conservatively taken to and Area PAB-2{5}, Zone be 10 minutes, from CCR to PAB.

30A Travel time is non-critical, since no attempt is made to perform the OMA for the initial 60 minutes of the scenario.

Locally control SGADVs WITHDRAWN PCV-1 135, PCV-1 136 See response to RAI-02.1 REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 2 Page 13 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,2010 TABLE RAI-08.1-6 FIRE AREA PAB-2{5}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time Actual Time Total Time to Initiator (I)

Required ReurdOATm OMA Time to o toNeed Diagnose for to Complete tComAlt Complete and Fire Area/Zone Comments omet Complete NoA OMA OMA Resultant Margin OMA Performance (P)

Fire Area/Zone Locally close supply 75 m 30 m 7m TTC: 37 m I: Area PAB-2{5}, Zone Target: 32 Charging Pump control breaker for 32 Charging 4A- 487A, 1 19A, 58A cables

[previously "CVCS"] Margin: 38 m; Pump 51% P: Area CTL-3, Zone 11 Locally control 32 75 m 30 m 9m TTC: 39 m I: Area PAB-2{5}, Zone Target: 32 Charging Pump control Charging [previously 4A-148-7A, 19A, 58A cables "CVCS"] Pump using Margin: 36 m; scoop tube positioner 48% P: Area PAB-2{3},

Zone 6 Open valve 227 to 75 m 30 m 9m TTC: 39 m I: Area PAB-2{5}, Zone Targets: Cables associated with establish Charging 27A, 30A, 59A, 6260A valve HCV-142 flowpath to RCS around Margin: 36 m; potentially failed closed 48% P: Area PAB-2{5}, Travel time conservatively taken to HCV-142 Zone 62A59A 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.

REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-1 1-013 Docket No. 50-286 Attachment 2 Page 14 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-10-043 DATED MAY 4,O2010 TABLE RAI-08.1-6 FIRE AREA PAB-2{5)

CREDITED lll.G.2 OPERATOR MANUAL ACTIONS OMA Required Actual Time Actual Time Total Time to Initiator (I) to Complete Required OMA Time to toNeed Diagnose Complete and Fire Area/Zone Comments for mp Resultant OMA Performance Complete OMA Margin (P)

Fire Area/Zone Locally close valve LCV- 75 m 30 m 11 m TTC: 41 m I: Area PAB-2{5}, Zone Targets: cables associated with 112C and open valve 288 6, 17A, 2120A, 27A, valves LCV-1 12B, LCV-1 12C to establish flowpath from Margin: 34 m; 30A,-60A RWST to Charging pump 45% Travel time conservatively taken to suction P: Area PAB-2{3}, be 10 minutes, from CCR to PAB.

Zone 6 and Area PAB- Travel time is non-critical, since no 2{5}, Zone 30A attempt is made to perform the OMA for the initial 60 minutes of the scenario.

REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

ENCLOSURE 3 TO NL-1 1-059 Revised Pages for Table RAI-01.1-1 from Entergy Letter NL-1 1-013 dated February 10, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-1 1-059 Docket No. 50-286 Enclosure 3 Page 1 of 2 Summary of Required Changes to Table RAI-01.1-1 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change ADD Entergy Letters NL-1 1-013 and NL-1 1-059 as references in Information in Tables RAI-08.1-6 and 08.1-7 was revised in footnote 1 Entergy Letter NL-1 1-014; information in Tables RAI-08.1-2 and 08.1-6 was revised in Entergy Letter NL-1 1-059 REVISE OMA wording from "Locally operate FCV-1 121 in "Bypass valve for" was inadvertently omitted from this OMA support of use of 31 AFW Pump" to "Locally operate bypass wording valve for FCV-1121 in support of use of 31 AFW Pump" REVISE OMA wording from "Align Appendix R Diesel Generator Buses 3A and 312 were inadvertently omitted from this OMA (ARDG) to 480V Buses 2A and 5A, through 6.9kV Buses 2 and wording; 6.9kV bus information is unnecessary; consistency 5" to "Align Appendix R Diesel Generator (ARDG) to 480V with Table RAI-08.1-2 wording Buses 2A, 3A, 5A, and 312" REVISE OMA wording from "Locally start Appendix R Diesel Clarification that the ARDG powers 38 SW Pump through MCC Generator (ARDG) to supply Bus 312, to support use of 38SWP" 312A, which is on Bus 312; this is consistent with Tables RAI-to "Locally start Appendix R Diesel Generator (ARDG) to 01.1-1 and RAI-01 .1-2 (TBL-5) supply MCC 312A, to support use of 38SWP" DELETE Area/Zone ETN-4{3}/73A from the Required OMA This zone was inadvertently included on the table "Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to Steam Generators"

NL-1 1-059 Docket No. 50-286 Enclosure 3 Page 2 of 2 Summary of Required Changes to Table RAI-01.1-1 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change ADD Area/Zone TBL-5154A to the Required OMA "Locally Inadvertently omitted an associated circuit. NOTE: The operate FCV-406A, 406B to control AFW flow to Steam "Summary of Required Changes to Tables RAI-08.1-1 through Generators," and ADD cable "K45-YM3" to the Cables of RAI-08.1-8 from Entergy Letter NL-10-043 dated May 4, 2010" Concern column for Zone 54A contained in Entergy Letter NL-1 1-013 dated February 10, 2011 indicated a change to Table RAI-08.1-7 OMA Initiator column to DELETE Zone 54A as an Initiator Zone for the Required OMA of "Locally operate FCV-406A, 406B to control AFW flow to SGs." This change was not made to that table and it has subsequently been confirmed that Zone 54A is an Initiator Zone for this OMA.

REVISE Fire Protection Defense in Depth column for the With the addition of Zone 54A as described in the entry above, Required OMA "Locally operate FCV-406A, 406 to control AFW it is necessary to specify that Zone 52A has portable flow to Steam Generators" as follows to specify the fire extinguishers only and that Zone 54A has a hose station only protection features in Zones 52A and 54A

NL-11-013 Docket No. 50-286 Attachment 3 Page 2 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 TABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA Required Initiator Component of Cables of2 Fire Protection Defense in Depth 3 Fire Area Concern' Concern OMA' Fire Zone' Locally start Area AFW-6 33AFP AK3-PT2 Exemption granted for App R III.G.2 SER dated January 7, 1987 33 AFW Pump Zone 23 JB1-PT2/2 Area wide smoke detection from breaker JB1-X32/2 Area wide wet pipe sprinklers on Bus 6A LL7-X32 Low Fixed Combustible Loading LQ7-X32 Transient Combustible Controls X32-Y2J Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Swap 32 CCW Area ETN-4{1} 32CCP AS9-WlD Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Pump to Zone 7A January 7, 1987, and September 28, 2007 alternate Area wide smoke detection power supply Thermal detection in cable trays or align city Dry pipe/pre-action sprinklers in trays water to Low Fixed Combustible Loading Charging Transient Combustible Controls pumps Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Operate 480V Area ETN-4{1} 31AFP AI5-PT2 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Bus 3A breaker Zone 7A JB1-PT2/1 January 7, 1987, and September 28, 2007 locally to start JB1-X32/1 Area wide smoke detection 31 AFW Pump Thermal detection in cable trays I Dry pipe/pre-action sprinklers in trays

References:

Entergy letter NL-10-043 dated May, 4, 2010, Tables RAI-08.1-1 through RAI-08.1-8; Entergy letter NL-10-101 dated September 29, 2010, Tables RAI-08.l-6 and RAI-08.1-7; Entergy letter NL-1 1-013 dated February 11, 2011. Tables RAI-08.1-6 and RAI-08.1-7; Enteray letter NL-1 1-059 dated May 26, 2011. Tables RAI-08.1-2 and RAI-08.1-6 2

Reference:

Entergy letter NL 101 dated September 29, 2010, RAI-02. I response 3

References:

Entergy letter NL- 10-043 dated May, 4, 2010, Tables RAI-GEN- I through GEN-23; Entergy letter NL 101 dated September 29, 2010, Tables RAI-GEN-8, RAI-GEN-10, RAI-GEN-15, RAI-GEN-16, and RAI-GEN-19 REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 3 Page 3 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 TABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA 3

Required Initiator Component of Cables of Fire Area Concern' Concern 2 Fire Protection Defense in Depth OMA' Fire Zone' Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area ETN-4{1} FCV-1121 JB1-X32/1 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, bypass valve Zone 7A January 7, 1987, and September 28, 2007 for FCV-1121 Area wide smoke detection in support of Thermal detection in cable trays use of 31 AFW Dry pipe/pre-action sprinklers in trays Pump Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area TBL-5 JB1-X32/1 Low Fixed Combustible Loading Zone 52A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Operate HCV- Area ETN-4{1} HCV-1118 JB1-TA5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, 1118 manually Zone 60A January 7, 1987, and September 28, 2007 to control 32 Area wide smoke detection AFW Pump Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-1 1-013 Docket No. 50-286 Attachment 3 Page 4 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 TABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA Required Initiator Component of Cables of Fire Protection Defense In Depth 3 1 1 2 OMA Fire Area Concern Concern Fire Zone 1 Area ETN-4{3} JBI-TA5 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 73A January 7, 1987, and September 28, 2007 Area wide smoke detection Thermal detection in trays Dry pipe/pre-action sprinklers in trays Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Align Appendix Area ETN-4{1} 480V Bus 2A Cables of Exemption granted for App R III.G.2 - SERs dated February 2, 1984, R Diesel Zones 7A and 480V Bus 5A concern are January 7, 1987, and September 28, 2007 Generator 60A not explicitly Area wide smoke detection (ARDG) to identified by Thermal detection in cable trays 480V Buses the IP3 Safe- Dry pipe/pre-action sprinklers in trays 2A, 3A and-5A, Shutdown Low Fixed Combustible Loading and 312 Analysis Transient Combustible Controls thFOUgh-69W Minimal Ignition Sources Buses 2 and-5 Hot Work & Ignition Source Controls Portable Extinguishers in the zones Locally start Area YARD-7 SWS PMP-31 AQ8-M59 Exemption granted for App R III.G.2 - SER dated January 7, 1987 Appendix R Zone 22 SWS PMP-32 AT6-M61 Area wide smoke detection Diesel SWS PMP-33 AJ8-M62 Low Fixed Combustible Loading Generator SWS PMP-34 AQ7-M63 Transient Combustible Controls (ARDG) to SWS PMP-35 AH2-M64 Minimal Ignition Sources supply Bus SWS PMP-36 AJ7-M65 Hot Work & Ignition Source Controls MCC 312A, to Portable Extinguishers in zone support use of Hydrants in adjacent yard 38SWP REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 3 Page 6 of 17 UNIT 3 TABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA Required Initiator Component of 3 Cables of OMA1 Fire Area Concern' Concern 2 Fire Protection Defense in Depth Fire Zone' Locally operate Area ETN-4{1} FCV-406B JB1-SX1/1 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-405B, Zone 7A JF5-KV4 January 7, 1987, and September 28, 2007 FCV-405D, or JF5-LL8 Area wide smoke detection FCV-406B to K45-YM3 Thermal detection in cable trays control AFW K47-YM3 Dry pipe/pre-action sprinklers in trays flow to Steam Low Fixed Combustible Loading Generators Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area ETN-4{1} FCV-405B JB1-KV6 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, Zone 60A January 7, 1987, and September 28, 2007 FCV-405D JB1-KV8 Area wide smoke detection Thermal detection in cable trays Dry pipe/pre-action sprinklers in trays Low Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Area-EFN- FGV 405C IBI KV8 Exemption grantcd for App R 111.G.2 SERs daited Fcbrurn-; 2, 1984, 4{}FGV 4051) jBI KV7 lanuapt 7, 1987, and Septcmber 28, 2007 Zone 73A Arca wide smoke dctcction Thcrmal detcction in tr~r;s Dry pipelprc action Sprinkler- In tfays Moderate Fixed Comnbustible Leading T~asent omustible entls-Minimal ignition Seurcc Hot WOr- & ignition Source Controls

_______________________Portabic Extinguishcr-s in the zone REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 3 Page 15 of 17 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 UNIT 3 TABLE RAI-01.1-1 OMA Initiator Cables of Concern and Mitigating Features Minimizing the Potential to Require Use of Credited OMAs OMA Required Initiator Component of 3 Cables of2 OMA' Fire Area Concern' Concern Fire Protection Defense In Depth Fire Zone' Area TBL-5 Low Fixed Combustible Loading Zone 44A Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in zone Hose station in adjacent zone Locally operate Area ETN-4{3} FCV-405C JB1-KV8 Exemption granted for App R III.G.2 - SERs dated February 2, 1984, FCV-405C, Zone 73A FCV-405D JB1-KV7 January 7, 1987, and September 28, 2007 FCV-405D to Area wide smoke detection control AFW Thermal detection in trays flow to steam Dry pipe/pre-action sprinklers in trays generators Moderate Fixed Combustible Loading Transient Combustible Controls Minimal Ignition Sources Hot Work & Ignition Source Controls Portable Extinguishers in the zone Locally operate Area TBL-5 FCV-406A JB1-SX1/1 Low Fixed Combustible Loading FCV-406A, Zone 52A FCV-406B JF5-KV3 Transient Combustible Controls 406B to JF5- KV4 Minimal Ignition Sources control JF5-LL8 Hot Work & Ignition Source Controls AFW flow to K45-YM3 Portable Extinguishers in zone 52A Steam Area TBL-5 K45-YM3 Hose station in zone 54A Generators Zone 54A Locally close Area PAB-2{5} 32 Charging AH9-PL2 Low Fixed Combustible Loading supply breaker Zone 19A Pump JA4-PL2/2 Transient Combustible Controls for 32 K-B-W--B Minimal Ignition Sources Charging Hot Work & Ignition Source Controls Pump Portable Extinguishers in adjacent zone Hose station in adjacent zone REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

ENCLOSURE 4 TO NL-1 1-059 Revised Page for Table RAI-01 .1-2 from Entergy Letter NL-1 1-013 dated February 10, 2011 ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

NL-1 1-059 Docket No. 50-286 Enclosure 4 Page 1 of 1 Summary of Required Changes to Table RAI-01.1-2 from Entergy Letter NL-11-013 dated February 10, 2011 Change Reason for Change REVISE OMA wording from "Locally operate FCV-1 121 in support of use of "Bypass valve for" was inadvertently omitted from this 31 AFW Pump" to "Locally operate bypass valve for FCV-1121 in OMA wording support of use of 31 AFW Pump" REVISE OMA wording from "Align Appendix R Diesel Generator to 480V Buses 3A and 312 were inadvertently omitted from Buses 2A and 5A" to "Align Appendix R Diesel Generator (ARDG) to this OMA wording; consistency with Table RAI-08.1-2 480V Buses 2A, 3A, and 5A, and 312" wording ADD cable DD4-VN3 to the Associated Cables column for the Required Cable DD4-VN3 was inadvertently omitted from the OMA of "Locally close LCV-1 12C and open valve 288 to establish flowpath table from RWST to charging pump suction.

NL-11-013 Docket No. 50-286 Attachment 4 Page 3 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-01.1-2 IP3 Fire Area ETN-4{1}

Credited OMAs And Cable/Component Failures That May Require the Use of the Credited OMAs Type of cable Effect of cable OMA Affected Associated failure(s) that may failure that Comments / Conclusion Component(s) Cables cause need for leads to need OMA for OMA Swap 32 CCW 32 CCW Pump AS9-W1D Intra-cable fault, Presumes This area is equipped with fire Pump to alternate ground fault, open failures of detection and automatic sprinkler power supply or circuit cables serving systems as discussed in Table 01.I-I.

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

cables in this area.

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

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

to cables in this area.

Locally operate FCV-1121 JB1-X32/1 Intra-cable fault, Miniflow This OMA is required only if a bypass valve for ground fault, open recirculation concurrent failure is sustained to all FCV-1121 in circuit, inter-cable flow may be AFW flow control valves FCV-406A support of use of fault insufficient to through FCV-406D, resulting in 31 AFW Pump prevent pump 31AFW pump potentially being overheating operated under minimum flow REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-11-013 Docket No. 50-286 Attachment 4 Page 4 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-01.1-2 IP3 Fire Area ETN-4{1}

Credited OMAs And Cable/Component Failures That May Require the Use of the Credited OMAs Type of cable Effect of cable OMA Affected Associated failure(s) that may failure that Comments / Conclusion Component(s) Cables cause need for leads to need OMA for OMA conditions. The multiple concurrent failures necessary to render all AFW flow control valves failed closed is considered a low likelihood event, given the active fire protection features of the area, as described on Table RAI-01.1-1.

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

Align Appendix 480V Bus 2A Cables of concern Intra-cable fault, Potential The use of the ARDG is credited for R Diesel 480V Bus 5A are not explicitly ground fault, open inability to supplying power to the 480V buses in Generator identified by the circuit, inter-cable control offsite the event of a fire in Fire Area ETN-(ARDG) to IP3 Safe- fault power supply 4{1}. The need for implementation of 480V Buses 2A, Shutdown breakers to this OMA would require loss of 3A. and-5A, emergency function of 31 through 33 EDGs and a and 312 480V concurrent loss of offsite power.

switchgear and tie This area is equipped with fire breakers detection and automatic sprinkler between systems as discussed in Table RAI-REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

NL-1 1-013 Docket No. 50-286 Attachment 4 Page 16 of 21 ORIGINALLY PROVIDED IN ENTERGY LETTER NL-11-007 DATED JANUARY 19, 2011 Table RAI-01.1-2 IP3 Fire Area PAB-2{5}

Credited OMAs And Cable/Component Failures That May Require the Use of the Credited OMAs Type of cable Effect of cable Affected Associated failure(s) that may failure that Comments / Conclusion OMA Component(s) Cables cause need for leads to need OMA for OMA to the RCS charging makeup path to the RCS, it can be expected that limited makeup to the RCS would continue, via the RCP seal injection flowpath, which is not impacted by the closure of HCV-142.

Locally close LCV-112C DK7-VN5 Intra-cable fault, Valves may Selective cable failure modes may LCV-112C and LCV-112B DD4-VN5/1 ground fault, open spuriously result in a sustained functional open valve 288 DD4-VN5/2 circuit, inter-cable close or open charging pump suction path, or may to establish DK7-VN3/1 fault result in isolation of all charging pump flowpath from DK7-VN3/2 suction. Control room operator action RWST to DD4-VN3 taken in accordance with fire response charging pump procedure 3-ONOP-FP-1 will secure 31 suction and 32 Charging Pumps in pullout, upon detection of a fire in this area, precluding spurious pump starts, and ensuring pumps remain free of fire damage until a reliable suction path can be aligned.

REVISED IN ENTERGY LETTER NL-11-059 DATED MAY 26, 2011

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