ML12361A048

Indian Point, Unit 3, Response to Request for Additional Information on Proposed License Amendment Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank

ML12361A048
Person / Time
Site:	Indian Point
Issue date:	12/13/2012
From:	Ventosa J A Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-155, TAC ME9263
Download: ML12361A048 (252)

Text

w=EntergyEntergy Nuclear NortheastIndian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 10511-0249Tel 914 254 6700John A VentosaSite Vice PresidentNL-12-155December 13, 2012U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001SUBJECT: Response to Request for Additional Information on Proposed License AmendmentRegarding Connection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263)Indian Point Unit Number 3Docket No. 50-286License No. DPR-64REFERENCES: 1. Entergy Letter NL-12-090 to NRC Regarding Proposed LicenseAmendment Regarding Connection of Non Seismic Purification Line toRefuel Water Storage Tank, dated August 14, 20122. Entergy Letter NL-12-143 to NRC Regarding Response to Request forAdditional Information on Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263), dated October 25, 20123. Entergy Letter NL-12-154 to NRC Regarding Response to Request forAdditional Information on Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263), dated November 14, 20124. NRC Letters to Entergy, Request for Additional Information RegardingProposal to Align the Refueling Water Storage Tank and The Spent FuelPool Purification System (TAC No. ME9263), (ML12284A446,ML12299A156, and ML12313A511), Dated November 15, 2012Dear Sir or Madam:Entergy Nuclear Operations, Inc, (Entergy) requested a License Amendment, Reference 1, toOperating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3(IP3). Entergy responded to previous requests for information in References 2 and 3. Theproposed amendment would revise Technical Specification 3.5.4, to allow the non-seismicallyqualified piping of the Spent Fuel Pool (SFP) purification system to be connected to the RefuelingWater Storage Tanks (RWST) seismic piping by manual operation of a RWST seismically qualifiedAo NL-12-155Docket 50-286Page 2 of 2boundary valve under administrative controls for a limited period of time. On November 15, 2012the NRC staff identified the need for additional information to complete their review in three letters(Reference 4). Entergy is providing additional information in response to these requests (seeAttachments 1, 2 and 3 for the three letters).There are no new commitments being made in this submittal. If you have any questions or requireadditional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 254-6710. A copy of this response is being submitted to the designated New York State official inaccordance with 10 CFR 50.91.I declare under penalty of perjury that the foregoing is true and correct. Executed on December13, 2012.Sincerely,JAV/spAttachments:1. Response to Request for Additional Information (ML1 2284A446)Regarding Connection of Non Seismic Purification Line to Refuel WaterStorage Tank2. Response to Request for Additional Information (ML1 2299A1 56)Regarding Connection of Non Seismic Purification Line to Refuel WaterStorage Tank3. Response to Request for Additional Information (ML12313A51 1)Regarding Connection of Non Seismic Purification Line to Refuel WaterStorage TankEnclosure:Requested Documentscc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORLMr. William Dean, Regional Administrator, NRC Region 1NRC Resident InspectorsMr. Francis J. Murray, Jr., President and CEO, NYSERDAMs. Bridget Frymire, New York State Dept. of Public Service ATTACHMENT 1 TO NL-12-155RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION(ML12284A446) REGARDING CONNECTION OF NON SEISMICPURIFICATION LINE TO REFUEL WATER STORAGE TANKENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-286 NL-12-155Docket 50-286Attachment 1Page 1 of 5By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request foradditional information responses in letters dated October 25, 2012 and November 14, 2012,Entergy Nuclear Operations, Inc, (Entergy) submitted a license amendment request for U.S.Nuclear Regulatory Commission (NRC) review that would revise the Technical Specifications(TSs), for Indian Point Unit No. 3 (IP3). The changes would revise TS 3.5.4, "Refueling WaterStorage Tank [RWST]," such that the non seismically qualified piping of the Spent Fuel Pool (SFP)purification system may be connected to the RWST's seismic piping by manual operation of aRWST seismically qualified boundary valve under administrative controls for a limited period oftime for filtration for removal of suspended solids from the RWST water. The NRC staff, in its letterof November 15, 2012 (ML12284A446), identified that additional information was required in theirreview as follows:Question 1A single failure of these now open RWST boundary valves needs to be considered. IP3's licensingbasis accident dose analysis includes consideration of Emergency Core Cooling System (ECCS)leakage. The existing analysis approved by the NRC staff in License Amendment 224, dated March 22,2005, "Indian Point Nuclear Generating Unit No. 3 -Issuance of Amendment Re: Full Scope Adoption ofAlternative Source Te.rm (TAC No. MC3351)" (ADAMS Accession No. ML050750431) assumed theRWST valves connected to non-safety related piping remain closed during operation.After the end of the post-loss-of-coolant-accident (post-LOCA) injection phase, the ECCS andcontainment spray systems [ESF systems that recirculate sump water] are switched to therecirculation phase. This requires that water from the containment sump replace the RWST as theESF systems water supply by realigning several system valves that interface between these ESFsystems and the RWST and the pathways leading back to the RWST. If these system valves leakby design or the leakage of these valves is unknown, a leakage path between the containmentsump and the RWST and any interfacing piping may exist. For the design basis LOCA radiologicalanalyses, it is assumed that 40% of the core iodine inventory is mixed homogeneously andinstantaneously in the primary containment sump water at the time of release from the core.Because the ECCS takes suction from the sump, the sump water is assumed to be radioactive. PerRegulatory Guide 1.183, Regulatory Position 5.1.2, any piping downstream of the failed valve thatis non-safety related or not in technical specifications would not be credited in the design basisradiological analyses. Therefore, the proposed change would create a potential release pathwayfor radioactivity to the environment which is not considered in the current design basis accidentanalyses.An active failure of the boundary valve would allow any radioactive ESF leakage to the RWST tankor in route to the RWST to drain to non-seismic piping after a design basis accident (e.g. LOCA).Please describe how the credible failure of the boundary valves, proposed to be opened, impactthe assumptions for the most limiting Single active failure considered in the licensing basisaccident analysis and the resulting consequences. If this proposed change results in a new limitingsingle active failure assumption, please provide the inputs, methods1 and results for the revisedaccident analysis in order for the staff to conduct an independent analysis to confirm radiologicaldoses would remain below the criteria in 10 CFR 50.67.As an alternative to the information requested above, to address NRC staff concerns, provide ajustification for creditable actions2 to be taken to prevent and/or mitigate a radiological releasethrough non-seismic piping while in the proposed configuration. Justify how these actions would NL-12-155Docket 50-286Attachment 1Page 2 of 5not allow any increase in leakage of radioactivity to the environment which would increase theradiological consequences of any design basis accident. Any response should also include: 1)creditable actions such as additional means available to isolate flow through the non-seismic pipingafter a design basis accident, 2) the worst case single active failure (i.e. failure of the openboundary valve(s) to close), 3) the maximum time to isolate the flow after a design basis accident,4) a justification for how this closure can be accomplished within this time, 5) the minimum timeafter a design basis accident for the plant to recirculate sump water, 6) the design leakage of anycredited boundary valves at which the valve would declared inoperable by technical specifications,7) how this leakage is confirmed by testing, and 8) the inputs and methods3 used to determine thatany increased leakage (beyond the leakage in the current accident analyses), before or afterclosure of a credited boundary valve, does not increase the design basis accident doses used toconfirm compliance with 10 CFR 50.67.Please provide any design drawings showing the valves and flow pathways described in theLAR or references to docketed material with this information. Indicate which credited valves andpiping are safety related, required to be operable by technical specifications and are powered byemergency power sources.In addition, the staff believes that the proposed note to Technical Specification 3.5.4 should bemodified to 1) identify the manual valves requiring operator action to close and 2) reference theadministrative controls as described in the Technical Specification Bases. In this regard, anexpanded discussion of the administrative controls should be included in the TS Bases. Thediscussion should address planned actions, use of dedicated/designated operators, proceduresemployed, timeliness goals, and operator shift turnover discussions.1 Regulatory Guide 1.183 provides a method acceptable to the NRC for demonstrating compliancewith 10 CFR 50.67.2 Regulatory Guide 1.183, Regulatory Position 5.1.2, provides a method acceptable to the staff forcrediting mitigating systems.3 Regulatory Guide 1.183 provides a method acceptable to the NRC for demonstrating compliancewith 10 CFR 50.67.ResponseEntergy is not proposing to revise the most limiting single failure so, as an alternative, Entergy isproviding justification for creditable actions to be taken to prevent and/or mitigate a radiologicalrelease through non-seismic piping while in the proposed configuration.As noted in our previous submittals, administrative controls would be put into place to closeisolation valves 725 and 727A on the suction line from the RWST and to close valve 727B on thereturn line to the RWST. The check valve 726B does not require operator action to close. Thesevalves are all seismic 1 as noted on drawing 9321-F27513 sheet 2 sent to you-in our letter ofNovember 14, 2012. Since these pairs of valves are in series the single failure of one of the valveswould be mitigated by the other valve. Note that original plant design and licensing did notconsider the failure of a check valve as an active failure and failure of a manual valve is a passivefailure. This licensing basis is not changed by the failure assumptions in this case.The time to isolate the flow from the RWST is based on assuring adequate water in the RWST andnot on the potential for source term leakage. The time to isolate the flow from the RWST, based NL-12-155Docket 50-286Attachment 1Page 3 of 5upon the potential for limiting the available water in the RWST, was conservatively determined.The level of the RWST is raised to the overflow level of 36.8 feet, the Plant Integrated ComputerSystem sends a signal to provide an alarm prior to the RWST level reaching 36 feet (the CriticalFunctions Monitoring System was recently integrated with other computer systems as the PlantIntegrated Computer System (PICS)). The time to drain from below the overflow point (e.g., 36.7feet) to the required RWST level of 35.4 feet is 100.3 minutes. The time to drain from the 36 footlevel to the required RWST level of 35.4 feet is about 46 minutes. If the need for the RWST wereto occur due to an accident or earthquake then 100.3 minutes or more is available because thereare indications and contact with the CR is maintained. A pipe break during normal operation ispossible without the operator seeing the flow. Therefore 46 minutes is considered the timeavailable for operator action under all circumstances.The occurrence of the RWST alarm at 36 feet is presumed to initiate action to close the RWSTisolation valves. The operator could be inside or outside of the Plant Auxiliary Building (PAB) (e.g.,attend shift turnover, pick up / drop off tests, personnel hygiene, etc.). The operator will closelycoordinate with the CR and be in radio communication. A verification walkdown was lastperformed on November 19, 2012 with the Nuclear NPO in the Unit 3 Control Room to simulate anend of shift meeting. After a simulated alarm, the NPO proceeded to the PAB at a normal paceand completed the following actions from procedure 3-SOP-SI-003 in 5 minutes:1.1.1 IF in Mode 1, 2, 3, or 4, AND any symptom of a DBE occurs, THEN PERFORM thefollowing within 46 minutes:1.1.1.1 STOP Refueling Water Purification Pump.1.1.1.2 CLOSE the following valves:a) AC-727A, Refueling Water Purification Pump Suction Isolation (41'PAB, Refueling Water Purif. Pump).b) AC-725, Refueling Water Purification Pump Discharge Isolation (41'PAB, Refueling Water Purif. Pump).c) AC-727B, Spent Fuel Pit Purification Loop To RWST Isolation (34' SIPump Room).d) SI-841, Spent Fuel Pit Demineralizer To RWST Isolation (34' SIPump Room).1.1.1.3 NOTIFY Control Room, RWST Purification Lineup has been isolated.This demonstrates the ability to isolate the RWST from the purification loop with substantial marginof time. Should this action be initiated by a DBE, there would be more time available and thepathways are lighted by Appendix R lights.The time to isolate the flow from the RWST is not based on the potential for source term leakageThis is because no source term is available for leakage through any valves until the plant entersexternal recirculation after 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (NRC Letter regarding Issuance of Amendment 224 for FullScope Adoption of Alternative Source Term (TAC MC3351) dated March 22, 2005). After theRWST is injected into the containment the redundant internal recirculation pumps will be usedinstead of the external RHR pumps for suction from the sumps to inject into the core in order tominimize dose design basis accident doses. The internal recirculation pumps are also used toprovide containment spray by opening motor operated valve 889A or 889B on the outlet line fromthe residual heat exchangers that are inside containment. All of these pathways and valves are NL-12-155Docket 50-286Attachment 1Page 4 of 5part of the ECCS, controlled by TS, and powered by emergency power sources. After 6.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />sthe internal recirculation pumps are used to provide flow to the high head pumps through the 888Aand 888B valves outside of containment for hot leg injection. These flow paths are shown onDrawings 9321 -F-27353 (in the enclosure) and 9321 -F-27503 (provided in the Entergy letter ofNovember 14, 2012).The single active failure assumptions for the boundary valves are also a function of the pathwayused for the low head to high head external recirculation. In the low head to high head injectionpathway described above, the discharge of the internal recirculation pumps is directed to the 31and 33 high head safety injection (HHSI) pumps through valves 848A (31 pump) and 848B (33pump). When using this pathway there are dual isolation valves preventing pressurization of thesuction line from the RWST (see check valve 847 and MOV 1810 on one line, and MOV 887A and887B to the 32 HHSI pump are closed). The potential leakage path between the containmentsump and the RWST occurs when a passive failure is postulated that prevents low head to highhead recirculation using the internal recirculation pumps. In this case, the Residual Heat Removal(RHR) pumps are used for low head to high head recirculation. The RHR pumps take suction fromthe Containment Sump through MOV 885A and 885B. The RHR pump discharge to the suctionline from the RWST is obtained by keeping MOV 744 closed and opening MOV 883 and 1863.Recirculation is prevented because the RHR pump suction from the RWST is isolated using MOV882. The RHR pump discharge goes to HHSI pump 32 through manual valve 898. This dischargedoes not go to the 31 and 33 HHSI pumps because MOV 887A and 887B are closed (as well as1810 and 847). Because the line to the RWST is only pressurized following a single passive failure,the additional single failure of a boundary valve (in this case manual valve 727A) to close wouldnot have to be postulated.Valves AC-727B and AC-726B do not require leak testing because they are located on thedownstream side of the Class III piping boundary and are isolated from post LOCA recirculationfluid by valves that are leak tested (SI-MOV-842, SI-MOV-843) in surveillance procedure 3-PT-R1 82. Single failures are not postulated for valves AC-727A and AC-725 because that line ispressurized with sump fluid only following a single failure so that an additional single failure of avalve to close is not required. Valve AC-727A is a boundary valve for the leak testing of valve 846in procedure 3-PT-R178 and therefore leakage is tested.In response to the NRC staff request, the proposed Note and the proposed bases are to be revisedas follows:The proposed note to be added directly under actions will be revised to add the requested valvesand previously discussed administrative controls. The note will say:................................................ N O T E 1 ...........................................................The RWST isolation valves AC-727A, AC-727B and AC-725 connected to non-safety related pipingmay be opened under administrative controls for up to 14 days per fuel cycle for filtration until theend of refuel outage 18.The bases ACTION section will be revised as follows:

NL-12-155Docket 50-286Attachment 1Page 5 of 5"A note allows the RWST valves AC-727A, AC-727B and AC-725 that isolate non seismic piping tobe opened under administrative control until the end of RO 18. The administrative controls willrequire a designated operator to be assigned to isolate the RWST as needed. The operator will betrained on when to isolate in accordance with required procedure (e.g., specific indications of SI,loss of offsite power, CR orders) and that this is a critical function to be performed as quickly aspossible. The operator will coordinate with the CR if leaving the PAB for activities such as shiftturnover. The operator shall discuss the functions to be performed when turning over to adesignated operator during shift change. The controls are sufficient to assure that the TS requiredamount of water will be available under all conditions. "

ATTACHMENT 2 TO NL-12-155RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION(ML12299A156) REGARDING CONNECTION OF NON SEISMICPURIFICATION LINE TO REFUEL WATER STORAGE TANKENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-286 NL-12-155Docket No. 50-286Attachment 2Page 1 of 3By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request foradditional information responses in letters dated October 25, 2012 and November 14, 2012,Entergy Nuclear Operations, Inc, (Entergy) submitted a license amendment request for U.S.Nuclear Regulatory Commission (NRC) review that would revise the Technical Specifications(TSs), for Indian Point Unit No. 3 (IP3). The changes would revise TS 3.5.4, "Refueling WaterStorage Tank [RWST]," such that the non seismically qualified piping of the Spent Fuel Pool (SFP)purification system may be connected to the RWST's seismic piping by manual operation of aRWST seismically qualified boundary valve under administrative controls for a limited period oftime for filtration for removal of suspended solids from the RWST water. The NRC staff, in its letterof November 15, 2012 (ML12299A156), identified that additional information was required in theirreview as follows:Question 1Describe the review of operating experience that was done in support of the proposed TS change.Provide copies of any corrective action items that identified problems involving the SFP purificationsystem or operation of the RWST boundary valves, or if too numerous, provide a summary ofproblems and the preventive actions taken.ResponseOperational Experience was not reviewed since this manual action had been credited by safetyevaluation under RIS 2005-20 until the NRC position in Information Notice 2012-01 was reviewedand addressed.Condition Reports of potential interest from November 1, 2002 have been identified and are in theenclosure.Question 2On page 4 of 7 of Attachment 1 to the licensee's submittal, it is stated, "The calculated time foroperator action to close AC-725 or AC-727A and terminate flow is 46 minutes based on dischargefrom one end of the purification loop." Further down on that same page, it is stated, "Thecalculated time to reach the TS level of 35 feet 4 inches from 36 feet is 46 minutes." By thesestatements it appears that there is no margin, that is, it will take the operator the full 46 minutes toterminate flow from the RWST in time to comply with the TS limit. Please clarify or justify why nomargin is necessary.ResponseThe calculated time for the operator action is the time calculated as available for operator action(i.e., 46 minutes after the level alarm). There is margin for the operator to perform the requiredfunctions based on the time it takes the operator to perform the function which is discussed in theresponse in Attachment 1.Question 3On page 3 of 7 of Attachment 1 to the licensee's submittal, it is stated, "There is no dedicatedoperator..." On page 4 of 7, the licensee states that the procedure associated with purifying the NL-12-155Docket No. 50-286Attachment 2Page 2 of 3RWST requires "designated operators" to walk down the location of the refueling water purificationpump switch and the four relevant valves. Traditionally, the NRC defines "dedicated" as beingassigned to a certain task and no other(s), while "designated" means that a specific person isassigned to a task, but may have other assignments. Clarify whether a dedicated or a designatedoperator will be used, or whether operators will be neither dedicated nor designated. The NRCstaff has not approved this kind of TS change, to date, without the use of a dedicated operator.ResponseThe operator action requested was for a designated operator (one assigned and briefed on thetask) rather than a dedicated operator (one assigned to a certain task and no other). This is basedupon the indications available and the training provided as discussed in the original request(Entergy Letter NL-12-090 to NRC Regarding Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water Storage Tank, dated August 14,2012) and the amount of time available for performance of the task (see Attachment 1 discussion).Although NRC has not approved other than a dedicated operator for this task, IP3 is unique indesign by having internal recirculation pumps so that sump fluid is not recirculated outsidecontainment for at least 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> rather than the normal time of about 20 minutes for a majorLOCA (the existing analysis approved by the NRC staff in License Amendment 224, dated March22,2005, "Indian Point Nuclear Generating Unit No. 3 -Issuance of Amendment Re: Full ScopeAdoption of Alternative Source Term (TAC No. MC3351)" (Accession No. ML050750431) contains thisdiscussion). The actual valve lineups are discussed in Attachment 1.Question 4Describe the process used to validate the effectiveness of the procedures referenced in thesubmittal.ResponseThis action is a Time Critical Operator Action per OAP-1 15. A copy of the procedure is included inthe Enclosure (see pages 25, 26 and 69).Question 5Provide a copy of Procedure 3-SOP-SI-003, "Recirculation and or Purification of the RefuelingWater Storage Tank".ResponseA copy is provided in the Enclosure.Question 6What verification and validation (V&V) processes were used to determine that the relevant operatoractions could be done effectively and within the time constraints involved? What sample ofoperators was used during V&V testing?

NL-12-155Docket No. 50-286Attachment 2Page 3 of 3ResponseThis action is a Time Critical Operator Action per OAP-1 15, see Enclosure, which describes thevalidation required for this.Question 7Does IP3 have a Time-critical Action Program to protect high-risk, time-limited actions frominadvertent change? If yes, is the proposed task sequence included in that program? If no, whatcontrols are used to prevent inadvertent changes to the proposed operator actions or the timeavailable to perform them?ResponseIPEC has a time critical action program as described in the responses to questions 4 and 6.Question 8What cue(s) call the operators' attention to the Critical Functions Monitoring System when acomputer point is in alarm?ResponseThe CFMS has been replaced with PICS, but the process is the same. Per 3-SOP-SI-003 step4.1.1 high head to low head the RWST alarm is set 0.3 ft lower than the indicated overflow alarm.Performing this task is skill of the craft for Reactor Operators, and they can refer to the PICs UsersGuide. If this alarm is generated then the operator action to initiate isolation of the RWST is takenper the operator training.

ATTACHMENT 3 TO NL-12-155RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION(ML12313A511) REGARDING CONNECTION OF NON SEISMICPURIFICATION LINE TO REFUEL WATER STORAGE TANKENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-286 NL-12-155Docket No. 50-286Attachment 3Page 1 of 1By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request foradditional information responses in letters dated October 25, 2012 and November 14, 2012,Entergy Nuclear Operations, Inc, (Entergy) submitted a license amendment request for U.S.Nuclear Regulatory Commission (NRC) review that would revise the Technical Specifications(TSs), for Indian Point Unit No. 3 (IP3). The changes would revise TS 3.5.4, "Refueling WaterStorage Tank [RWST]," such that the non seismically qualified piping of the Spent Fuel Pool(SFP) purification system may be connected to the RWST's seismic piping by manual operationof a RWST seismically qualified boundary valve under administrative controls for a limitedperiod of time for filtration for removal of suspended solids from the RWST water. The NRCstaff, in its letter of November 15, 2012 (ML12313A51 1), identified that additional information tosupplement the October 25, 2012 letter was required in their review as follows:Question 2In your response noted above, you indicated that the American Society of MechanicalEngineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code)/ISTC-3540 five year exercise requirement was applicable to the subject manual valves.However, this requirement has been modified by Title 10 of the Code of Federal Regulations (10CFR) 50.55a(b)(3)(vi), wherein the frequency for exercise testing for manual valves is requiredto be at intervals no longer than two years. Will the revised Indian Point Unit 3 (IP3) InserviceTesting (IST) Plan show the required test frequency for these manual valves as two years orless?ResponseThe frequency will be two years.Question 3In your response noted above, you indicated that ASME OM Code exercise testing wasapplicable to the subject valves and that this requirement would be added to the IP3 IST Plan.Did your analysis reveal that any other ASME OM Code testing is required (e.g., positionindication verification or seat leakage testing)? Other licensees have revisited their NRCInformation Notice 91-56 evaluations, to ensure that leakage past these valves would notadversely affect their calculations of control room and offsite dose from post-Loss of CoolantAccident recirculation fluid.ResponseValves AC-727B and SI-841 do not require leak testing since they are located on thedownstream side of the Class III piping boundary and are isolated from post LOCA recirculationfluid by valves that are leak tested (SI-MOV-842, SI-MOV-843). Valve AC-727A is part of thepressure boundary for the testing to valve SI-846 (RWST suction). These tests are confirmatoryof the post loss of coolant accident recirculation fluid dose analyses. See attachment 1 for amore detailed discussion.

ENCLOSURE TO NL-12-155REQUESTED DOCUMENTS1. Drawings 9321-F-273532. Procedure OAP-1 15, "Operations Commitments and Policy Details"3. Procedure 3-SOP-SI-003, "Recirculation and orPurification of the Refueling Water Storage Tank"4. CR-IP3-2002-50925. CR-IP3-2003- 1166, 3264, 4700, 47196. CR-IP3-2005- 02397. CR-IP3-2007- 08598. CR-IP3-2009- 22199. CR-IP3-2-11-3729, 4483, 451510. CR-IP3-2012-1710, 1741, 1768, 3339ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-286 86533540 8571 1-5141~ -19352 SC SIT 7tF213'3.S-8599 2 S35LIS.- 815 05, 12-- 'lL193R 2-SISI- I --1 --~~~~~LN -11OCF 28 1315T- EIR 0 2 1 1,-RE (T I SS aPLR85IN117 1, 92 2LSTH 316. 01 0 'S-47~Y~S306 -0-5550 SE.., '%sS-ICs -S -R RS -ST~S -3 055 0C 1 "S R1 ~ -180r~ 14E S ' M3838 LIS U2184 I -S -I.I1A.86 3' 410.LE83 318C -IS-12 -S4. 2--2IO z~E" FHIPT5310 -.2 -N~ lC -5 -50 -C-63 " C "-SS,86-023 C1-SI-SaCS2O~ __________ N 0525163-311-13 IT 8j~iI~I ~ -HC~~t63R CT CL)I-~~L N-1TT 4 -EaEE (FOCI r --- a C-SI-SIF SITCT C-Il SIICS -OT 515C57FaIRE C" 8881 0 -SlD aRa 10 -5C 830 RE06 OSS 2931 LITE 58IN-S~ 0S SI C ~ z3795 5 5-~ RCT 4 -TCTC !IR SICT~81-ITCNISS E'0S f 63 893 15528-STIS I.StO ITPIOLI 4704 S IETCF-_,f ICOC F-15 -4 1526C 63 035 5 0n' i i T I v~ E -E -I C1'.- 523 755 C * -~3--l- 9R N4- LESM a" " 4SCC 118-S C 334- 1 T I tV a1 C020 I I2131I TO 73.ISCISTSC-F-21T5I532 ý 3SC23C0 SS ....S.S.CN- 3I1 'T --SI-S01I I E -SISL C: xLSIC TISOCL s3 r:QFa RS)IT3"3E~~aC~~a I ~~~ ~ 3 TSCF1 76' 1-ICISIL.TSSTI94TI .8T132 LT14u 3 36 LST-31REF EI4y-FC C 855 18SEE C LT101S8DETN IL ES/AREFERENCES:G E SF -- 11.C9 803OE S05C. G-6751- REV. I3. FIEE- SS.05 3T9RVO.. S530. 4-47D89 RFV.Io E 7:C 0-67639eS IEV, 3H[] TE7EEEySTE 59508-LE- L1EI4-RSEERERECJE0 FEAR TRW-0 ll ON83 E LOW LE IN _0 1=ýIITIONNm] -ONc _:n C , I TESTF- E ECIILL85.LCAI) MI.-IG ST.E 01 -I IN -OA -1G POINTD, ORTFOEF IS -TLED WITH -pUMPEM DWITH -1-1IT-11SIOPISON FL L IEFRSI. L 5I -.E -87 -BI.LO* T LOW PINTI OH PEll M. NS IT-ED FIS NT-1- DIS-EIt, ET .S P.LINES IIN DI-TED TO THIRD S-TION OF THESL COINTAINI-G 1CIRC. F-S)Rý I-W OR .JK C0- ON THE -.LI. N- osBO. -.1. INISI. -6 IL T, --OR s -NH VLV NO'S. ý -RCE BY "S1' IIS THE s-T-F7P AS MITEO2171, 2172 IS NE DTERMIAM BY 1 5Y1- FLOW85S TO -T PIPI-REFERENCE INGS :27193 -I~ IS SYSTM SHET I -CONTaINWENT27201 _jIL rY --T SYS -iNSIO -T.1-NT2-1 Z: _ IN IS & T 227363 CVL CHENIIOX O OUN T-C SYSTEM 1..... ""c CHEMIA -orc SYSTEM SHEET27173 --T OOO T SYSTEM SHEET 22_33 N TO NL~- M EQUIPEN27245 W THIM -WITEI SYSTEMI S SINNILING I- I-ATIN -ý SYSIEN13 I-C-27-3 L E EI-THIS -WITH -31-F-11-1SF8854 P1OINT N. 68663C R & 1-3ER641055010N1N EINE -E. I -ofE-E -OSE 1-13OI3T~TS OS1FLCI' DIESGRAMN-SAFETY INJECTION SYSTEMSHEET NO.IF321%F273S314286TTYPE A/ISI/FSiR4 a-EntergyNuclear NortheastProcedure Use Is:O3 Continuous[o ReferenceI InformationControl Copy:Effective Date: 3//2Page 1 of 79OAP-115, Revision: 15OPERATIONS COMMITMENTS AND POLICY DETAILSApproved By:ý " ý /I jk--4- -/ I R-E-SI-LProcedure Sponsor6SM/Desig~eeDateTeam StaffProcedure OwnerEDITORIAL REVISION ry OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 2 of 79REVISION SUMMARY(Page 1 of 2)1.0 REASON FOR REVISION1.1 Incorporated Supervisor feedback to clarify supervisory use of NA.2.0 SUMMARY OF CHANGES2.1 Added step 4.4.1.4 for marking post test / evolutions valve positions N/A.Previous rev 14 removed similar step in response to CR-IP3-2011-05110, CA#13. Step was removed via feedback COM-0735 "due to the possibility ofmisapplication". The corrective action though, requested that a feedback besubmitted to "clarify Supervisory use of N/A" in the specified situation. Uponreview with AOM, it was decided to re-apply the step with clarifications as to theconditions when N/A can be used by supervisory personnel only. This is anALARA concern and safety concern. {Editorial 4.6.11}

z--Entergy OPERATIONS COMMITMENTS AND No: QAP-115 Rev. 15POLICY DETAILS Page 3 of 79TABLE OF CONTENTSSection Title Page1.0 PURPOSE ......................................................................................................................... 52.0 PRECAUTIONS AND LIMITATIONS ............................................................................ 53.0 PREREQUISITES .......................................................................................................... 54.0 PROCEDURE ........................................................................................................... 64.1 Standard W atch Routine/Practices .................................................................... 64.1.1 CCR Conduct (Ref: 7.1.33) ................................................................... 64.1.2 Response to Annunciators: ................................................................... 74.1.3 Control Room Annunciator Tracking Log ............................................... 84.1.4 CCR Access {Ref: 7.1.14 and 7.1.20} .................................................. 94.1.5 Non-Outage CCR Activities .................................................................. 94.1.6 Response to Plant Events ..................................................................... 94.1.7 Operations Department Briefs ............................................................. 104.1.8 NRC Authentication Codes .................................................................. 124.1.9 Peer Checking ..................................................................................... 124.1.10 Movements of Operators assigned duties under 0-AOP-SEC -1 ...... 134.2 Expectations Related to I&C Activities in the CCR ........................................... 134.2.1 General Access ................................................................................... 134.2.2 Communications ............................................................................... .144.2.3 Component Manipulations .................................................................. 144.3 Equipment Operation ....................................................................................... 154.3.1 General Guidelines .............................................................................. 154.3.2 Starting Equipment / Returning Equipment to Service: ......................... 164.3.3 W ork Step List ..................................................................................... 164.4 Use of Procedures ............................................................................................ 174.4.1 General Guidelines .............................................................................. 174.4.2 Continuation of Partially Performed Procedures .................................. 194.4.3 Completed Procedures ....................................................................... 204.4.4 10 CFR 50.54 (x) and (y): .................................................................. 204.4.5 Components Out Of Desired Position .................................................. 224.5 Management Expectations ............................................................................... 22 OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 4 of 794.6 Fire Brigade Requirements ............................................................................. 234.7 Unit 2 Annunciator Window Color Coding ......................................................... 244.8 Time Critical Operator Actions ......................................................................... 264.9 Site Tagging Guidance ..................................................................................... 275.0 RESPONSIBILITIES ................................................................................................... 296 .0 D E F IN IT IO N S .................................................................................................................. 3 17 .0 R E F E R E N C E S ................................................................................................................ 328.0 RECORDS AND DOCUMENTATION ......................................................................... 35AttachmentsATTACHMENT 1, Siren Activation Event Data Sheet ................................................ 37ATTACHMENT 2, Work Step List .................................................................................. 39ATTACHMENT 3, Authentication Code Log .................................................................. 41ATTACHMENT 4, Unit 2 Time Critical Operator Actions ............................................... 42ATTACHMENT 5, Unit 3 Time Critical Operator Actions ............................................... 61ATTACHMENT 6, Time Critical Operator Action Validation ........................................... 79 IEnte& OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 5 of 791.0 PURPOSE1.1 To provide guidance on implementing IPEC Operations Departmentcommitments, policies, and expectations.2.0 PRECAUTIONS AND LIMITATIONS2.1 Plant operations personnel SHALL:2.1.1 Operate safety-related systems and components within proceduraloperating limits (including log sheet operating bands) UNLESS a formalreview process (e.g. NSEs, operability determinations) demonstrates theacceptability of operation outside of procedural operating limits).{Ref: 7.1.8}2.1.2 Adhere to Tech Spec, TRM, and ODCM requirements. {Ref: 7.1.3}3.0 PREREQUISITESNone 4.0tergy OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 6 of 79PROCEDURE4.1 Standard Watch Routine/Practices4.1.1 CCR Conduct {Ref: 7.1.33)4.1.1.1 A professional CCR atmosphere SHALL be maintained asfollows:* CCR access is limited to official business ONLY.* All shift team members SHALL be in conformance withthe dress code specified in step 4.5.1." All personnel entering the CCR SHALL dressprofessionally including the wearing of shirts with collars.Hats/caps, shorts, t-shirts, and sneakers SHALL not beworn within the CCR.* Reading material NOT directly related to plant operation,testing, or maintenance is prohibited." Any personal device used for entertainment is prohibited,including:* Radios" Stereos* Hand held games* Internet access is limited to work related activities,including the following sites:* INPO" NRC* Weather* Tides* Entergy/IPEC Web pages* Communications concerning plant business is open,courteous, and concise:" Non-business-related extraneous communicationis limited.* Personality conflicts SHALL NOT interfere withperformance.* Cursing is NOT allowed.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 7 of 794.1.1.2 Personnel permitted to enter the CCR controls area SHALLallow the operator clear access to controls and indications.4.1.1.3 Food and drink in the CCR SHALL be limited to watch teammembers:* Food and drink SHALL be kept away from control panels.* Eating SHALL NOT detract from plant monitoringactivities.* Empty food containers/dishes SHALL NOT be left out foran extended period.4.1.2 Response to Annunciators:4.1.2.1 IF the alarm panel is local, THEN NPO SHALL investigate:(Ref: 7.1.31)Any actions taken should be reported to the CCR assoon as possible.4.1.2.2 Nuisance annunciators are defined as CCR alarms that satisfyone of the following:* NOT valid for existing plant, system, or equipmentconditions* Result from loop or circuit failure* Valid, but at a repeat frequency that produces operatordistraction4.1.2.3 IF all of the following conditions are met, THEN nuisanceannunciators may be removed from service without a T-Alt:0 ARP evaluated and applicable actions taken based onplant, system, or equipment conditions.* IF the annunciator is required to support operability, or isrequired by Emergency Procedures, THEN annunciatoris declared inoperable and appropriate actions taken forinoperability.* Alternate monitoring methods or other compensatoryactions (i.e., increased tours, special log) implemented asnecessary.0 Removal from service entered in the Unit Log, and ifapplicable, the CCR Annunciator Tracking Log.0 Associated alarms are marked with an OUT OFSERVICE label.

OPERATIONS COMMITMENTS AND NO: QAP-li1 Rev. 15POLICY DETAILS Page 8 of 79SM approved disabling the alarm.4.1.2.4 IF a nuisance annunciator return to service is NOT anticipatedbefore turnover, THEN the annunciator SHALL be entered onthe CRS Turnover Sheet.4.1.2.5 IF a nuisance annunciator return to service is NOT anticipatedwithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, THEN a CR SHALL be initiated to documentevaluation of operability and reportability, and to assessimplementation of a Temporary Alteration.4.1.3 Control Room Annunciator Tracking Log4.1.3.1 At Unit 3 The Control Room Annunciator Tracking Log SHALLbe used to track the status of all illuminated/out-of-servicecontrol board annunciators in the Control Room.4.1.3.2 The Reactor Operator/Balance of Plant Operator isresponsible for maintaining this log. This log SHALL beupdated prior to each shift turnover as follows:a) All illuminated annunciators that are in service SHALLbe annotated as such by placing an 'X' on theappropriate window of the laminated sheet in thetracking log.b) All out-of-service/impaired annunciators SHALL beannotated as such by placing a circle on theappropriate window of the laminated sheet in thetracking log.c) The reason for each illuminated or out of serviceannunciator SHALL be noted in the comments sectionon the appropriate laminated sheet in the tracking log(e.g., a problem description with the WRT number,surveillance testing that is in progress and the testprocedure number, etc.).4.1.3.3 During the shift turnover process, a review of the ControlRoom Annunciator Tracking Log SHALL be performed by theoncoming shift crewmembers to ensure that an accurate andthorough understanding of illuminated and out-of-serviceannunciators are clearly understood by the oncoming shift.4.1.3.4 Configuration Control of Annunciators during testing iscontrolled under OAP-21, Configuration Control of CCREvolution/Test Interface.

OPERATIONS COMMITMENTS AND No: QAP-li1 Rev. 15POLICY DETAILS Page 9 of 794.1.4 CCR Access {Ref: 7.1.14 and 7.1.2014.1.4.1 The CRS OR RO SHALL authorize and manage ControlRoom access.4.1.5 Non-Outage CCR Activities4.1.5.1 Maximum permitted concurrent tasks that affect the CCRSHALL be:* Determined by the SM: {Ref: 7.1.29}* IF differing concerns can NOT be resolved, THENthe SM SHALL make the final determination." Nominally3 Tasks on U-34 Tasks on U-24.1.5.2 On-shift review of system issues is authorized as follows:* Special projects SHALL NOT interfere with the STAprimary duties (Unit 2) {Ref: 7.1.23)4.1.6 Response to Plant Events4.1.6.1 IF the CCR announces a plant fire, THEN:* A currently, or previously licensed IPEC operator meetingthe minimum qualification requirements defined inIP-SMM-DC-901 (IPEC Fire Protection Program Plan)SHALL respond as the Fire Brigade Leader [Ref: 7.1.4).4.1.6.2 IF CCR is notified that an Emergency Notification SystemSiren is sounding, THEN Unit 2 CCR SHALL:* COMPLETE ATTACHMENT 1, Siren Activation EventData Sheet .{Ref: 7.1.16)

OPERATIONS COMMITMENTS AND No:QAP-ilS Rev. 15POLICY DETAILS Page 10 of 794.1.7 Operations Department Briefs4.1.7.1 The guidance provided in IP-SMM-HU-102, Pre-job Briefingand Post Job Critiques, SHALL normally be referred to formost briefs conducted by Operations Department personnel.a) An exception to the above applies in the cases ofreactivity management and plant transients whereplacards in the control rooms which are controlled bythe Operator Aid Program shall be used for conductingthese briefs.4.1.7.2 There are numerous sources of information available toenhance the pre-job briefings and post job critiques performedby Operations Department personnel. Some of these include(but are not limited to) the following:* OAP-25, Operations Self-Assessment Program,Attachment 3" EN-OP-102, Protective and Caution Tagging Program" Operations Pre-Job Brief Database" From time to time other tools may be provided as ameans of enhancing or improving these communicationsprocesses.4.1.7.3 The tools referenced in Step 4.1.7.2 may be employed at thediscretion of the supervisor in charge. With the exception oftransient briefs and reactivity management briefs (per Step4.1.7.1 a)), IP-SMM-HU-102 provides adequate guidance forthe conduct of Operations Department briefs, the supervisormay elect to use any of the sources referenced in Step 4.1.7.2or others as an enhancement to the brief, however IP-SMM-HU-1 02 is adequate to meet the minimum requirement for pre-job briefs and post job critiques.4.1.7.4 Briefings should normally be conducted as "Reverse orEngaged" briefs. In circumstances where in the judgment ofthe supervisor (e.g. a tag out prepared by the supervisor tosupport an emergent job is being hung on short notice) aReverse or Engaged brief is inappropriate. The supervisor orother designated personnel should lead the brief. In thosecases the lead should point out during the brief the reason forthe exception.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 11 of 794.1.7.5 NO tasks should be assigned to field operators over thephone. All tasks are to be assigned and reviewed in thefollowing manner:a) A face to face meeting between the person directingthe task and the field operator.b) During the face to face meeting the operator and theperson assigning the task SHALL ensure the operatorhas the correct procedure in hand.c) At the conclusion of the task, the operator SHALLreturn the marked up copy of the procedure to the FSSor CRS.d) The supervisor SHALL ensure proper place keepingwas performed (the optimum being the supervisor waspresent to observe the evolution, providing feedbackon the spot)." Feedbacks are to be submitted by the operator forany procedural enhancement* Ensure the operator knows NOT to interpret steps.The operator is to stop, make the equipment safeand get the procedure clarified by the supervisoror the procedure revised.e) Exceptions to Step 4.1.7.5 of this procedure are:1) Emergency Operating Procedures2) Abnormal Operating Procedures3) Alarm Response Procedures -However, fieldARP's shall be returned to the Control RoomSupervisor for review of:Steps performedPlace keepingEnsure replacement of marked up field copies4) As directed by Shift Manager5) Skill of the craft item, as designated in EN-OP-115, IPEC site specific attachment.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev._15POLICY DETAILS Page 12 of 794.1.8 NRC Authentication Codes4.1.8.1 The following apply to the reception and use of the daily NRCAuthentication Codes:" NRC will generate and provide a single, four-digitalphanumeric sequence to each CCR during the dailyplant communications check. (approximately 0400)" The NRC will state the current authentication code andgive the new authentication code." The Control Room Operator taking the call will ensure thenew code is written to ATTACHMENT 3 (AuthenticationCode Log) that will be used with 0-AOP-SEC-2(AIRCRAFT THREAT).* The new code will be effective at 0800 each day.4.1.9 Peer Checking4.1.9.1 Peer Checking SHALL be performed as determined by theOperations Supervisor (CRS/FSS/SM) for equipmentmanipulations per EN-OP-1 15, Section 5.8 and Aft. 9.4 (flowchart), except during the performance of EOPs, AOPs, andONOPs.4.1.9.2 WHEN Peer Checking is not used, THEN operators andsupervisors SHALL USE Self Checking, STAR, and othererror prevention techniques to ensure operational events donot occur.4.1.9.3 During off-normal or emergency conditions, Peer Checkingshould be restored when the plant has been stabilized orpersonnel become available, as determined by the CRS/SM.

OPERATIONS COMMITMENTS AND No: QAP-il1 Rev._15POLICY DETAILS Page 13 of 794.1.10 Movements of Operators assigned duties under 0-AOP-SEC-14.1.10.1 Reactor Operators assigned to the ABFP building:* May leave the Control Room provided they take withthem:* Radio OR other portable communication device* Assigned keysMay not exit the building in an area that they are able tobe observed from the site fence line. This includes anypart of the river front, and any location the fence line isvisible.4.1.10.2 Unit 2 NPO assigned to the Appendix R EDG:* May not exit the building in an area that they are able tobe observed from the site fence line. This includes theriver front, the north hill, etc." Areas of movement shall be limited to the followingareas:* Unit 1 from 15' to 53' inside the turbine hall, adminbuilding, superheater building, house serviceboiler building* Unit 2 from 15' to 53' inside the turbine hall,feedwater heater bay, control building" They shall carry with them, at all times:" Radio OR other portable communication device" Assigned keys4.1.10.3 These assignments shall be made and understood at theSOW meeting to ensure all parties are clear on responsibilitiesand movement restrictions4.1.10.4 These assignments will NOT apply upon entry into an EOP,ONOP, or AOP (other than 0-AOP-SEC-1) and shall beresumed immediately upon exit from an EOP, ONOP, or AOP.4.2 Expectations Related to I&C Activities in the CCR4.2.1 General AccessI&C should always get permission prior to entering the operating areaof the CCR. This includes following breaks and or lunch. (i.e. I&Cshould not be granted free access in and out of the operating area asplant conditions may change throughout the day).

OPERATIONS COMMITMENTS AND No: QAP-li1 Rev. 15POLICY DETAILS Page 14 of 79" Traffic through the ATC area should be kept to a minimum andlimited to required work in the area. When entering the ATC area,I&C should pause and get permission from the ATC operator.* When practical, I&C traffic should be diverted through the back racksto access the key box or enter the back of the panels. (To minimizetraffic the rack keys have been moved to the CRS desk on U3.)4.2.2 Communications* Formal 3 point communications shall be used and enforced for allcommunications related to performance of a test or activity. This isfor both I&C communications with each other and I&Ccommunications with the operators.* Slang or informal terminology shall not be used.* Non-work related conversations should be kept to a minimum andheld outside of the operating area.4.2.3 Component Manipulations4.2.3.1 All component manipulations performed by operations inaccordance I&C testing shall be communicated via proper 3point communication and peer checked in accordance withmanagement expectations. There are 2 methods for I&C torequest these component manipulations, via the CRS or viathe RO:a) Requesting Component Manipulations via the CRS:1) The I&C technician will inform/request the CRSof the desired component manipulation utilizing 3point communications.2) The CRS will then direct the operator to performthe manipulation utilizing 3 point communication.3) The operator will perform the manipulation withthe required peer check. The Peer checker canbe another operator or an I&C technician asdetermined by CRS.b) Requesting Component Manipulations via the RO:1) The manipulations required are discussed withthe CRS in the pre-job brief.

ergy OPERATIONS COMMITMENTS AND No: QAP-il1 Rev. 15POLICY DETAILS Page 15 of 792) The I&C technician will inform/request the RO ofthe desired component manipulation utilizing 3-point communications.3) The RO will then inform the CRS of themanipulation to be performed utilizing 3 pointcommunication.4) The operator will perform the manipulation withthe required peer check. NOTE: the Peerchecker can be another operator or an I&Ctechnician as determined by CRS.4.3 Equipment Operation4.3.1 General Guidelines4.3.1.1 WHEN necessary for authorized Non-Operations personnel tooperate plant equipment, THEN perform the following:{Ref: 7.1.6)a) CONTACT the CCR prior to operating plantequipment." Obtain SM authorization." Certain equipment manipulations per approvedprocedures by other departments (i.e. FIN) may beexcluded from this requirement.b) OPERATE plant equipment per approved plantprocedures OR within the scope of the work package.IF equipment is being operated under minormaintenance, THEN ENSURE all componentmanipulations are documented by annotating onMinor Maintenance Sheet.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 16 of 79c) WHEN equipment operation is complete, THEN:" INFORM the CCR.* RESTORE to As Found position andIndependently VERIFY.* VERIFY As Left position per COL or governingprocedure:May be accomplished by contacting the on-watchCRS, FSS, or SM to ensure the correctcomponent position is identified.4.3.2 Starting Equipment I Returning Equipment to Service:4.3.2.1 During non-abnormal/non-emergency situations, when startingequipment, alternative indication SHALL be used to ensure asuccessful start of the equipment. Acceptable alternativeindications are pressure, flow, local observation or amps(component or bus amperage before and after the start).4.3.3 Work Step List4.3.3.1 Work Step lists SHALL NOT be used to troubleshootequipment. (Refer to EN-MA-125, Troubleshooting Control ofMaintenance Activities).4.3.3.2 Work step lists are to be used only for the followingcircumstances:" Preparing a System, Subsystem, Component or Devicefor maintenance prior to or after Tagout is applied.* Restoration of a piece of equipment following work, afterTagout removal and prior to being declared operable.4.3.3.3 IF an item manipulated in the work step list requires doubleverification, those items SHALL be placed in their final positionusing the type of verification called for in the COL anddocumented on ATTACHMENT 2, Work Step List (Page 39).4.3.3.4 An individual Work Step List SHALL NOT be used more thanonce.4.3.3.5 ATTACHMENT 2, Work Step List, OR electronic substitutecontaining all information listed on ATTACHMENT 2 SHALLbe used to outline a Work Step List.

t"6 OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 17 of 794.3.3.6 E mail electronic copy OR forward paper copy IF no electroniccopy exists to the Operations Procedure Group Supervisor forpossible procedure incorporation.4.4 Use of Procedures4.4.1 General Guidelines4.4.1.1 Ensure work is performed to the current revision including anyoutstanding changes by verifying document or record statusthrough MERLIN.a) Personnel may verify current revision, including anyoutstanding changes by use of controlled hard copyset in the following locations. {Ref: 7.3.1)* U2 Control Room" U3 Control Room* U2 FSS* U3 SM Office" U2 SM Office4.4.1.2 Approved procedures SHALL be used to operate plantequipment: {Ref: 7.1.13)IF a procedure can NOT be performed as written,THEN a TPC or revision SHALL be issued PRIOR to use:The SM retains the discretionary authority to orderdeviations to any procedure pursuant to 10CFR 50.54.Operators SHALL use their extensive training,qualification, and experience to ensure procedures arecorrect and appropriate for the activity being performed.Operators may take actions that are NOT covered byprocedures, but necessary to stabilize the plant:CRS permission should be obtained prior to takingactions.IF time does NOT permit prior approval, THEN theCRS SHALL be informed of actions taken as soonas possible.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev._15POLICY DETAILS Page 18 of 794.4.1.3 Procedure steps cannot be written that address everycircumstance, but are written assuming that all applicableequipment is available, and that the tasks addressed arebeing performed for the first time. Circumstances will arisethat would warrant marking a step, or section as NotApplicable (N/A).a) Examples of circumstances applicable to the use ofN/A are as follows:* Steps or sections that establish a condition thathas already been established" Steps or sections that direct the use of equipmentthat is Out of ServiceExample: Place a charging pump controller inAUTO when the controller is NOT functioningwould be N/A.* Prerequisites or initial conditions that DO NOTapply:Example: The initial condition to perform a COLfor a system, when the task is to bump apump for rotation during an outage, AND thesystem is NOT in service." Steps obviously NOT applicable to the plantcondition:Example: Performing a manual makeup with theRV Head removed, a step "OBSERVE TaveAND control rod bank position followingaddition of makeup" would be N/A." Any conditional step can be marked N/A.Conditional steps are those that begin with an IFstatement.b) Conditional steps that are NOT performed SHALL bemarked N/A by the user, and DO NOT require priorapproval of the SM/CRS/FSS.c) Non-conditional steps SHALL ONLY be marked N/Awith the approval of the SM/CRS/FSS.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 19 of 794.4.1.4 Restoration valve line ups for Surveillance tests andoperations evolutions can have individual valve positionsmarked Not Applicable (N/A) if all of the following conditionsare met;0 The As Found and As Left valve positions are the sameas the COL valve position.* The valve was verified in the COL position when the AsFound line up was performed.0 The valve was NOT manipulated during the performanceof the Surveillance test or Operations Evolution.0 Only the on shift Surveillance Test Supervisor and / orShift Manager SHALL mark restoration position N/A.4.4.1.5 COLs establish initial system alignments (Unit 2) or 100%system alignments (Unit 3): {Ref: 7.1.36)A set of completed COL books SHALL be maintainedcurrent to ensure the most recently performed COL isavailable.IF only portions of a system OR selected equipment is tobe operated, THEN ONLY applicable COL portions arerequired to satisfy the initial condition statement of COLcomplete.4.4.1.6 The performer and peer checker shall read the procedure andreview expected response prior to usage.4.4.2 Continuation of Partially Performed Procedures4.4.2.1 Prerequisites SHALL be performed prior to recommencingprocedure performance.4.4.2.2 Field Use procedures that are NOT completed in the sameshift OR are carried over between shifts SHALL be annotatedas to what step is in progress, brought to the CCR, and placedin the bin behind the CRS at the end of the shift. Allcompleted steps SHALL be annotated. If the originalprocedure is contaminated or destroyed, a copy SHALL bemarked up showing what steps have been performed andwhat steps are still to be completed or in progress. Someexceptions to this are:Procedures controlled from local workstations or localalarm panels (Regens in the CPF, Ul waste operations,GE water lineups)

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 20 of 79* Procedures that have been completed (swapping SFPpumps)" Procedures directed by or controlled from CCR (mastercopy of procedure is in CCR). As directed by theCRS/FSS/SM.4.4.2.3 Procedures in use SHALL be tracked as necessary onappropriate turnover sheets.4.4.3 Completed Procedures4.4.3.1 Completed procedures and/or procedure sections SHALL besubmitted to the CRS/FSS for review.4.4.3.2 The CRS/FSS SHALL review the completed procedures forthe following.* Proper section and all required steps performed* Validate procedure quality and ensure feedbacksubmitted if required.* Ensure proper place keeping was utilized.4.4.4 10 CFR 50.54 (x) and (y):4.4.4.1 Operations personnel SHALL NOT give or accept directions orguidance that conflicts with approved procedures, TechnicalSpecifications, or a License Condition, with the exception ofthose actions pursuant to 50.54 (x) and (y).4.4.4.2 All actions that occur per 50.54 (x) and (y) SHALL beapproved by a licensed Senior Reactor Operator:Those actions SHALL be immediately reported to theUnit Operations Manager, Site Operations Manager,Plant Operations General Manager, or the IPEC SiteVice President and documented via CR.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 21 of 794.4.4.3 Operations personnel MAY take responsible action thatdeparts from a License Condition or Technical Specificationpursuant to 10 CFR 50.54 (x) and (y), within the limits of thefollowing:" Use of the provision is NOT optional:IF an emergency protective action is needed ANDNO action consistent with the license isimmediately apparent that can provide adequateor equivalent protection, THEN personnel areobligated to take protective action under thisprovision." Use of the provision does NOT require NRCconcurrence:* IF time permits, THEN NRC Operations Centertelephone notification should be made beforeaction is taken.* IF time does NOT permit, THEN NRC OperationsCenter telephone notification SHALL be made assoon as possible.* NRC notifications SHALL be made per ENN-LI-102, Corrective Action Process." Provision does NOT apply where time permits NRCamendment to Technical Specifications or LicenseCondition.* Provision SHALL NOT be used to prevent damage to theplant or machinery unless such damage is tied to apossible adverse effect on public health and safety.* Provision ONLY applies to emergencies where licensecompliance poses a barrier to effective protective action,and rapid action is needed to protect public health andsafety:Immediate threat of injury to personnel isappropriate justification for the use of theprovision.Use of the provision is NOT tied to the declaration of anyemergency classification in the Emergency Plan. Sinceemergencies can develop rapidly, use of the provisionshould NOT be encumbered by administrativeprerequisites.

Ilk No: OAP- 115 lRev. 15VEntergy OPERATIONS COMMITMENTS AND NPOLICY DETAILS Page 22 of 794.4.4.4 Circumstances requiring use of the provision may occur duringboth analyzed or unanalyzed transients or accidents.4.4.5 Components Out Of Desired Position4.4.5.1 WHEN a component is found that is NOT believed to be in thedesired position AND NO procedure is found that wouldprovide guidance on placing the component in the desiredposition, THEN:a) OBTAIN concurrence from an SRO prior tore-positioning the componentb) ENTER the manipulation of the component in theNarrative Logc) INITIATE a Condition Report4.5 Management Expectations4.5.1 Attire in a manner reflecting the high standards of the department:* Watch Team or Respirator Qualified personnel are clean shaven.* Well-groomed and neat in appearance* Uniform shirts are buttoned and tucked in, cleaned and pressed, etc.NOTEApproved uniform shirts are acceptable in addition to the items listed below.Operations Line Management Personnel on the watch:* White button-down shirts* Navy Blue or Black dress pantsBargaining Unit Reactor Operators:* Blue button-down shirts* Blue short sleeve shirts* Black dress pants A Ilo A- 1 e.1--Enterg OPERATIONS COMMITMENTS AND No: OAP-i1 , Rev. 15POLICY DETAILS Page 23 of 79* Bargaining Unit Personnel:* Hunter green or Navy blue button-down shirts (ColdWeather)* Grey or blue button-down shirts -(Warm Weather)* Black denim or cotton pantsN O open-toed shoes or sandals* NO excessively worn or tattered clothing* When actively working in operating areas of the plant, around rotatingequipment or hot pipes and valves, or when engaged in physicalwork, short sleeved shirts are NOT permitted.* "Active work" does NOT include passive activities suchas rounds taking, tours, and the like.4.6 Fire Brigade Requirements4.6.1 Fire Brigade SHALL consist of four (4) members and a Brigade Leader.4.6.2 The below listed positions are members of the Fire Brigade and may beused to fulfill the requirements of step 4.6.1. Their Brigaderesponsibilities are delineated in IP-SMM-DC-901, (IPEC Fire ProtectionProgram Plan):* Fire Brigade Leader (Qualified Individual)* Station Rover NPO* Schedule designated NPO* Schedule designated NPO* Schedule designated NPO4.6.3 The following limitations apply to Fire Brigade members:4.6.3.1 The Fire Brigade leader can NOT concurrently hold the STAposition.4.6.3.2 Fire Brigade Responders shall not be assigned duties withouthaving established a means of direct communication with theControl Rooms.4.6.3.3 Fire Brigade Responders shall not be assigned to attendtraining outside of the protected area.

terg/ OPERATIONS COMMITMENTS AND No: 0AP-115 Rev. 15POLICY DETAILS Page 24 of 794.6.3.4 IF needed outside the Protected Area but within the OwnerControlled Area, GT 2 and 3, OR the Buchanan Switch Yard,THEN the following criteria apply:* ONLY ONE member may leave the Protected area at anyone time." The member must be in radio contact with the ControlRoom while outside the Protected Area.* The member must have a vehicle for travel while outsidethe Protected Area.* The member's turnout gear and SCBA must be staged atthe Protected Area entrance while outside the ProtectedArea.4.6.3.5 At least one member SHALL maintain a presence at each unit.4.6.3.6 Only one member may enter the VC while access is restricted.4.6.4 WHEN responding to a fire, THEN Fire Brigade members shall report toeither the fire brigade room or the nearest fire brigade locker and don allnecessary personal protective equipment, including Self-ContainedBreathing Apparatus (SCBA), and proceed to the fire scene withappropriate extinguishers and equipment.4.7 Unit 2 Annunciator Window Color Coding4.7.1 Unit 2 annunciator windows SHALL be colored using the followingguidelines: {Reference 7.2.1)" Full Red -All reactor and turbine trips, imminent plant trip/safetyinjection/plant transient if operator action is not taken withinapproximately five minutes.* Half Red -All Safety Injection trips. Any potential plant transientleading to plant trip/safety injection/equipment damage if operatoraction is not completed within approximately 30 minutes.* White -Normal Annunciator Response Procedure usage and urgencyapplied.9 Green -Normally lit annunciator AIMEnteig OPERATIONS COMMITMENTS AND No:QAP-1iS Rev.15POLICY DETAILS Page 25 of 794.7.2 The list of Unit 2 color coded annunciators is provided as follows:List of Unit 2 Color Coded AnnunciatorsAll Reactor Trips and Turbine Trips -Panel FAF and FDFPanel FBF Window 2-5, 3-5, 3-7, 3-8Panel SAF Window 4-9Panel SBF-2 Window 2-6, 3-6, 1-8, 2-8, 3-8, 4-8Panel SCF Window 4-6Full Red Panel SDF Window 4-1, 4-3Panel SEF Window 3-8Panel SFF Window 1-5, 3-5Panel SGF Window 2-3, 3-3, 3-6, 3-7Panel SJF Window 2-82-ARP-016 Window 3-1All Safety Injection Trips -FDF Window 2-5, 3-5, 1-7, 2-7, 1-8Half Red FBF Window 4-6SAF Window 3-9SCF Window 1-6SEF Window 3-2, 1-4SFF Window 3-6, 4-6, 3-7, 4-7Half RedSGF Window 2-9SJF Window 1-52-ARP-016 Window 1-1, 2-1, 1-2, 4-3Green 2-ARP-005 Window 2-4 OPERATIONS COMMITMENTS AND No: QAP-liS Rev. 15ery OPERATIONS COMMITMENTS AND N:OP 1 e.1POLICY DETAILS Page 26 of 794.7.3 Red page sleeves SHALL be placed in the Annunciator ResponseProcedures corresponding to Full Red alarm annunciators for rapidlocation of red alarm responses. First Out annunciator ARPs do NOTrequire page sleeves.4.8 Time Critical Operator Actions4.8.1 Time critical operator actions (TCOAs) are identified on ATTACHMENT4 and ATTACHMENT 5.4.8.2 A TCOA as defined in WCAP-1 6755-NP as a manual action or series ofactions that must be completed within a specified time to meet the plantlicensing basis.4.8.3 If a TCOA must be completed immediately, per Technical Specifications:"When 'immediately' is used as a Completion Time, the Required Actionshould be pursued without delay and in a manner."4.8.4 TCOAs are grouped as follows:* FSAR* Appendix R Fire Scenario* Other Miscellaneous (PRA, Station Blackout, Tech Specs,Commitments and other license basis sources)4.8.5 TCOAs should be validated as follows:* Every 5 years* Implementation of procedure changes significantly affecting therequired time to complete a TCOA, as listed in OAP-6 OperationsProcedure Review and Control, Attachment 14.Plant modifications significantly affecting the required time tocomplete a TCOA. It is necessary to consider modifications changingequipment design and operation, changing access, etc." TCOAs should be validated either in simulator or by walkthrough, ifpossible and alternate means if not, and documented usingATTACHMENT 6, Time Critical Operator Action Validation.* Simulator Validation -Execution of procedures using theplant-specific simulator during a simulated event.* Walkthrough Validation -A step-by-step in-plantwalkthrough of procedures by plant personnel, simulatingmanipulation of controls and equipment.* Validation can be waived if TCOA is determined to be of low risksignificance OR performance is not expected to exceed 50% ofrequired time.

erg OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 27 of 794.8.6 Staged equipment supporting TCOAs should be periodically inventoried.4.9 Site Tagging Guidance4.9.1 The following guidance is provided to support tagout preparation. Thisguidance is a result of OE and an effort to promote consistency betweenunits.4.9.1.1 Tag control power to the traveling water screens to ensureconsistency between units.4.9.1.2 All tagouts prepared in Online Ops Planning are to be peerchecked by an Operations Planning SRO/Equivalent beforegoing to the watch. This is NOT the independent review. Wewant the independent review to remain with the watch. Thepeer check is a big picture check that verifies* The component numbers are consistent* There are NO glaring errors* The correct component* The details make sense* The nomenclatures are clear4.9.1.3 Watch tagout review of online tagouts should be performed atT-4 (4 day shifts). Comments if any should be forwarded andfinal sign off should occur NO later than Sunday night of T-3 (4night shifts).4.9.1.4 Any newcomers to Operations Planning (online or outage)need to complete the Familiarization Guide and return theguide to the Lead SRO for filing.4.9.1.5 Any big picture changes in how we implement EN-OP-102 willrequire a change management plan either from the onlineplanning lead SRO or the outage planning lead SRO. This isnecessary to ensure all stakeholders are aware and are NOTsurprised in the field during walk-down. This applies when wedeviate from some long used, well known tagout that the craftare familiar with.4.9.1.6 When used as protection on a tagout, all breakers will bedisconnected from the bus (Racked out, Racked into Test, orRemoved), unless a different arrangement is approved by theAssistant Operations Manager.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 28 of 794.9.1.7 For outage emergent tagout revisions, during outageexecution, the following guidance applies:a) Revisions are only to be generated in OSS quiet room,on-line ops planning area or outage planning area.b) Revisions must be pre-approved by SOC (OSSmanager).

5.0No: OAP-115 l e.1fergy OPERATIONS COMMITMENTS AND Rev. 15POLICY DETAILS Page 29 of 79RESPONSIBILITIES5.1 ALL OPERATIONS PERSONNEL5.1.1 Attending training as scheduled UNLESS prior Site Operations Managerapproval is obtained: {Ref: 7.1.24 and 7.1.37)5.2 UNIT OPERATIONS MANAGER (2 or 3) (UOM)5.2.1 Controlling Shift Manager (SM) administrative loading. (Ref: 7.1.32)5.2.2 Issuing SM Responsibilities and Authorities letter.{Ref: 7.1.17 and 7.1.18)5.3 SHIFT MANAGER (SM)5.3.1 Implementing or supervising the Operations Department responsibilitiesof the following programs:* Emergency Plan {Ref: 7.1.16)* Equipment Status and Configuration Control {Ref: 7.1.25, 7.1.3015.3.2 Periodically conducting plant tours to inspect material condition andcoach proper watch standing/worker practices. {Ref: 7.1.22)5.3.3 Ensuring safety system operability verification as follows:{Ref: 7.1.15, 7.2.3)* Reviewing Check Off Lists and log sheets* Verifying or demonstrating alternate safety train operability perTechnical Specifications and applicable testing documents PRIOR toremoval from service AND following restoration {Ref: 7.1.34)5.3.4 Authorizes access to protected equipment areas.5.4 CONTROL ROOM SUPERVISOR (CRS)5.4.1 Remaining sufficiently proficient with all operations procedures andguides to recognize abnormal conditions, correctly diagnose the cause,and direct actions to terminate the event. {Ref: 7.1.26)5.4.2 Maintaining a broad overview and awareness of plant operations, inprogress or planned, and plant conditions to ensure reactor safety andreliability via the following: {Ref: 7.1.30)* Reviews of Unit logs, completed COLs, the Protective Taggingdatabase, and the LCO Tracking Log0 Communications with the SM, FSS, STA, ROs, and NPOs teg OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 30 of 795.5 REACTOR OPERATOR (RO -OTC, BOP, 3rd RO)5.5.1 Continually monitoring instrumentation and alarms, and remainingsufficiently proficient with all operations procedures and guides torecognize abnormal conditions, correctly diagnose the cause, andterminate the event. (Ref: 7.1.26)5.6 SHIFT TECHNICAL ADVISOR (STA) {Ref: 7.1.19)5.6.1 Providing engineering expertise on-shift to ensure safe operation.{Ref: 7.1.27)5.6.2 Advising the SM and CRS regarding safe plant operation duringevolutions involving reactivity changes, major transients, or accidentconditions. (Ref: 7.1.2115.6.3 Conducting control board walk-downs {Ref: 7.1.26)5.6.4 Conducting joint, face-to-face discussions with the SM, FSS, and CRSat the beginning of shift and during significant changes to plantconditions to discuss the following: (Ref: 7.1.271* Current plant conditions* Planned shift evolutions* Any changes in plant status, expected transients, and possiblecontingencies5.6.5 Conducting a minimum of 2 Vital Area tours per shift and noting anyabnormal conditions: {Ref: 7.1.28)* The results of these tours and any corrective actions required SHALLbe communicated to the SM/CRS/FSS.* The performance and results of these tours SHALL be documentedin the Unit Narrative Log.5.6.6 IF transiting to areas where the plant page may NOT be audible, THENinforming CCR personnel and obtaining other means ofcommunications. {Ref: 7.1.28)5.6.7 Expeditiously informing the Unit Operations Manager of identifiedconditions where corrective action is required and NOT taken:(Ref: 7.1.28)* IF required action is still NOT taken, THEN the Site OperationsManager SHALL be informed.

Ener y OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 31 of 795.7 FIELD SUPPORT SUPERVISOR (FSS)5.7.1 Authorizing removal of plant equipment and systems from service ANDsafety tagging for maintenance, testing, or operational activities:* Obtaining SM authorization for safety-related equipment.{Ref: 7.1.35)5.7.2 Authorizing return to service of all equipment and systems followingmaintenance, testing, or operational activities: {Ref: 7.1.35)* Notifying SM of plant equipment returned to service.5.7.3 Authorizing scheduled surveillance test start in lieu of the SM.{Ref: 7.1.35)6.0 DEFINITIONSNoneI MEntergy OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15POLICY DETAILS Page 32 of 797.0 REFERENCES7.1 Commitment DocumentsUnit 3 Commitments7.1.1 COM-94-05147 (IPN-94-091), Reply to NOV Associated with LER 94-09(Log 94-041 -B)7.1.2 COM-94-05147 (IPN-94-112), Closure of NRC Commitments7.1.3 COM-95-05281 (IPN-95-01 0), Interruption of Switch Gear ContinuousFire Watch (Log 95-003-A)7.1.4 COM-95-05340 (IPN-95-021), Response to Request for Evaluation ofConcern Regarding Activities at IP3 (Log 95-018)7.1.5 COM-95-05543 (IPN-95-112), Reply to NOV 50-286/95-13-01(Log 95-062-A)7.1.6 COM-96-05796 (IPN-96-103), Reply to NOV 50-286/96-07-01(Log 96-046-A)7.1.7 COM-88-03186 (IP3-88-055), Response to LER 88-12 (Log 88-023)7.1.8 COM-95-05464 (LER 95-014), Low Pressure Operation Placed the PlantOutside Design Basis Due to Inadequate Procedures and ImproperDocument Use (Log 95-048-B)7.1.9 COM-95-05631 (LER 95-022), Plant Operating Outside Procedures andIn Violation of Technical Specifications Due to Personnel Error (Log 96-005-B)7.1.10 Limitorque SMB-00 Operators, PS 4114/IP3 Letter from Limitorque,08/26/1995.7.1.11 COM-87-03066 (WAJ-87-0627), Response to IER-87-08 (Log 87-003-B)7.1.12 COM-93-04831 RGI, (Log 93-090-AU) Enforcement ConferenceAssociated with IR-93-22.7.1.13 COM-95-05579 (IR 95-15), Resident Safety Inspection andNOV 50-286/95-15 (Log 95-065-D)

OPERATIONS COMMITMENTS AND No:_OAP-115 Rev. 15POLICY DETAILS Page 33 of 79Unit 2 Commitments7.1.14 NL-73-A74-C02 Action taken to limit control room access7.1.15 NL-73-A91-C01 When redundant system is removed from service,portion remaining functional will be tested7.1.16 NL-79- A91 -C19 Alerting of emergency personnel by CCR operators7.1.17 NL-79-A65-C38 Shift Manager responsibilities for safe plant operation7.1.18 NL-79-A65-C41 Shift Manager responsibilities for safe plant operation7.1.19 NL-79-A65-C42 Requirement for Watch Engineer7.1.20 NL-79-A65-C46 Limiting CCR access and establishing clear line ofauthority and responsibility in the CCR7.1.21 NL-79-A91-C14 Requirement for Watch Engineer to assist SM7.1.22 NL-80-A25-C05 Maintain 2 CRS in CCR during power operations orhot shutdown7.1.23 NL-81-A01-C17 WE duties other than specified functions clarification7.1.24 NL-83-A27-C05 Alteration of training schedules by Plant Manager7.1.25 NL-87-01 1-C01 See commitment database for detail7.1.26 NL-88-013-C04 SM, CRS and WE/STA board walk-downs7.1.27 NL-88-013-C06 WE will be assigned to a shift and attend start ofwatch meeting7.1.28 NL-88-013-C07 WE will be assigned to CCR, conduct 2 vital areatours and maintain a log book7.1.29 NL-88-070-C17 Procedures and policies to resolve differing ofopinions between SM, CRS, RO and WE7.1.30 NL-92-045-C02 See commitment database for detail7.1.31 NL-97-084-C08 Verification of local panel for alarm conditions7.1.32 NL-98-066-C038 Reduce administrative burden on the SM7.1.33 NL-98-066-C065 Improve standards for CCR decorum7.1.34 NL-98-141-C01 Redundant equipment is available prior to removingsafety-related equipment from service OPERATIONS COMMITMENTS AND NO: QAP-li1 Re1POLICY DETAILS DM 13Aavu ~ Uk I V7.1.35 NL-98-141-C02 On watch CRS will grant permission to commencemaintenance or testing7.1.36 NL-99-035-C02 Operations procedures revised to be consistent withthe "Standards and Expectations for Operations Personnel7.1.37 PD-83-042-C03 Limiting use of the 25% annual toleranceRequirement and Commitment Cross ReferenceProcedure Procedure ProcedureSection Section Section73-A74-C02 4.1.4 79-A91-C14 5.6.2 88-070-C17 4.1.5.180-A25-C05 5.3.2 92-045-C02 5.3.1, 5.4.273-A91-C01 5.3.3 81-A01-C17 4.1.5.2 97-084-C08 4.1.2.179-A91-C19 5.3.1, 4.1.6.2 83-A27-C05 5.1.1 98-066-C038 5.2.179-A65-C38 5.2.2 87-011-C01 5.3.1 98-066-C065 4.1.15.1.1, 5.4.1,79-A65-C41 5.2.2 88-013-C04 98-141 -C01 5.3.35.5.1, 5.6.379-A65-C42 5.6 88-013-C06 5.6.1, 5.6.4 98-141-C02 5.7.1, 5.7.2,5 55.7.379-A65-C46 4.1.4 88-013-C07 5.6.5,5.6.6, 99-035-C02 4.4.1.35.6.7U2 Other Procedure U2 Other Procedure U2 Other ProcedureSection Section SectionPD-83-042-C 5.1.103U3 IPN Procedure Procedure ProcedureScinSection SectionCOM-95-05281(IPN-95-010)2.1.2COM-96-05796 (IPN-96-103)4.3.1.1COM-94- COM-95-0534005147 (IPN- (IPN-95-021) 4.1.6.194-091) (IPN-95-021)COM-94- COM-95-0554305147 (IPN- (IPN-95-1512)94-112) (IPN-95-112 OPERATIONS COMMITMENTS AND No: OAP-115POLICY DETAILS On ,-,A 7QI Rev. 15I %J.J ~JI I .1Procedure Procedure ProcedureU3 Other Scon U3 Other Scin U3 Other SetoSection Section SectionCOM-88- COM-87-0306603186 (IP3- (IER-87-08) SMB-0088-055) OperatorsCOM-95- COM-93-04831 PS 411405464(LER 2.1.1 (IR-93-22) IP3 Letter95-014) __ fromCOM-95- Limitorque,05631 (LER COM-95-05579 4.4.1 08/26/199595-022) (IR 95-15)7.2 Development Documents7.2.1 Unit 2 Modification GMT FIX-98-1201 1-M (for local alarm window) andGMT-FIX-SNX-91-06681-M (for CCR alarm window)7.2.2 WCAP-1 6755-NP, Rev. 0, Operator Time Critical Action ProgramStandard, March 20077.2.3 SOER 09-1, Shutdown Safety7.2.4 CR-IP3-2011-5166 CA-14 and CA-157.2.5 LO-WTIPC-2012-84 CA-37.2.6 CR-1P3-2011-5110 CA-137.3 Interface Documents7.3.1 EN-AD-1 03, Document Control and Records Management Activities7.3.2 IP-SMM-DC-901, IPEC Fire Protection Program7.3.3 IP-SMM-OU-1 04, Shutdown Risk Assessment8.0 RECORDS AND DOCUMENTATION8.1 RecordsThe following required records are generated by this procedure and SHALL bemaintained in accordance with IPEC Records Retention Schedule:None8.2 Documentation OPERATIONS COMMITMENTS AND NO: OAP-115 Rev.15POLICY DETAILS Page 36 of 79The following documentation resulting from this procedure are NOT required tobe controlled and maintained in accordance with the IPEC Records RetentionSchedule:8.2.1 ATTACHMENT 6, Time Critical Operator Action Validation ATTACHMENT 1Siren Activation Event Data Sheet(Page 1 of 2)1. IDENTIFY CALLER IF caller is other than event observer, THEN attempt to identify byName, Address, and Telephone number of event observer.a. Name:b. Address:c. Telephone:2. DATE: 3. TIME OF CALL: AM /PM4. TIME OF EVENT: AM /PM5. SIREN LOCATION:a. Town AND County:b. Street OR Intersection:6. OPERATION REPORTED:a. Siren sounded? .................................................................. Yes Nob. Is siren still operating? ........................................................ Yes Noc. Any unsafe conditions? ...................................................... Yes Nod. Any damage assessed? ..................................................... Yes Noe. Approximate duration sounded? ................................... Minutes7. OTHER PERTINENT DETAILS:8. Westchester Division requested to make safe?Yes No ATTACHMENT 1Siren Activation Event Data Sheet(Page 2 of 2)WARNING POINTSWestchester County WP ........................................................................... (914) 231-1905Rockland County W P ................................................................................ (845) 364-8600O range County W P ................................................................................... (845) 615-0879Putnam County W P ................................................................................... (845) 225-4300 ATTACHMENT 2Work Step List(Page 1 of 2)WSL Number:(Use "year / Month / day / time" as the number Example 200703031515)Date: / / Page 1 ofSystem / Component affected:Purpose of Step list:References used in step list development:Prepared By:Reviewed By:Watch Chemist:(Required if there is a potential for a Chemistry concern.)Watch HP:(Required if there is a potential for a Radiological concern.)Approved By:(SM/Designee)NOTEIt MAY be acceptable to perform some steps concurrently OR NOT in the sequencepresented provided the SM approval is obtained.Prerequisites:1. Briefing held outlining Precautions, Limitations, Safety concerns, Scope of work etc..2. Verification that equipment status is as expected prior to performance of Work Step List.

ATTACHMENT 2Work Step List(Page 2 of 2)Step List 1st 2nd1.2.3.4.5.6.7.8.9.10.Steps MAY continue for as many pages as necessary.

ATTACHMENT 3Authentication Code Log(Page 1 of 1)MONTH MONTH1 16 1 162 17 2 173 18 3 184 19 4 195 20 5 206 21 6 217 22 7 228 23 8 239 24 9 2410 25 10 2511 26 11 2612 27 12 2713 28 13 2814 29 14 2915 30 15 3031 31 No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 42 of 79ATTACHMENT 4Unit 2 Time Critical Operator Actions(Page 1 of 19)IP2 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableDetermine the cause 15 minutes Chemical and CN-TA-03-90, Rev. 2-AOP-CVCS- Not required Uncomplicatedof dilution, isolate following Volume 1: Indian Point Unit 1 Actions inthe reactor water initiating event Control 2 (IPP) Boron Mode 1 Auto response tomakeup source, and (startup & System Dilution Analysis for 2-ARP-SAF alarmsApproaching Rodinitiate boration power Malfunction the 4.7% Uprate Insertion Umit 12.5"before available operation). (FSAR Program. Rod Insertion Limit 0" Not expectedshutdown margin is 30 minutes -14.1.5). Mode I Manual to exceed 50%l t 2-ARP-FDFlost, du~ring refueling Over Temp Delta-T of time limitNIS Power Range(Mode 6). High Range 108%Mode 22-ARP-FDFNIS Source RangeFlux Level HINIS Power RangeLow Range 25%Mode 62-ARP-FCFSource Range HighFlux Level AtShutdownIf only 1 MD AFW 10 minutes Loss of CN-TA-03-126, 2-E-0, Step 7 Simulator NApump is available, after reactor Normal Rev. 1: Loss of RNO No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 43 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableprovide AFW flow trip. Feedwater Normal Feedwater/from the TD AFP to and Loss of All Loss of Non-the steam AC Power to Emergency ACgenerators. the Station Power Analysis forAuxiliaries Indian Point Unit 2(FSAR 14.1.9 (IPP) 4.7% Uprate.& 14.1.12).Isolate Letdown Line 30 minutes Accidental CN-CRA-03-66, 2-AOP-CVCS- Simulator NAafter VCT Failure after VCT Release -Rev. 0: Indian Point 1, Step 4.4failure. Waste Gas 2 -Failure of a(FSAR 14.2.3) Tank ContainingGaseous Activity(Stretch PowerUprate Program).During a SGTR, 60 minutes after Steam CN-CRA-03-48, 2-E-3, Step 21 Simulator NAterminate primary to SGTR. Generator Rev 1: Indian Pointsecondary break Tube Rupture Unit 2flow and prevent SG FSAR 14.2.4 Supplementaloverfill. Steam GeneratorTube RuptureAnalysis for 4.7%

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 44 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableUprate.CN-CRA-03-37,Rev 0: Indian PointUnit 2 (IPP) SteamGenerator TubeRupture T&HAnalysis for UprateProgram.CN-CRA-03-63,Rev. 1: Indian Point2 -SGTR Dosesfor Power Uprate.(a) Terminate (a) 15 minutes Rupture of a CN-CRA-05-58, Prudent Simulator NAauxiliary feedwater after SI signal. Steam Pipe Rev. 0: Indian Point Operatorflow to the faulted (FSAR 14.2.5) 2 Steamline Break Action Liststeam generator with open OAP-012following receipt of Feedwater Bypassthe SI signal for Lines.main steamline CN-CRA-03-20, 2-E-2, Step 4break (MSLB); and Rev. 0: Indian Pointmanually isolate No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 45 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablefaulted SG for those 2 Steamline BreakOutside Inside ContainmentContainment breaks Analysis for Stretchwhere steamline Power Uprate.isolation does not CN-CRA-03-19,occur automatically. Rev. 0: Indian PointUnit 2 SteamlineBreak OutsideContainmentAnalysis for 4.7%Stretch Uprate.Complete Transfer Prior to RWST During IP2 FSAR 6.2.2.1.4 2-ES-1.3 Simulatorto Cold Leg Level <3' for Transfer to Calculations:Recirculation prior to SI, RHR and Cold Leg GSX-00036-00stopping all pumps charging Recirculationtaking suction from Pumps, <2' for FMX-00089-00the RWST containmentspray pumps No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 46 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableOpen Central Within 30 Station IP-RPT-04-0081 1, 2-ECA-0.0, Not Required UncomplicatedControl Room minutes Blackout Rev. 0: Station Step 5 Actionscabinet doors following the (SBO) Event Blackout Finalonset of an Report. Not expectedSBO event. to exceed 50%of time limit.Open AFW Pump Within 30 Station IPP-RPT-04-0081 1, 2-ECA-0.0, Not Required UncomplicatedRoom Roll-up Door minutes Blackout Rev. 0: Station Step 5 Actionsto maintain room following the (SBO) Event Blackout Finaltemperatures less onset of an Report. Not expectedthan the 130OF limit. SBO event. IP-CALC-07-00143, to exceed 50%Rev. 1: Auxiliary of time limit.Feedwater PumpRoom TemperatureRiseAlternate AC Power Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Station IP-RPT-04-0081 1, 2-ECA-0.0, Walkthrough NA(Appendix R diesel) following the Blackout Rev. 0: Station Step 5 RNOto be available, onset of an (SBO) Event Blackout FinalSBO event. Report.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 47 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableIsolate high energy 110 seconds High Energy RPT-196-1, Rev. 2: 2-ARP-FCF, Walkthroughlines in PAB piping after receipt of Line Break EQ Program Window 2-11 ORpenetration area alarm -Based (HELB) Environmental Simulatorupon receipt of pipe on SGBD Analyses Parameters Report.pen. high break IP2-DBD-225,temperature alarm. presenting the Rev.1: High Energylimiting time. Line Break.(Isolationvalves to beclosed 3 minafter breakbased on: 40sec to tempalarm; 110 secoperatorresponse; 30sec for valveclosure]

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 48 of 79 CA'TACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableTrip Circulating 10 minutes Internal Plant Con Edison Letter 2-AOP- WalkthroughWater Pump or open from event Flooding to AEC, 12/18/72. FLOOD-i, ORTurbine Building roll- initiation -Analyses Con Edison Letter Step 4.100 Simulatorup door to prevent (Assumes 3 (FSAR 1.11.8) to NRC, 7/14/80. 1-ARP-002flooding of 480V min forSwitchgear Room. condenser pitalarm and 7min operatoraction].(a) Locally close (a) 30 minutes Seismic Event FMX-001 30-00, 2-ARP-SCF, WalkthroughLCV-1 158 (if to close LCV- Rev. 1: Indian Point Window 2-3automatic closure on 1158 following Unit 2 Impact ofCST level fails failure to auto- Pipe Breakfollowing seismic close. Downstream of 0-AOP-event) -to isolate (b) 4hrs to LCV-1 158. SEISMIC-1break flow to non- RHR cut-in IP-CALC-04-00648,seismic portion of after 1158 Rev. 0: IP2 ImpactCST supply line to closure, of Pipe BreakAFW. Downstream of(b) After 1158 LCV-1 158 at Powerclosure, cooldown to Uprate Conditions.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 49 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableRHR cut-in prior toCST emptying.Take operator action 10 minutes Overpressure FMX-00270-00, 2-ARP-SGF, Not Required Uncomplicatedto terminate cause after initiation Protection Rev. 0: NET-i177- Window 2-6, Actions inof RCS low of event. System (OPS) 01- Overpressure 1-6, 1-7 response totemperature -(FSAR Protection System alarmsoverpressurization 4.3.4.1) Thermal Hydraulicevent. Analysis, Setpoint Not expectedDevelopment and to exceed 50%Tech Spec Rev for of time limit,25 EFPY.Dispatch dedicated Immediately on When AFW is IP2 Calculation: 2-AOP-AIR-1 Not required Uncomplicatedoperator to control loss of N2 required. FIX-00030 2-ECA-0.0 Actions NotAux Feed Flow. Backup, in 30 expected tominutes on loss 2-E-0 exceed 50% ofof Instrument time limit.Air.During Mode 4 10 minutes During Mode 4 WCAP-12476 2-AOI-4.2.2 SimulatorLOCA, initiate after initiation LOCA event Step 5makeup to RCS with of event.SI Pump No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 50 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableStart of fire event 0 minutes Appendix R 2-AOP-SSD-1 Not Required NA -not anFire operatoractionReactor trip 5 minutes Appendix R 2-ONOP-FP-1 2-AOP-SSD-1 Walkthrough NAFire identifies significantfire that requiresentry into 2-AOP-SSD-1. ReferenceIP-CALC-05-01034for reactor trip time.Trip RCPs from 5 minutes Appendix R Preserve RCP seal 2-AOP-SSD-1 Walkthrough NACCR Fire integrity, assumingthat both sealinjection andthermal barriercooling may be lostdue to fire.ReferenceWestinghouse Tech No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 51 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableBulletin 04-22, Rev.1, and calculationIP-CALC-05-01034.Defeat power to 5 minutes Appendix R Promptly 2-AOP-SSD-1 Walkthrough NApressurizer PORVs Fire secure/preventand letdown path inventory loss via(LCV-459) from letdown path, and ifCCR 125V PORVs and blockdistribution panels valves arespuriously openeddue to cable faults.Action time is notbased explicitly ona calculation, but isexpected to beperformed promptlyfollowing manualreactor trip andprior to CCR exitinto 2-AOP-SSD-1.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 52 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableLocally confirm/trip 10 minutes Appendix R Same as "Trip 2-AOP-SSD-1 Walkthrough NARCPs at 6.9kV swgr Fire RCPs." Localconfirmation of tripat 6.9kV switchgearis needed in eventthat cable faultscause the CCRbreaker tripswitches to fail totrip the breakersremotely.Referencecalculation NEA-00031 for 10-minute RCP tripassumption.Isolate instrument air -15 minutes Appendix R Fails most AOVs in 2-AOP-SSD-1 Walkthrough NAto VC at IA-501 in Fire VC to desired/safepipe pen area or IA- position (e.g., fails739 in 480V swgr letdown pathroom closed, fails normal No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 53 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablecharging path open,etc.). CalculationI P-CALC-05-01034credits isolatingletdown within 15minutes, althoughthis is alreadyaccomplished byCCR distributionpanel breaker tripslisted above. Also,prevent loss ofnitrogen inventoryfor ASSSinstruments, if valveHCV-943 has beenspuriously openeddue to cable faults.Securing air to VCheader will ensureHCV-943 is failedclosed.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 54 of 79A'TACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableLocally confirm -15 minutes Appendix R In the event that 2-AOP-SSD-1 Walkthrough NAMSIV closure at Fire cable faults havecontrol racks in caused CCRABFP Bldg controls to fail tosecure MSIVs.If BOTH RCP CVCS 22 minutes, Appendix R IP-RPT-06-00022 2-AOP-SSD-1 Walkthrough NAseal injection AND assuming initial Fire (Applies to both IP2CCW thermal barrier seal leakoff and IP3); alsocooling have been rate is 3 gpm Westinghouse TBlost for the time 04-22, Rev. 1duration listed atright, do NOTrestore eithercooling function tothe seal packagesIsolate S/G 30 minutes Appendix R Maintain S/G 2-AOP-SSD-1 Walkthrough NAblowdown locally Fire inventory abovedryout conditions,pending restorationof AFW flow.Reference No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 55 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablecalculation NEA-00031 for 30-minute SGBDisolationrequirement. Notethat NEA-00031includes a 30-minute SGBDisolation case, butcalculation IP-CALC-05-01034only references a20-minute SGBDisolation time. Thelimiting time istaken to be 30minutes, andcalculation IP-CALC-05-01034should be updatedto reflect the 30-minute SGBD No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 56 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableisolationassumption.Start TDAFW pump 30 minutes Appendix R Prevent S/G dryout. 2-AOP-SSD-1 Walkthrough NAand align flow to Fire Per CalculationS/Gs. Alternatively, NEA-00031, dryoutif power is available, will occur instart one MDAFWP approximately 38minutes withoutmakeup.Assumption of AFWinitiation at 30minutes is used incalculation IP-CALC-05-01034.Open ASSS -30 minutes Appendix R Provide ASSS 2-AOP-SSD-1 Walkthrough NApneumatic line Fire monitoringisolation valves in instrumentation aspipe pen soon as possible.Take -30 minutes Appendix R As above. 2-AOP-SSD-1 Walkthrough NAcontrol/monitoring at FireFan House 90'_el. I III No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 57 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableASSS instrumentpanelStart Appendix R 60 minutes Appendix R Support recovery of 2-AOP-SSD-1 Walkthrough NADG Fire charging, CCW,SW, and ASSSinstruments assoon as possible.Limiting time is thatrequired for startinga charging pump(to preserve RCSinventory to withinthe indicating rangeof the pressurizerwide-rangechannel), by 75minutes. Seebelow.Line up 13kV swgr 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NAFire No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 58 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableTransfer 23 CHP to 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NAASSS feed FireClose 23 CHP 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NAbreaker on 12FD3 FireStart 23 CHP 60 minutes Appendix R Maximum allowable 2-AOP-SSD-1 Walkthrough NAFire analyzed time is 75minutes forrestoration of RCSmakeup, perCalculation IP-CALC-05-01034.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 59 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableTransfer 23 CCW <90 minutes Appendix R CHP can be 2-AOP-SSD-1 Walkthrough NAPump to ASSS feed Fire operated at fullspeed forapproximately 60minutes beforerestoring CCWcooling. The timeshown assumesthat one CHP hasbeen started at -60minutes, and thusmay be runningwithout cooling for-30 minutes beforeCCW is restored.Per 2-AOP-SSD-1,the alternative is toalign City Water tothe running CHPuntil CCW isrestored.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 60 of 79ATTACHMENT 4Unit 2 Time Critical Operator ActionsIP2 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableStart CCW pump <90 minutes Appendix R Initially, to provide 2-AOP-SSD-1 Walkthrough NAFire cooling to chargingpump, which canbe operated for upto 60 min at highspeed withoutcooling from CCWor City Water.Transfer 23 or 24 <90 minutes Appendix R Support restart of 2-AOP-SSD-1 Walkthrough NASWP to ASSS feed Fire SW as heat sink forCCW.Start one SWP <90 minutes Appendix R 2-AOP-SSD-1 Walkthrough NAFire No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 61 of 79ATTACHMENT 5Unit 3 Time Critical Operator Actions(Page 1 of 18)IP3 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableDetermine the cause 15 minutes Chemical and CN-TA-03-140, 3-ARP-009 Not required Uncomplicatedof dilution, isolate following Volume Rev. 1: Indian Point 3-AOP-CVCS- Actions inthe reactor water initiating event Control Unit 3 (INT) Boron 1 Step 4.102 response tomakeup source, and (startup & System Dilution Analysis for '1 Ste alarmsinitiate boration power Malfunction the Power Uprate 3Mobefore available operation). (FSAR 14.1.5) Program. Rod Insertion Low Not expectedshutdown mriisLimittoecd5030 minutes -Rod Insertion Low- toexceed50%lost. during refueling Low Umit of time limit(Mode 6)Mode I Manual(Mode 6) 13-ARP-n02OverTemp ATNIS Power RangeHigh RangeMode 23-ARP-002NIS Source RangeHigh Flux LevelNIS Power RangeLow RangeMode 63-ARP-004Source Range HighFlux Level AtShutdown No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 62 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableIf only 1 MD AFW 10 minutes Loss of CN-TA-03-143, Rev 3-E-0, Step 4 Simulator NApump is available, after reactor Normal 0: Loss of Normal RNOprovide AFW flow trip. Feedwater Feedwater/ Loss offrom the TD AFP to and Loss of All Non-Emergencythe steam AC Power to AC Power Analysisgenerators. the Station for Indian Point UnitAuxiliaries 3 (INT) Power(FSAR 14.1.9 Uprate Program.& 14.1.12)Isolate Letdown Line 30 minutes Accidental CN-CRA-03-29, 3-AOP-CVCS- Simulator NAafter VCT Failure. after VCT Release -Rev. 1: Indian Point 1, Step 4.3failure. Waste Gas 3 -VCT Rupture(FSAR 14.2.3) Doses.During a SGTR, 60 minutes Steam CN-CRA-03-77, 3-E-3, Step 24 Simulator NAterminate primary to after SGTR. Generator Rev. 1: Indian Pointsecondary break Tube Rupture 3 Stretch Powerflow and prevent SG FSAR 14.2.4 Uprateoverfill. SupplementalSteam GeneratorTube Rupture No: QAP-li1 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 63 of 79ATTACHMENT 5Unit 3 Time Critical Operator Actions1P3 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableAnalysis.CN-CRA-03-69,Rev. 1: Indian Point3 Stretch PowerUprate SteamGenerator TubeRupture (SGTR)Thermal HydraulicAnalysis.CN-CRA-03-25,Rev. 1: Indian PointUnit 3 -SteamGenerator TubeRupture Doses forStretch PowerUprate.(a) Terminate (a) 30 minutes Rupture of a CN-CRA-03-1 00, EOP Prudent Simulator NAauxiliary feedwater after SI signal Steam Pipe Rev. 1: Indian Point Operatorflow to the faulted (Inside VC (FSAR 3 Steamline Break Action List persteam generator MSLB). 14.2.5); and Inside Containment OAP-012following receipt of Steamline Analysis for Stretch No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 64 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Operator Action Times Assumed in FSAR AnalysisRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablethe SI signal for Break Power Uprate. 3-RO-1main steamline Containment CN-CRA-03-67, 3-E-2 Steps 1break (MSLB). Integrity Rev. 1: Indian Point and 4.b.(b) Manually (FSAR Unit 3 Steamlineterminate AFW to (b) 10 minutes 14.3.6). Break Outsidefaulted SG and close (Limiting Containmentfaulted SG MSIV for Outside VC Analysis for Stretchthose Outside MSLB). Uprate.Containment breaks CN-CRA-02-51,where steamline Rev. 1: Indian Pointisolation does not 3 -Steam Releaseoccur automatically. for Dose.CN-CRA-03-22,Rev. 1: Indian Point3 Main Steam LineBreak Doses forStretch PowerUprate.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 65 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableOpen Central Within 30 Station UFSAR Section EOP Setpoint: Not UncomplicatedControl Room minutes Blackout 8.2.3; and NRC Time .14 Required Actionscabinet doors following the (SBO) Event safety evaluation 3-ECA-0.0,onset of an report dated Step 7 Not expectedSBO event 12/23/91, "Safety to exceed 50%Evaluation of the of time limit.Indian Point 3Response to theStation BlackoutRule"Open AFW Pump Within 30 Station IP3-CALC-AFW- EOP Setpoint: Not UncomplicatedRoom doors to minutes Blackout 00418 and IP- Time .14 Required Actionsmaintain following the (SBO) Event CALC-07-00179. 3-ECA-0.0,temperatures less onset of an Calculations were Step 7 Not expectedthan the 130 OF limit SBO event required as a result to exceed 50%of NRC safety of time limit.evaluations to re-analyze AFW pumproom temperaturesduring SBO events.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 66 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableSee also IP-CALC-07-00193.Alternate AC Power Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Station Action is stated in 3-ECA-0.0 Simulator NA(Appendix R diesel) of the initiation Blackout IP3-DBD-307, Step 6.d RNOto be available, of a SBO event (SBO) Event "480V AC ElectricalDistributionSystem"; IP3-DBD-324, "Appendix RDiesel Generator";and NRC safetyevaluation reportdated 12/31/91 No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 67 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableBattery charger for Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Station IP3-DBD-307, 3-ECA-0.0, Simulator NAone division to be of the initiation Blackout "1 25V DC Electrical Step 31available, of a SBO event (SBO) Event DistributionSystem"; and NRC 3-AOP-safety evaluation 138KV-1,report dated Steps 4.26/4712/31/913-AOP-480V-1, Steps4.32/51/70Open CCR Rack Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> If only one NSE-00-3-064-ESS 3-RO-1, Step Not UncomplicatedDoors of losing 1 A/C CCR A/C unit 25.d Required Actions Notunit is operable. expected toApplies only exceed 50% ofduring EOPs. time limit.Dispatch dedicated Immediately on When AFW is IP3-CALC-MULT- 3-AOP-AIR-1 Not required Uncomplicatedoperator to control loss of N2 required 382 3-ECA-0.0 Actions NotAux Feed Flow. Backup, in 30 expected tominutes on loss 3-E-0 exceed 50% ofof Instrument time limit.Air No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 68 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableDuring Mode 4 Within 10 During Mode 4 WCAP-12456 3-ONOP- SimulatorLOCA, initiate minutes of LOCA event RCS-8makeup to RCS with Event Step 4SI PumpPerform SFP Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> During B.5.b NL-07-001 0-AOP-SEC-4 WalkthroughMakeup to IP3 SFP of decision to event NL-07-075 Table A.2-2using External use ExternalStrategy MakeupPerform SFP Spray Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> During B.5.b NL-07-001 0-AOP-SEC-4 Walkthroughto IP3 SFP using of decision to event NL-07-075 Table A.2-3External Strategy use ExternalSprayComplete Transfer Prior to RWST During IP3 FSAR 6.2.2 3-ES-1.3 Simulatorto Cold Leg Level <1.5' Transfer to IP3-CALC-CS-Recirculation prior to Cold Leg 02590stopping all pumps Recirculationtaking suction from IP3-CALC-SI-the RWST 00725 No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 69 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Selected Miscellaneous EventsRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableIsolate RWST Unmanned 46 Seismic NSE-99-3-035- 3-RO-1 Walkthrough NAPurification Loop minutes after Events; SFPC, Rev. 1, 3-SOP-SI-003initiation of Accidents RWST Purificationevent requiring Without ContinuousManned 15 RWST Manning Whileminutes after injection. Above Coldinitiation of ShutdowneventTake operator action 10 minutes Overpressure UFSAR 4.2.3, 3-ARP-010 Not Uncomplicatedto terminate cause after initiation Protection 4.3.4, and 7.3.2. Required Actions inof RCS low of event. System (OPS) response totemperature Event. (FSAR alarmsoverpressurization 4.3.4)event. Not expectedto exceed 50%of time limit No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 70 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableStart of fire event 0 minutes Appendix R 3-AOP-SSD-1 Not NA -not anFire Required operator actionReactor trip 5 minutes Appendix R 3-ONOP-FP-1 3-AOP-SSD-1 Walkthrough NAFire identifies significantfire that requiresentry into 3-AOP-SSD-1. ReferenceIP-CALC-06-00029for reactor trip time.Trip RCPs from 5 minutes Appendix R Preserve RCP seal 3-AOP-SSD-1 Walkthrough NACCR Fire integrity, assumingthat both sealinjection andthermal barriercooling may be lostdue to fire.ReferenceWestinghouse TechBulletin 04-22, Rev.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 71 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicable1, and calculationIP-CALC-06-00029.Defeat power to 5 minutes Appendix R Promptly 3-AOP-SSD-1 Walkthrough NApressurizer PORVs Fire secure/preventand letdown path inventory loss viafrom CCR 125V letdown path, and ifdistribution panels PORVs and blockvalves arespuriously openeddue to cable faults.Action time is notbased explicitly ona calculation, but isexpected to beperformed promptlyfollowing manualreactor trip andprior to CCR exitinto 3-AOP-SSD-1.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 72 of 79A'TACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableLocally confirm/trip 10 minutes Appendix R Same as 'Trip 3-AOP-SSD-1 Walkthrough NARCPs at 6.9kV swgr Fire RCPs." Localconfirmation of tripat 6.9kV switchgearis needed in eventthat cable faultscause the CCRbreaker tripswitches to fail totrip the breakersremotely.Referencecalculation IP-CALC-04-000766for 10-minute RCPtrip assumption.Locally confirm -15 minutes Appendix R In the event that 3-AOP-SSD-1 Walkthrough NAMSIV closure at Fire cable faults havecontrol racks in caused CCRABFP Bldg controls to fail tosecure MSIVs.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 73 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableIf BOTH RCP CVCS 22 minutes, Appendix R IP-RPT-06-00022 3-AOP-SSD-1 Walkthrough NAseal injection AND assuming initial Fire (Applies to both IP2CCW thermal barrier seal leakoff and IP3); alsocooling have been rate is 3 gpm Westinghouse TBlost for the time 04-22, Rev. 1duration listed atright, do NOTrestore eithercooling function tothe seal packagesIsolate S/G 30 minutes Appendix R Maintain S/G 3-AOP-SSD-1 Walkthrough NAblowdown locally Fire inventory abovedryout conditions,pending restorationof AFW flow.Referencecalculation IP-CALC-04-000766for 30-minuteSGBD isolationrequirement. Note No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 74 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablethat IP-CALC-04-00766 includes a30-minute SGBDisolation case, butcalculation IP-CALC-06-00029only references a20-minute SGBDisolation time. Thelimiting time istaken to be 30minutes, andcalculation IP-CALC-06-00029should be updatedto reflect the 30-minute SGBDisolationassumption.Start TDAFW pump 30 minutes Appendix R Prevent S/G dryout. 3-AOP-SSD-1 Walkthrough NAand align flow to Fire Per Calculation IP-S/Gs. Alternatively, CALC-04-000766, No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 75 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableif power is available, dryout will occur instart one MDAFWP approximately 37minutes withoutmakeup.Assumption of AFWinitiation at 30minutes is used incalculation IP-CALC-06-00029.Start Appendix R 60 minutes Appendix R Support recovery of 3-AOP-SSD-1 Walkthrough NADiesel Generator Fire charging, CCW,SW, and ASSSinstruments assoon as possible.Limiting time is thatrequired for startinga charging pump(to preserve RCSinventory to withinthe indicating rangeof the pressurizerwide-range No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 76 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicablechannel), by 75minutes. Seebelow.Energize MCC 312A 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NAfrom Appendix R FireDiesel GeneratorTransfer 31 or 32 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NACHP to ASSS feed FireClose selected CHP 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NAbreaker on MCC Fire31 2AStart selected 60 minutes Appendix R Maximum allowable 3-AOP-SSD-1 Walkthrough NAcharging pump Fire analyzed time is 75minutes forrestoration of RCSmakeup, perCalculation IP-CALC-06-00029.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 77 of 79ATTACHMENT 5Unit 3 Time Critical Operator ActionsIP3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableTransfer 32 CCW <90 minutes Appendix R CHP can be 3-AOP-SSD-1 Walkthrough NAPump to ASSS Fire operated at fullspeed forapproximately 60minutes beforerestoring CCWcooling. The timeshown assumesthat one CHP hasbeen started at -60minutes, and thusmay be runningwithout cooling for-30 minutes beforeCCW is restored.Per 3-AOP-SSD-1,the alternative is toalign City Water tothe running CHPuntil CCW isrestored.

No: OAP-115 Rev: 15OPERATIONS COMMITMENTS AND POLICY DETAILSPage 78 of 79ATTACHMENT 5Unit 3 Time Critical Operator Actions1P3 Target Completion Times for Appendix R FireRequired Action Required Time When TCOA Source Procedure Validation Basis forLimits Document that performs Method waivingthe required validation, ifTCOA applicableStart 32 CCW Pump <90 minutes Appendix R Initially, to provide 3-AOP-SSD-1 Walkthrough NAFire cooling to chargingpump, which canbe operated for upto 60 min at highspeed withoutcooling from CCWor City Water.Start 38SWP from <90 minutes Appendix R Support restart of 3-AOP-SSD-1 Walkthrough NAMCC 312A feed Fire SW as heat sink forCCW.Stop any running <120 minutes Appendix R EC-25886 3-AOP-SSD-1 Walkthrough N/ARHR Pumps Fire IP-CALC-10-00221,Avoid excessiveheat up of pump/seal ATTACHMENT 6Time Critical Operator Action Validation(Page 1 of 1)Unit: Date:Team Leader:Team Members:TCOA:JPM No. Sim. Scenario No.Initial Conditions:Malfunctions:Procedures Used:Additional Tcoa Information Or Guidance:Required Completion Time: Actual Completion Time:Resolution Of Discrepancies:1.0 WHEN complete, THEN FORWARD this Quality Record to the Operations DepartmentRecords Custodian.Team Leader Signature Date EnteyNuclear NortheastProcedure Use Is:RI ContinuousO Reference13 InformationControl Copy:_Effective Date: '31 f/2o3/i..Page 1 of 28)N AND/OR PtNG WATER S"XTION OFTHEApproved By:TANKRPO or Designee:PriiTeam 3CProcedure OwnerEDITORIAL REVISION RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 2 of 28REVISION SUMMARY(Page 1 of 1)1.0 REASON FOR REVISION1.1 Procedure Upgrade Project.1.2 Incorporate feedback IP3-11398.2.0 SUMMARY OF CHANGES2.1 Made various enhancements to maintain procedure format current(No side bars used) [Editorial 4.6.14].2.2 Changed reference to Plant Process Computer to PICS throughout[Editorial 4.6.13].2.3 Reworded 40 bullet in Note prior to Step 4.1.1 regarding the method of using atemporary alarm as opposed to changing the setpoint of the current alarm in PICS[Editorial 4.6.13].2.4 Reworded Step 4.1.1.5 to set a temporary alarm in PICS [Editorial 4.6.13].2.5 Reformatted Step 4.2.1.3, formerly Step 4.2.1.2d), as it is not a valve to be closed[Editorial 4.6.13].2.6 Reworded Step 4.2.4 by adding "for example" because there are other situationswhich require temporarily securing the evolution (IP3-11398) [Editorial 4.6.13].2.7 Reworded Step 4.2.5 (formerly Step 4.2.4.4) to remove specific reasons whyRWST purification may have been temporarily secured (IP3-11398) and addedvalve table for lineup (PUP) [Editorial 4.6.13].2.8 Reworded Step 4.4.1.4d) to remove temporary alarm in PICS [Editorial 4.6.13].2.9 Added Step 5.3.6 for 3-SOP-SFP-001 [Editorial 4.6.4].2.10 Added locations and grouped valves in Attachment 4 [Editorial 4.6.13].

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 3 of 28TABLE OF CONTENTSSection Title Page1.0 P U R P O S E ......................................................................................................................... 42.0 PRECAUTIONS AND LIMITATIONS ............................................................................ 43.0 PR ER EQ U IS ITES ....................................................................................................... 64 .0 P R O C E D U R E ................................................................................................................... 74.1 System Startup ............................................................................................... 74.2 N orm al O peration ........................................................................................... 104.3 Lowering RW ST Level .................................................................................. 124.4 System Shutdow n ......................................................................................... 154.5 Pumping RWST to CVCS HUT Using the Refueling Water Purification Pump.. 175 .0 R E F E R E N C E S ................................................................................................................ 196.0 RECORDS AND DOCUMENTATION .......................................................................... 19Attachments:ATTACHMENT 1, RWST PURIFICATION LINEUP ........................................................... 20ATTACHMENT 2, TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGEIN S TA LLE D ........................................................................................... 22ATTACHMENT 3, TEMPORARY RWST HEISE GAUGE SPECIAL LOG ........................... 25ATTACHMENT 4, VALVE ALIGNMENT FOR PUMPING THE RWST TO A CVCS HUT ........ 26 RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 4 of 281.0 PURPOSE1.1 This procedure establishes the requirements for recirculation and/or purification ofRWST.1.2 This procedure applies to recirculation and/or purification of RWST.2.0 PRECAUTIONS AND LIMITATIONS2.1 UNTIL LER-2012-002-00 is resolved, this procedure can NOT be performed inMODES 1, 2, 3 or 4. LER-2012-002-00 states the RWST is inoperablewhenever it is connected to the purification system due to non-qualifiedseismic piping.2.2 Precautions And Limitations2.2.1 AP across Spent Fuel Pit Filter should NOT exceed 20 psid.2.2.2 Refueling water flow should NOT exceed 100 gpm as indicated by FI-656(capacity of Refueling Water Purification Pump is approximately100 gpm).2.2.3 WHEN recirculating RWST, THEN an operating order should be writtenper EN-OP-102, "Protective and Caution Tagging, to close spent fuel pitpurification isolation valves AC-719A and AC-629 to prevent inadvertentdraining of RWST into Spent Fuel Pit.2.2.4 It is noted, RWST level should be maintained greater than 36 ft in theevent of a DBE/SI to ensure required RWST inventory is maintainedfollowing a seismic event.2.2.5 In Modes 1, 2, 3 and 4, either of the following steps SHALL beimplemented depending on whether dedicated operator manning forRWST recirculation/purification operations is desired OR NOT:2.2.5.1 IF unmanned operation desired,THEN Operations staff must have a heightened awareness toisolate the Purification Loop upon indications of a Design BasisEvent (DBE). The time should be less than 46 minutes, from thetime of the alarm to the isolation of the loop. {Reference 5.2.1).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 5 of 282.2.5.2 IF manned operation is desired, THEN a dedicated personSHALL be briefed on the NSE 99-3-035 SFPC. The dedicatedperson is required to be stationed on the 41 foot elevation in thePAB. (near the Refueling Water Purification Pump) Thededicated person is to isolate non-siesmic portions of thesystem (by securing the pump, closing AC-727A AND AC-727B), after occurrence of a Design Basis Event and/or IF aSafety Injection (DBE/Sl) occurs. This manual isolation isrequired to be completed within 15 minutes after receipt ofcomputer alarm.2.2.6 In Modes 1, 2, 3, and 4 other activities (excluding sampling), that mayeffect flow in or out of the RWST, will not be permitted simultaneouslywith the purification process, to preclude any masking of level changes{Reference 5.2.11.2.2.7 Operations personnel SHALL isolate purification of RWST upon thefollowing:* Control Room direction* SI signal Actuation (loss of normal PAB lighting and PurificationPump)* LT-920 instrument loop, PICS becomes inoperable* Seismic motion is suspected* Unidentified area flooding2.2.8 A test requirement for 3-PT-V055, Exercise Close of Valve AC-726B RWSTPurification Return Check Valve, has been established prior to placingRWST on Recirculation and/or Purification by Work Request (WR) test.2.2.9 WHEN in Modes 1, 2, 3, and 4, THEN RWST purification/recirculationSHALL not exceed 120 days (within any continuous 365 day period)provided LT-920 instrument loop, PICS is operable {Reference 5.2.1).2.2.10 WHEN in Modes 5 or 6, THEN there are no time or level instrumentationlimitations for RWST purification/recirculation {Reference 5.2.1).2.3 General Information2.3.1 IF any activity (i.e. Maintenance, 3-PT-SA43, RWST Instrument Check andCalibration Loop 920A/B), is performed after the PICS Lo Level alarm is setin this procedure (Step 4.1.1), THEN Step 4.1.1 must be re-performed toreset the PICS Low Level alarm setpoint.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 6 of 282.3.2 IF purification of RWST is unnecessary, THEN demineralizer and/or filtermay be bypassed in accordance with Attachment 1, RWST RecirculationLineup.2.3.3 WHEN topping off the RWST per 3-SOP-SI-002, Filling the Refueling WaterStorage Tank,THEN the following are essential to minimize overflow:* Communications and coordination with individual stationed at theoverflow stanchion pipe at lower WHUT pump room.* Flow should be limited to approximately 25 gpm or less2.3.4 Operator should walkdown to locate the purification loop isolation valvesand switch location to stop the pump.2.3.5 Operations Personnel SHALL possess the following in order to isolate thepurification loop:* Flashlight (Loss of lighting in PAB)* Keys (if responder exits PAB)* Radio (for instant communication with Control Room)* Respirator protection (if required by HP)3.0 PREREQUISITES3.1 Power is available to Refueling Water Purification Pump from MCC-37.3.2 Surveillance 3-PT-V055, Exercise Close of Valve AC-726B RWST Purification ReturnCheck Valve, has been completed satisfactorily prior to system startup.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 7 of 284.0 PROCEDURE4.1 System StartupNOTE* Recirculation and/or purification requires a RWST Low Level alarm supplementary to theexisting level indication, since the existing level indicators (LT-920/LI-920) are not asaccurate." Computer alarm (L0933A) provides timely warning in case of RWST/piping rupture.0 PICS monitor with RWST level on trend SHOULD have the alarm functionENABLED* Anticipate a flush of 200 to 300 gallons since makeup is > 5000 ppm." The intent is to slowly fill RWST to the overflow level (36.8'). Some overflow of RWST isexpected. Reaching the point of overflow provides a method to use a Temporary Alarmfor RWST low level (L0933A) in PICS." Care should be taken as the point of overflow is approached. The flow rate should bereduced to minimize the amount of water that will eventually enter WHUT sump whichwill then be processed.4.1.1 IF in Mode 1,2, 3, or 4, THEN:4.1.1.1 At the CRS, SRO, or BOP PICS Monitor,PLACE the RWST level on trend (display point L0933A).4.1.1.2 LOWER WHUT Pump Room sump level to minimum bytoggling the float switch as required.a) MONITOR sump level to determine the normal fill rate.4.1.1.3 Station a person at the WHUT Pump Room to MONITOR theoverflow into the WHUT Pump Room Sump who will notifyControl Room (CCR) at first indication of RWST overflow.* WHEN sump level rises faster than the normal fill rate,THEN the RWST is topped offAND NOTIFY CCR to secure the RWST fill4.1.1.4 SLOWLY FILL RWST to overflow (this should occur atapproximately 36.8') as per 3-SOP-SI-002, Filling The RefuelingWater Storage Tank.0 REFUELING WATER STORAGE TANK HI LEVEL alarm(3-ARP-012), should annunciate, makeup can continue,if desired RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 8 of 284.1.1.5 WHEN filling is complete (overflow is indicated at WHUT PumpRoom),THEN SET a Temporary Alarm on PICS System Page forRWST low level alarm (L0933A) at .3 ft. less than the indicatedoverflow level (e.g. 36.8'-.3'= 36.5' new alarm setpoint).4.1.1.6 IF Temporary Alteration TA-05-3-022 is installed,THEN PERFORM Attachment 2, TRACKING RWST LEVELALARMS WITH TEMPORARY HEISE GAUGE INSTALLED,Steps 1.0 and 2.0.4.1.2 VERIFY the following valves are LOCKED OPEN:* SI-846, RWST Outlet-SI/RHR Supply Line Isolation* SI-1862, RWST Return Line Isolation4.1.3 VERIFY the following valves are TAGGED CLOSED by a PTO:* AC-719A, Spent Fuel Pit Purification Loop Supply Isolation* AC-629, Spent Fuel Pit Purification Loop Return Isolation4.1.4 VERIFY AC-628, Refueling Cavity Draindown Filtration System OutletIsolation, is CLOSED (41' FSB, SFP Pump Room).4.1.5 NOTIFY Health Physics to conduct a survey on the spent resin transferline #157 prior to placing RWST on recirculation.Drawings 9321 -F-27503 and 9321 -F-27513 Sht No.2 may be used as reference.4.1.6 PERFORM Attachment 1, RWST Recirculation Lineup.4.1.7 VERIFY disconnect switch for Refueling Water Purification Pump onMCC-37 is CLOSED.4.1.8 POSITION AC-727B, Spent Fuel Pit Purification Loop To RWST Isolation,approximately three turns OPEN (34' Sl Pump Room).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 9 of 28CAUTIONIf NOT continuously manned, the recirculation or purification of RWST must be secured perP&L 2.2.6 AND integrity must be confirmed per Step 4.2.2, any time alarm is generated.(seismic OR PICS {L0933A}) to determine the alarm basis (i.e.spurious OF real).4.1.9 START Refueling Water Purification Pump using local controllermounted on wall by pump.NOTEStep 4.1.9.1 is N/A if RWST recirculation/ purification operations is manned by a dedicatedoperator.4.1.9.1 IF a PICS alarm is generated during the purification process,THEN:STOP operation AND verify system lineup integrity forany leaks. NOTIFY System Engineer for further directionORIF Temporary Alteration TA-05-3-022 is installed,THEN GO TO Attachment 2, TRACKING RWST LEVELALARMS WITH TEMPORARY HEISE GAUGEINSTALLED, Step 3.0CAUTIONDo NOT exceed 100 gpm as indicated on FI-656.4.1.10 ADJUST the following to establish a maximum flow of 100 gpm asindicated on FI-656:* AC-715, Spent Fuel Pit Filter Outlet Isolation, (15' PAB. SFP Filter)* AC-727B, Spent Fuel Pit Purification Loop To RWST Isolation,(34' SI Pump Room)4.1.11 IF AC-715 is closed to bypass filter per Attachment 1,THEN throttle AC-716 instead.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 10 of 284.2 Normal OperationNOTEThe following are symptoms for a Design Basis Event (DBE) which indicate RWST purificationSHALL be isolated:* CRS direction" Loss of normal lighting (lights & purification pump strip off bus on SI)* Site Page announcement SI has occurreds SI Signal Actuation (loss of normal PAB lighting and Purification Pump)* Local area flooding (Potential Pipe Break)a Actual unusual shaking or vibration indicating a seismic event is occurring4.2.1 IF in Mode 1, 2, 3, or 4, AND any sympton of a DBE occurs,THEN PERFORM the following within 46 minutes:4.2.1.1 STOP Refueling Water Purification Pump.4.2.1.2 CLOSE the following valves:a) AC-727A, Refueling Water Purification Pump SuctionIsolation (41' PAB, Refueling Water Purif. Pump).b) AC-725, Refueling Water Purification Pump DischargeIsolation (41' PAB, Refueling Water Purif. Pump).c) AC-727B, Spent Fuel Pit Purification Loop To RWSTIsolation (34' SI Pump Room).d) SI-841, Spent Fuel Pit Demineralizer To RWST Isolation(34' SI Pump Room).4.2.1.3 NOTIFY Control Room, RWST Purification Lineup has beenisolated.4.2.2 IF purification loop was isolated in Step 4.2.1,THEN the isolation valves SHALL NOT be reopened until the following:* Initial conditions for loop operation is restored* Any SI signal is cleared* Purification loop piping is inspected for damage and is found to bestill intact/undamaged* Dose Rates for the area are normal RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 11 of 28NOTEIt will take approximately 2-1/2 days to recirculate contents (350,000 gals.) of RWST.4.2.3 IF recirculating for purification of RWST,THEN CONTINUE recirculation flow until chemical analysis shows thatpurification is no longer needed.4.2.4 IF it is desired to temporarily secure RWST recirculation (for example, forfilling Accumulator(s) or SI, RHR or Containment Spray Pump run),THEN:4.2.4.1 STOP Refueling Water Purification Pump using local controller.4.2.4.2 POSITION valves per the following table:Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSEDDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED andPump Suction Isolation Purif. Pump LOCKEDSI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSEDRWST Isolation I I PAC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED andTo RWST Isolation LOCKED4.2.4.3 PERFORM Independent Verification for the following valves perOAP-019, Component Verification and System Status Control:Independent Verification Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSEDDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED andPump Suction Isolation Purif. Pump LOCKEDSI-841, Spent Fuel Pit Demineralizer To 34*SI Pump Room CLOSEDRWST IsolationAC-727B, Spent Fuel Pit Purification Loop 34'Sl Pump Room CLOSED andTo RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 12 of 284.2.5 IF it is desired to restore RWST recirculation after being temporarilysecured in Step 4.2.4, THEN:4.2.5.1 OPEN the valves in the following table:Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water OPENDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water OPENPump Suction Isolation Purif. PumpSI-841, Spent Fuel Pit Demineralizer To 34 SI Pump Room OPENRWST IsolationAC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room OPENTo RWST Isolation4.2.5.2 RESTART Refueling Water Purification Pump using localcontroller.4.3 Lowering RWST Level4.3.1 IF necessary to lower RWST Level (i.e. Maintenance acitivity),THEN VERIFY 5 Fan Cooler Units are operable.4.3.1.1 IF in Mode 1,2, 3 or4,THEN ENTER LCO 3.6.6 Action Statement.NOTE* Dedicated individual must remain near 32 Containment Spray Pump on 41' el. in PABuntil relieved or draindown completion. Dedicated individual must be briefed on this taskand provided with the following equipment:o Flashlighto Radio tuned to a frequency monitored by the Control Roomo Key to allow unlocking and closing SI-865B, if directed to do so by CRS.* Dedicated individual may perform the following steps.4.3.1.2 ASSIGN a dedicated individual to isolate RWST drain pathwhen required.4.3.2 DECLARE 32 CS Train inoperable.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 13 of 284.3.3 VERIFY SI-4, Pressure Test Connection Isolation, is CLOSED(suction of 32 Containment Spray Pump).4.3.4 REMOVE cap at SI-4.4.3.5 ATTACH a hose to SI-4.4.3.6 ROUTE open end of hose to local floor drain.4.3.7 THROTTLE OPEN SI-4 to achieve desired drain flow rate.4.3.8 IF any of the following noted events/activities occur,THEN CLOSE SI-4, Pressure Test Connection Isolation.* Loss of normal lighting (light strip off bus on an SI)" Actual unusual shaking or vibration indicating that a seismic event isoccurring* Site announcement that a Safety Injection has occurred* Local area flooding (potential pipe break)* Starting of 1 or more containment spray pumps* CRS direction4.3.8.1 IF SI-4 fails to close,THEN PERFORM either of the following to isolate RWST drainpath:a) ISOLATE drain line at SI-4 as follows:1) REMOVE hose from SI-4.2) INSTALL cap on SI-4.ORb) ISOLATE 32 CS Pump suction as follows:1) REQUEST the Control Room place 32 CS Pumpcontrol switch in PULLOUT.2) UNLOCK and CLOSE SI-865B, 32 Spray PumpSuction Line Isolation.4.3.9 IF directed by CRS to temporarily suspend RWST draining,THEN CLOSE SI-4, Pressure Test Connection Isolation.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 14 of 28NOTEIf dedicated individual is stationed near 32 Containment Spray Pump on 41' el. in PAB, thendedicated individual may be released following completion of Step 4.3.9.1.4.3.9.1 PERFORM Independent Verification of SI-4, Pressure TestConnection Isolation per OAP-01 9, Component Verification andSystem Status Control.4.3.9.2 WHEN directed by CRS to restart RWST draining, THEN:NOTE* Dedicated individual must remain near 32 Containment Spray Pump on 41' el. in PABuntil relieved or draindown completion. Dedicated individual must be briefed on this taskand provided with the following equipment:o Flashlighto Radio tuned to a frequency monitored by the Control Roomo Key to allow unlocking and closing SI-865B, if directed to do so by CRS.* Dedicated individual may perform the following steps.a) IF in Mode 1,2, 3 or 4,THEN ASSIGN a dedicated individual to isolateRWST drain path when required.b) THROTTLE OPEN SI-4, Pressure Test ConnectionIsolation, to achieve desired drain flow rate.4.3.10 WHEN desired RWST level is obtained,THEN CLOSE SI-4, Pressure Test Connection Isolation.4.3.10.1 REMOVE hose at SI-4.4.3.10.2 INSTALL cap at SI-4.4.3.10.3 PERFORM Independent Verification on SI-4, Pressure TestConnection Isolation (Closed and Capped) per OAP-019,Component Verification and System Status Control.4.3.11 IF SI-865B, 32 Spray Pump Suction Line Isolation, was manipulated inStep 4.3.8.1 b)2),THEN PERFORM Independent Verification of SI-865B, 32 Spray PumpSuction Line Isolation (Locked Open) per OAP-019 Component Verificationand System Status Control.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 15 of 284.3.12 DECLARE 32 CS Train operable.4.3.13 IF LCO 3.6.6 action statement was entered instep 4.3.1,THEN EXIT LCO 3.6.6 Action Statement.4.4 System Shutdown4.4.1 WHEN recirculation flow needs to be secured, THEN:4.4.1.1 STOP Refueling Water Purification Pump using local controller.4.4.1.2 POSITION valves per the following table:Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSEDDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED andPump Suction Isolation Purif. Pump LOCKEDSI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSEDRWST IsolationAC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED andTo RWST Isolation LOCKED4.4.1.3 PERFORM Independent Verification for the following valves perOAP-019, Component Verification and System Status Control:Independent Verification Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSEDDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED andPump Suction Isolation Purif. Pump LOCKEDSI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSEDRWST IsolationAC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED andTo RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 16 of 284.4.1.4 WHEN recirculation flow is no longer neededAND as directed by the CRS/SM or designee, THEN:a) REMOVE PTO tags from AC-719A and AC-629 andOPEN AC-719A and AC-629.b) INITIATE flow through the Spent Fuel Pit PurificationSystem as follows:1) VERIFY AC-710, Spent Fuel Pit DemineralizerBypass is closed (34' Ion Exchanger Valve gallery,upper level).2) OPEN AC-709, Spent Fuel Pit Demineralizer OutletIsolation (34' Ion Exchanger Valve gallery, lowerlevel).3) CLOSE AC-716, Spent Fuel Pit Filter Bypass(15' PAB SFP Filter).4) OPEN AC-705, Spent Fuel Pit Demineralizer InletIsolation (34' Ion Exchanger Valve gallery,upper level).5) OPEN AC-719B, Spent Fuel Pit Purification LoopReturn Isolation (SFP Heat Exchanger Room, 55'FSB).6) INITIATE flow through SFP demin and filter bythrottling AC-715, Spent Fuel Pit Filter OutletIsolation (15' PAB SFP Filter).6 Flow is NOT to exceed 100 gpmc) PERFORM Independent Verification of valves in steps4.4.1.4.b) 1) through 4.4.1.4.b) 6) per OAP-01 9,Component Verification and System Status Control.d) REMOVE Temporary Alarm on PICS System Page forRWST Lo level alarm (L0933A).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 17 of 284.5 Pumping RWST to CVCS HUT Using the Refueling Water Purification Pump4.5.1 VERIFY SI-846, RWST Outlet-SI/RHR Supply Line Isolation, is OPEN.4.5.2 CLOSE SI-1862, RWST Return Line Isolation.4.5.3 VERIFY Spent Fuel Pit Demin and Filter are NOT in service per3-SOP-SFP-001, Spent Fuel Pit Cooling and Purification System Operation.4.5.4 PERFORM Attachment 4, RWST Pumping to CVCS HUT Lineup.4.5.5 IF pumping to 31 CVCS HUT, THEN:4.5.5.1 OPEN CH- 1104, 31 CVCS Holdup Tank Inlet Isolation.4.5.5.2 OPEN CH-1 102, 31 CVCS Holdup Tank Vent Header Isolation.4.5.5.3 CLOSE CH-1211, 31 CVCS HUT Inlet From Evaporator FeedIon Exchangers Isolation.4.5.5.4 CLOSE CH-1298, 31 CVCS Holdup Tank Recirculation InletIsolation.4.5.6 IF pumping to 32 CVCS HUT, THEN:4.5.6.1 OPEN CH-1 119, 32 CVCS Holdup Tank Inlet Isolation.4.5.6.2 OPEN CH-1263, 32 CVCS Holdup Tank Vent Header Isolation.4.5.6.3 CLOSE CH-1 182A, 32 CVCS HUT Inlet From Evaporator FeedIon Exchangers Isolation.4.5.6.4 CLOSE CH-1297, 32 CVCS Holdup Tank Recirculation InletIsolation.4.5.7 IF pumping to 33 CVCS HUT, THEN:4.5.7.1 OPEN CH-1 120, 33 CVCS Holdup Tank Inlet Isolation.4.5.7.2 OPEN CH-1 264, 33 CVCS Holdup Tank Vent Header Isolation.4.5.7.3 CLOSE CH-1 182B, 33 CVCS HUT Inlet From Evaporator FeedIon Exchangers Isolation.4.5.7.4 CLOSE CH-1296, 33 CVCS Holdup Tank Recirculation InletIsolation.4.5.8 VERIFY disconnect switch for Refueling Water Purification Pump isCLOSED (on MCC-37).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 18 of 284.5.9 POSITION AC-727B, Spent Fue Pit Purification Loop to RWST Isolation,approximately three turns OPEN (34' SI Pump Room).4.5.10 Using the local controller mounted on wall by pump, START the RefuelingWater Purification Pump.CAUTIONDo NOT exceed 100 gpm as indicated on FI-656.4.5.11 ADJUST AC-727B, Spent fuel Pit Purification Loop to RWST isolation, toestablish a maximum flow of 100 gpm as indicated on FI-656.4.5.12 WHEN desired level in RWST is reached,THEN using the local controller, STOP Refueling Water PurificationPump.4.5.12.1 POSITION valves per the following table or as directed by theCRS:Valve Position TableValve Location Position InitialAC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSEDDischarge Isolation Purif. PumpAC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED ANDPump Suction Isolation Purif. Pump LOCKEDSI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSEDRWST IsolationAC-727B, Spent Fuel Pit Purification Loop 34'SI Pump Room CLOSED ANDTo RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 19 of 285.0 REFERENCES5.1 Commitment DocumentsNone5.2 Development Documents5.2.1 NSE 99-3-035 SFPC-Rev 1, RWST Purification Without ContinuousManning While Above Cold Shutdown.5.2.2 IP3-CALC-SI-03333-Rev 0, Engineering Evaluation of Postulated RWSTInventory Loss (ACTS 99-44077)5.3 Interface Documents5.3.1 EN-OP-102, Protective and Caution Tagging5.3.2 3-PT-SA43, RWST Instrument Check and Calibration Loop 920NB5.3.3 Drawing 9321 -F-27503, Flow Diagram Safety Injection System Sheet 25.3.4 Drawing 9321-F-27513, Flow Diagram Auxiliary Coolant System Sheet 25.3.5 OAP-019, Component Verification and System Status Control5.3.6 3-SOP-SFP-001, Spent Fuel Pit Cooling and Purification SystemOperation5.3.7 3-SOP-SI-002, Filling the Refueling Water Storage Tank5.3.8 3-ARP-012, Panel SJF, Cooling Water and Air6.0 RECORDS AND DOCUMENTATIONNONE RECIRCULATION ANDIOR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 20 of 28ATTACHMENT 1RWST PURIFICATION LINEUPPage 1 of 2VALVE11NUMBE VALVE DESCRIPTION LOCATION REQUIRED POSITIONNUMBE RIAC-704 PI-653 Isolation 34' PAB, Ion Exchr Vlv Gallery Upper CLOSEDLevelAC-710 Spent Fuel Pit Demineralizer Bypass 34' PAB, Ion Exchr VIv Gallery UpperLevel (1)AC-706 Spent Fuel Pit Demineralizer Vent 34' PAB, Ion Exchr Vlv Gallery Upper CLOSEDLevelAC-708A Spent Fuel Pit Demineralizer Resin Fill Isolation 34'LPAB, Ion Exchr Vv Gallery Upper CLOSEDLevelAC-708B Spent Fuel Pit Demineralizer To SRST Isolation 34'LPAB Ion Exchr Vlv Gallery Lower CLOSEDLevelAC-707A Spent Fuel Pit Demineralizer Outlet Drain 34' PAB, Ion Exchr Vlv Gallery Lower CLOSEDLevelAC-707B Spent Fuel Pit Demineralizer Primary Water Backwash 34' PAB, Ion Exchr VIv Gallery Lower CLOSEDIsolation LevelAC-709 Spent Fuel Pit Demineralizer Outlet Isolation 34' PAB, Ion Exchr VLv Gallery Lower (2)Level(1) CLOSED if flow through demineralizer is desired. OPEN if demineralizer is to be bypassed.(2) OPEN if flow through demineralizer is desired. CLOSED if demineralizer is to be bypassed.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 21 of 28ATTACHMENT 1RWST PURIFICATION LINEUPPage 2 of 2VALVE VALVE DESCRIPTION LOCATION REQUIREDNUMBER POSITIONSI-841 Spent Fuel Pit Demineralizer To RWST Isolation 34' PAB, SI Pump Room OPENAC-720 Spent Fuel Pit Filter Outlet Sample Isolation 15' PAB, SFP Filter CLOSEDAC-716 Spent Fuel Pit Filter Bypass 15' PAB, SFP Filter (3)AC-713A Spent Fuel Pit Filter Drain 15' PAB, SFP Filter CLOSEDAC-713B Spent Fuel Pit Filter Vent 15' PAB, SFP Filter (Behind Shield on CLOSEDTop of Filter) CLOSEDAC-711 Spent Fuel Pit Filter Inlet Isolation 15' PAB, SFP Filter OPENAC-712 PI-655 Isolation 15' PAB, SFP Filter OPENAC-714 PI-654 Isolation 15' PAB, SFP Filter OPENAC-715 Spent Fuel Pit Filter Outlet Isolation 15' PAB, SFP Filter (4)AC-717 FI-656 HI Side Root Isolation 15' PAB, SFP Filter OPENAC-718 FI-656 LO Side Root Isolation 15' PAB, SFP Filter OPENAC-66 Refueling Water Purification Pump Discharge Sample 41' PAB, Refueling Water Purif. Pump CLOSEDIsolationAC-727A Refueling Water Purification Pump Suction Isolation 41' PAB, Refueling Water Purif. Pump OPENAC-725 Refueling Water Purification Pump Discharge 41'PAB, Refueling Water Purif. Pump OPENIsolation 1 1e(3)(4)CLOSED if flow through filter is desired. THROTTLED if filter is to be bypassed.THROTTLED if flow through filter is desired. CLOSED if filter is to be bypassed.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-ýI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 22 of 28ATTACHMENT 2TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGE INSTALLED(Page 1 of 3)1.0 WHEN the Temporary Alteration TA-05-3-022 is installed AND the PICS RWST Level isestablished, THEN:1.1 OBTAIN Temporary Heise Gauge reading as follows:1.1.1 ENERGIZE the Temporary Heise Gauge readout module.1.1.2 OPEN Temporary Heise Gauge Instrument Isolation valve.1.1.3 WAIT 5 minutes for warm up.1.1.4 RECORD the Temporary Heise Gauge reading on Attachment 3,TEMPORARY RWST HEISE GAUGE SPECIAL LOG.2.0 WHEN the level indicated by the Temporary Heise Gauge is logged, THEN:2.1 DE-ENERGIZE the Temporary Heise Gauge readout module.2.2 CLOSE the Temporary Heise Gauge Instrument Isolation valve.3.0 IF PICS RWST Level alarms (i.e. 0.3 ft. reduction in RWST level), THEN:3.1 DISPATCH a NPO to determine if symptoms of a DBE are present.0 REFER to NOTE prior to Step 4.2.1 for symptoms3.1.1 IF symptoms of a DBE are present, THEN SECURE the RWST Purificationsystem per Section 4.2, Normal Operation.3.2 DISPATCH a NPO to the RWST to perform the following:3.2.1 ENERGIZE the Temporary Heise Gauge readout module.3.2.2 OPEN the Temporary Heise Gauge Instrument Isolation valve.3.2.3 WAIT 5 minutes for the Temporary Heise Gauge to warm up.3.2.4 RECORD the Temporary Heise Gauge reading on Attachment 3,TEMPORARY RWST HEISE GAUGE SPECIAL LOG.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 23 of 28ATTACHMENT 2TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGE INSTALLED(Page 2 of 3)3.2.5 INITIATE monitoring of Temporary Heise Gauge.3.2.5.1 NOTIFY the Control Room of the SAT condition.3.2.5.2 LOG the PICS RWST Level value every 15 minutes.3.2.6 IF the Temporary Heise Gauge reading is more than 6 inches below theinitial overflow level reading, THEN:3.2.6.1 SECURE the RWST Purification system per Section 4.2, NormalOperation.3.2.6.2 DETERMINE if symptoms of a DBE are present:0 REFER to NOTE prior to Step 4.2.1 for symptoms3.2.7 IF there is a Temporary Heise Gauge reading change (greater than plus orminus 1" change) from the initial overflow reading, THEN:3.2.7.1 NOTIFY the Control Room of an anomalous condition requiringinvestigation.3.2.7.2 IF the RWST level change is due to water usage,THEN FILL RWST to overflow level to restore the 6 inch margin.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 24 of 28ATTACHMENT 2TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGE INSTALLED(Page 3 of 3)3.2.7.3 IF the PICS RWST level drops another 0.5 ft, THEN:a) SECURE the RWST Purification system per Section 4.2,Normal Operation.b) DETERMINE if symptoms of a DBE are present.0 REFER to NOTE prior to Step 4.2.1 for symptomsc) IF the PICS level drops more than 0.3 ft in 30 minutes (i.e.,initial alarm reading or any 3 loggings), THEN:1) SECURE the RWST Purification system per Section 4.2,Normal Operation.2) DETERMINE if symptoms of a DBE are present.* REFER to NOTE prior to Step 4.2.1 for symptoms3.2.8 IF the PICS RWST Level alarm clears,THEN logging of PICS RWST Level may be terminated.4.0 IF the RWST Purification system was secured,THEN PERFORM the following prior to returning the system to service:4.1 VERIFY conditions which prompted securing RWST Purification NO longer exist.4.2 OBTAIN Temporary Heise Gauge reading as follows:4.2.1 ENERGIZE the Temporary Heise Gauge readout module.4.2.2 OPEN Temporary Heise Gauge Instrument Isolation valve.4.2.3 WAIT 5 minutes for warm up.4.2.4 RECORD the Temporary Heise Gauge reading on Attachment 3,TEMPORARY RWST HEISE GAUGE SPECIAL LOG.4.2.4.1 IF the Temporary Heise Gauge reading reading is NO more than1 inch lower than initial overflow reading, THEN PLACE thesystem in service per Section 4.2, Normal Operation.4.2.4.2 GO TO Attachment 2, Step 2.0.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 25 of 28ATTACHMENT 3TEMPORARY RWST HEISE GAUGE SPECIAL LOG(Page 1 of 1)DATE TIME RWST LEVEL INITIALS4 4 44 + 44 4 44 + 41- II I 4I I 4.I I 4.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 26 of 28ATTACHMENT 4VALVE ALIGNMENT FOR PUMPING THE RWST TO A CVCS HUT(Page 1 of 3)VALVE VALVE DESCRIPTION LOCATION REQUIREDNUMBER POSITIONSI-AOV-1813 CS Pumps Recirc to RWST CCR CLOSEDSI-MOV-842 SI Recirc to RWST CCR CLOSEDCH-350 Boric Acid Blender to RWST 73' PAB, Blender Cage CLOSEDOH-i 133 Retired Concentrates Holding Tank to CVCS HUTs 73' PAB, VCT Valve Room CLOSED & CAPPEDIsolationAC-704 PI-653 Isolation CLOSEDAC-705 Spent Fuel Pit Demineralizer Inlet isolation OPENAC-710 Spent Fuel Pit Demnineralizer Bypass 34' PAB, Ion Exch VIv Gallery OPENUpper Level OPENAC-706 Spent Fuel Pit Demineralizer Vent CLOSEDAC-708A Spent Fuel Pit Demineralizer Resin Fill Isolation CLOSEDAC-708B Spent Fuel Pit Demineralizer To SRST Isolation CLOSEDAC-707A Spent Fuel Pit Demineralizer Outlet Drain CLOSED34' PAB, Ion Exch Vlv GalleryAC-707B Spent Fuel Pit Demineralizer Primary Water Backwash Lower Level CLOSEDIsolationAC-709 Spent Fuel Pit Demineralizer Outlet Isolation CLOSEDSI-841 Spent Fuel Pit Demineralizer To RWST Isolation 34' PAB, SI Pump Room OPENIAC-727B Spent Fuel Pit Filter to RWST 34' PAB, SI Pump Room CLOSED RECIRCULATION ANDIOR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 27 of 28(Page 2 of 3)ATTACHMENT 4VALVE ALIGNMENT FOR PUMPING THE RWST TO A CVCS HUTVALVE VALVE DESCRIPTION LOCATION REQUIREDNUMBER VALVE DECRPIOPOSITIONAC-720 Spent Fuel Pit Filter Outlet Sample Isolation 15' PAB, SFP Filter CLOSEDAC-716 Spent Fuel Pit Filter Bypass 15' PAB, SFP Filter OPENAC-713A Spent Fuel Pit Filter Drain 15' PAB, SFP Filter CLOSEDAC-713B Spent Fuel Pit Filter Vent 15' PAB, SFP Filter (Behind Shield on CLOSEDAC-713B___Spent___Fuel__Pit__Filter__Vent__Top of Filter) CLOSEDAC-711 Spent Fuel Pit Filter Inlet Isolation 15' PAB, SFP Filter CLOSEDAC-712 PI-655 Isolation 15' PAB, SFP Filter OPENAC-714 PI-654 Isolation 15' PAB, SFP Filter OPENAC-715 Spent Fuel Pit Filter Outlet Isolation 15' PAB, SFP Filter CLOSEDAC-717 FI-656 HI Side Root Isolation 15' PAB, SFP Filter OPENAC-718 FI-656 LO Side Root Isolation 15' PAB, SFP Filter OPENAC-719A Spent Fuel Pit Purification Loop Supply Isolation SFP Pump Room CLOSEDAC-628 Refueling Cavity Draindown Filtration System Outlet SFP Pump Room CLOSEDIsolationWD-507 RCDT Pumps & Refueling Cavity Drain Pump CLOSEDDishcarge to VACCO Filter System Isol.AC-626 Refueling Cavity Draindown/RWST Inlet Isolation CLOSEDW D- 1733 RCDT Pumps

• Refueling Cavity Drain Pump Isolation 34' PAB, end of pipe chase by Mini OPENTo RWST ContainmentSI-958 RWST Recirc Pump to RWST CLOSEDWD-191 RCDT and Refueling Cavity Drain Pumps to RWST, CLOSEDCVCS HUTs, WHUTs & VACCO Filter System Isol RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24THE REFUELING WATER STORAGE TANK Page 28 of 28ATTACHMENT 4VALVE ALIGNMENT FOR PUMPING THE RWST TO A CVCS HUT(Page 3 of 3)VALVE ALVE DESCRIPTION LOCATION REQUIREDNUMBER V D L POSITIONNED-1111F Charging Pumps Leakage Collection Tank Transfer 41' PAB CLOSEDPumps Discharge to CVCS HUTsAC-727A Refueling Water Purification Pump Suction Isolation 41' PAB, Refueling Water Purif. Pump OPENAC-725 Refueling Water Purification Pump Discharge Isolation 41' PAB, Refueling Water Purif. Pump OPENAC-66 Refueling Water Purification Pump Discharge Sample 41' PAB, Refueling Water Purif. Pump CLOSEDIsolationCH-1247 Monitor Tank Pumps Discharge to CVCS HUTs 41' PAB, near Monitor Tank Pumps CLOSEDCH-1100 RCDT Pumps to CVCS HUTs 41' PAB, WHU Access OPENWD-1731 RCDT Pumps

• Refueling Cavity Drain Pump To WHUT 41' PAB, WHU Access CLOSEDTank IsolationCH-1 108 CVCS Waste Transfer Pumps Recirc to CVCS HUTs 33' PAB, WHUT Pump Room CLOSEDCH-1 109 CVCS Recirc Pump #31 Discharge 33' PAB, WHUT Pump Room CLOSEDCH-1104 CVCS HUT #31 Inlet 31 CVCS HUT, on catwalk CLOSEDCH-1 119 CVCS HUT #32 Inlet 32 CVCS HUT, on catwalk CLOSEDCH-1 120 CVCS HUT #33 Inlet 33 CVCS HUT, on catwalk CLOSED I Entergy CONDITION REPORT CR-IP3-2002-05092Originator: Petrosi,SamuelOriginator Group: Design Eng MgmtSupervisor Name: Smith, Mark ADiscovered Date: 12/20/2002 14:00Originator Phone: 2879Operability Required: NReportability Required: NInitiated Date: 12/20/2002 14:41Condition Description:Engineering Area For Improvement identified by the WANO team: The timeliness and quality of design changes hasaffected plant performance. Examples include: Elimination of Turbine Runback circuitry, BUSFPCS, Essential SW alignedto cool Circulating Water Pumps, and temporary cooling to the EDG's.Immediate Action Description:CR written and discussed with Design Engineering supervision.Suggested Action Description:Develop Design Change Quality performance indicators, establish Engineering Quality Review Team, perform independentS/A of Design Changes.REFERENCE ITEMS:Type CodeLTCRDescriptionTRENDING (For Reference Purposes Only):Trend TypeKEYWORDSKEYWORDSKEYWORDSTrend CodeKW-SELF-IDKW-MANAGEMENT EMPLOYEE INITIATEDKW-PLANT MODIFICATIONS Entergy ADMIN CR-IP3-2002-05092Initiated Date: 12/20/2002 14:41 Owner Group :Design Eng MgmtCurrent Contact: Joe ReynoldsCurrent Significance: C -NO CARBClosed by: Reynolds,Joseph A 11/10/2003 16:59Summary Description:Remarks Description:Closure Description:Per CA&A review, concur with the CR owners recommendation to close the CR. The issue was resolved, therefore this CRclosed.

Entergy I ASSIGNMENTS I CR-IP3-2002-05092Version: 1Significance Code: C -NO CARBClassification Code: NON-SIGNIFICANTOwner Group: Design Eng MgmtPerformed By: Sorrell,WilliamAssignment Description:CRR Apparent Cause Evaluation required12/23/2002 10:58 Entergy I CORRECTIVE ACTION I CR-IP3-2002-05092CA Number:IGroupI orl, ilaNameIAssigned By:Assigned To:Subassigned To :PLT-CARB-PORCDesign Eng MgmtSorrell,WilliamPetrosi,SamnuelOriginated By: Sorrell,William 12/23/2002 11:00:2(Performed By: Varas,Kelley A 1/17/2003 13:49:17Subperformed By:Approved By:Closed By: Varas,Kelley A 1/17/2003 13:49:17Current Due Date: 01/17/2003CA Type: DISP-APP CAUSEPlant Constraint: #NONECA Description:CRR Apparent Cause Evaluation requiredResponse:See Attached. Per SAM PETROSISubresponse :Closure Comments:Attachments:Response DescriptionCRR ResponseInitial Due Date: 01/13/2003CA Priority:

Attachment

HeaderDocument Name:ICR-IP3-2002-05092 CA-00001Document LocationlResponse DescriptionAttach Title:ICRR Response (REV 2) CONDITION REPORT RESPONSE (CRR) Page 1 of 2la. CR NO. lb.CA No. 2. Date CRR Assigned: 3. Assigned Department:CR 02-5092 CA #1 1/13/03 Design EngineeringEvaluation Type: Z Progran/Process [-D Equipment Problem4a. STATE THE PROBLEM (precisely identify the core issue)Engineering Area For Inprovement identified by the WANO tean: The timeliness and quality of design changes hasaffected plant performance. Examnples include: Elimination of Turbine Runback circuitry, BUSFPCS, Essential SWaligned to cool Circulating Water Pumps, and temporary cooling to the EDG's.4b Select one or more of the following that you think is the reason for the problem:F-1 Human Performance Issue E Individual Error E A Process/Programn Problem E Management IssueD Procedural Problem El Equipment Problem E] Supervision Problem E] Design Problem5. a) STATE THE CAUSE(S): 'WI-I" did the event occur?Background -The examples cited to support this "Area for Improvement" include: 1). Turbine Runback (CR 02-03514, Level A) -2). 50.59 Evaluation for BUSFPCS (CR 01-02796, Level B) -3). 50.59 Evaluation for EssentialSer-vce Water Supply to the Circulating Water Purmps (CR 01-03116, Level A) -4). 50.59 Evaluation for TemporaryAlteration to provide alternate coolhig to EDG Coolers (CR 02-03013, Level B).Each of these examnples have an associated Condition Report with root causes and corrective actions. Furthermore, CR01-03177 (Level B) was issued to investigate any potential weaknesses that may exist in the 50.59 process as a result ofevents 2 mad 3, above. The response to CR 02-03177 was prepared by an independent assessment team from thecorporate office. With respect to the overall question of a weakness in the 50.59 process, the assessment teanconcluded that there was no weakness in the 50.59 process per se, but rather a weakness in the designa change process.A. Timeliness -Only event I represents an examnple of lack of timeliness and is attributable to poor prionitization ofdesign change.B. Quality -Events 2 through 4 represent exanmples of poor quality of 50.59 evaluations due to individual technicalerrors caused by non-critical thought processes. Contributing to the deficiencies identified in events 2 and 3 waslack of recognition and/or failure to properly categorize activities that constitute a design change. Contributing tothe deficiency identified in event 4 was overconfidence since the Temporary Alteration had previously been usedwith similar recominendated actions and justifications.

6. Is there an Extent of Condition? -If NONE, So State: -provide rationaleExtent of conditions of the individual events are contained ill dteir associated Condition Report responses. Arecent assessment of "Modification Quality and Schedule Adherence" (which included 50.59 evaluations)perforned in the 4' Qtr. Of 2002 concluded that modifications are technically acceptable but opportunities existto improve their quality.Is there a Safety Impact (Industrial or Nuclear)? -If "yes" provide rationaleThe safety significance of the individual events is contained in their associated CR response. The conclusions inthe recent 2002, 4' Qtr. Assessment of "Modification Quality and Schedule Adherence" support the assertionthat there is no safety significance associated with the CR.7. CORRECTIVE ACTIONS:Utilize the 'Problem Resolution Sheet' and generate a corrective action for each action. Attach completed Problemsheet to this document.In addition to the corrective actions already identified in the aforementioned CR's (2002-03514, 01-03116, 02-03013 and01-03177) as well as the learning organization corrective actions identified in LOCR 2002-00079, the following correctiveactions are proposed:1. Establish ,and proceduralize anl Engineering Quality Review Tearn for reviewing engineering products.2. Perform an independent self-assessment of design changes. Also tie following enhancement is proposed.3. Develop Design Change / 50.59 Evaluation quality performance indicators.DEPARTMENT APPROVAL8.CARB Presentation Required? [see PLT notes] [F- YES H NOInvestigator (Print Name) Sam Petrosi Date 1/17/03 Ext 2879Sam Petrosi / 1/17/03Dept Mangr Date Safety Prog Adm (For Safety Issues)

Entergy CA DUE DATE EXTENSION CR-iP3-20o2-05092Corrective Action : CR-IP3-2002-05092 CA-00001Version: 1 Approved:YRequested Duedate: 01/17/2003 Previous Duedate: 01/13/2003Requested By: Varas,Kelley A 01/13/2003Approved By: Sorrell,William 01/13/2003Request Description:Extension is requested due to holiday vacations and integration activities which limited available resources. Extension isacceptable since corrective actions have been identified, and in the majority of cases implemented, for the specific examplescited in the CR. Per SAM PETROSI.Approved Description:acceptable for extension Entergy CORRECTIVE ACTION I CR-IP3-2002-05092CA Number:2IGroutVaaeIeNameAssigned By: Design Eng MgmtAssigned To: Design Eng MgmtSubassigned To : Design Eng I&C StaffVaras,Kelley APetrosi,SamuelOriginated By: Varas,Kelley A 1/17/2003 13:44:16Performed By: Petrosi,Samuel 10/29/2003 12:04:3SSubperformed By: Hill,John 10/20/2003 11:33:3(Approved By:Closed By: Petrosi,Samuel 10/29/2003 12:08:5:Current Due Date: 10/30/2003CA Type: LONG TERM CAInitial Due Date: 05/31/2003CA Priority:Plant Constraint: LTCA OTHERCA Description:Establish and proceduralize an Engineering Quality Review Team for reviewing engineering products.CA re-classified as Long Term in accordance with ENN-LI-102. Department Mgr. and Eng. Director approval obtained.(MLT CA&A 8/29/03)CA REFERENCE ITEMS:Type CodeLTCA-PROCESS/PROGRAMDescriptionResponse:The Design Review Committee, which is established per ENN-DC-1 15, will review a variety of engineering documents inaddition to the modifications required by the procedure. The DRC will grade each engineering document reviewed andissue performance indicators. The first DRC meeting took place on 10/24. This CA may be closed.Subresponse :Paperwork for LTCA and new due date were submitted 8/28/03. jhillNo new procedures are required. The existing IP2 EQRT process has been reactivated and will be utilized. Review ofmodification work will be performed by the DRB (design review board) as required per ENN procedures for the ER process.Closure Comments:CA complete. This CA may be closed.

Entergy I CA DUE DATE EXTENSION lCR-iP3-2002-05092Corrective Action : CR-IP3-2002-05092 CA-00002Version: I Approved:FRequested Duedate: 08/31/2003 Previous Duedate: 05/31/2003Requested By: Hill,John 05/29/2003Approved By: Petrosi,Samuel 05/29/2003Request Description:A quality review team/process has been developed but has not yet been proceduralized. Additional time needed to allowconsolidation of team for both IP2 and IP3 as well as put procedure in new site procedure format. There is no impact to theplant since this item is not associated with plant equipment deficiencies and the quality reviews are being performed.Approved Description:Accept extension. Procedures have been gathered from other sites/utilities and a new IPEC procedure will be developedbased on these. The new procedure will also include performance indicators. SWP 05/29/03 Entergy I CA DUE DATE EXTENSION 1CR-IP3-2002-05092Corrective Action : CR-IP3-2002-05092 CA-00002Version: 2 Approved:Requested Duedate: 10/30/2003 Previous Duedate: 08/31/2003Requested By: Hill,John 08/29/2003Approved By: Varas,Kelley A 08/29/2003Request Description:This extension request is needed since department resources have been alocated to other tasks such as mod closeouts.Extension is acceptable since this is a purely administrative task to help department performance. There are existingprocesses in place to serve this function such as mod review meetings, supervisor reviews and department self assessments.Approval for the extension request has been obtained by the engineering director as required by procedure. In addition, thisitem was also approved by the Director as a long term CA item. Therefore the new due date in excess of 150 days isacceptable. Director's approval obtained on 8/29/03.Approved Description:Extension Request Accepted ...this CA has been approved by the Director of Engineering to be recoded as a LT item.

Entergy I CORRECTIVE ACTION I CR-IP3-2002-05092CA Number:3GrouoINameIAssigned By: Design Eng MgmtAssigned To: Design Eng MgmtSubassigned To : Design Eng Civil/Str StaffVaras,Kelley APetrosi,SamuelDrake,Richard SOriginated By: Varas,Kelley APerformed By: Varas,Kelley ASubperformed By:Approved By:Closed By: Petrosi,Samuel1/17/2003 13:45:327/18/2003 14:18:337/23/2003 12:31:04Current Due Date: 07/29/2003 Initial Due Date: 05/31/2003CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:Perform an independent self-assessment of design changes. Also the following enhancement is proposed.Response:CR should not have been initiated.. .should have been an LO. Close CR to LO-IP3-03-00068 / CA # I. This LO has a duedate of 7/31/03.Subresponse :Closure Comments:Actions will be tracked via LO as stated in response. SWP 07/23/03 Entergy I CA DUE DATE EXTENSION I CR-IP3-2002-05092Corrective Action: CR-IP3-2002-05092 CA-00003Version: 1Requested Duedate: 07/29/2003Requested By: Drake,Richard SApproved By: Petrosi,SamuelApproved: FPrevious Duedate: 05/31/200305/29/200305/29/2003Request Description:have not had chance due to outage and reorganization to perform self assesment.Approved Description:Accept extension SWP 05/29/03 Entergy CORRECTIVE ACTION I CR-1P3-2002-05092CA Number:4GroupVaaeleINameIAssigned By: Design Eng MgmtAssigned To: Design Eng MgmtSubassigned To : Design Eng MgmtVaras,Kelley APetrosi,SamuelVaras,Kelley AOriginated By: Varas,Kelley A 1/17/2003 13:47:19Performed By: Petrosi,Samuel 5/29/2003 14:41:59Subperformed By: Varas,Kelley A 5/29/2003 14:14:59Approved By:Closed By: Varas,Kelley A 5/29/2003 14:49:33Current Due Date: 05/31/2003 Initial Due Date: 05/31/2003CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:Develop Design Change / 50.59 Evaluation quality performance indicators.Response:Accept sub-response. SWP 05/29/03Subresponse :Close this CA to CR 5092 / CA # 2 which will develop a procedure for an "Engineering Quality Review Team" which willalso include performance indicators with respect to the quality of engineering documents reviewed.Closure Comments:Accept for closure Entergy I CORRECTIVE ACTION I CR-IP3-2002-05092CA Number:5GroupINameIAssigned By: CA&A StaffAssigned To: Design Eng MgmtSubassigned To :Schmidt,George PPetrosi,SamuelOriginated By: Schmidt,George PPerformed By: Petrosi,Samuel10/30/2003 07:14:2(11/10/2003 16:09:0(Subperformed By:Approved By:Closed By: Reynolds,Joseph A11/10/2003 16:58:3'Current Due Date: 11/14/2003CA Type: CR CLOSURE REVIEWInitial Due Date: 11/14/2003CA Priority:Plant Constraint: #NONECA Description:CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION5.8.Response:All corrective actions are completed. However, som clarification will be provided. The Engineering Quality review Team isactually the Design Review Board, whose responsibilities are as outlined in ENN-DC-l 15. In addition, the ENN procedureallows for the DRC to review other documents other than MODS as deemed necessary. The quality review checklists thatare being used, have not been proceduralized. However, they will provide the performance Indicators needed. This CR maybe closed. SWP 11/10/03Subresponse :Closure Comments:Per CA&A review, noted the CR owner both clarrified the CA responses and recommended the CR for closure.

Entergy CONDITION REPORT I CR-IP3-2003-01166Originator: Cramer,Thomas A Originator Phone: 8213Originator Group: Operations Shift Manager Staff Operability Required: NSupervisor Name: Seaboldt,Jack J Reportability Required: NDiscovered Date: 03/12/2003 02:33 Initiated Date: 03/12/2003 04:07Condition Description:When the RWST purification lineup was secured per SOP SI-003, flow through the Spent fuel pit demineralizer from thespent fuel pit cooling loop was not initially established as expected. Two valves were shut that were not addressed in SOPSI-003. These valves, AC-705, Spent fuel pit demineralizer inlet, and AC-719B, purification loop return, were apparentlyshut when securing spent fuel purification per SOP SFP-001. There is a disconnect in the procedure flowpath from SOPSFP-001 and SOP SI-003 in that the restoration section of SOP SI-003 assumes that purification was taken out per SOPSI-003 and not SOP SFP-001. These valves were then opened per SOP SFP-001 and the COL SFP 1Immediate Action Description:Opened valves per SOP SFP-001 and COL SFP- I and submitted feedback to SOP SI-003 to check AC-705 and AC-719Bopen in the restoration from RWST purification section.Suggested Action Description:Fix SOP SI-003 as described in feedback IP3-6473. Also address feedback IP3-6474 on SOP-SFP-001 in the establishing ofpurification flow.EQUIPMENT:Tag Name Tag Suffix Name Component Code Process System CodeAC-705 VALVE 5 0012AC-719B VALVE 5 0012REFERENCE ITEMS:Type Code DescriptionDOC SOP SI-003DOC SOP SFP-00 1DOC Procedure FDBK # IP3-6473DOC COL SFP-1DOC Procedure FDBK # IP3-6474KEYWORD ProcedureKEYWORD Spent fuel pit purificationTEAM 3BTRENDING (For Reference Purposes Only):Trend Type Trend CodeKEYWORDS KW-SELF-IDKEYWORDS KW-CONFIGURATION CONTROLKEYWORDS KW-PROCEDURE ADEQUACY Entergy I ADMIN P3-2003-01166Initiated Date: 3/12/2003 4:07 Owner Group :Operations Proc StaffCurrent Contact:Current Significance: C -REVIEW & CORRECTClosed by: Jowitt,Roseann 3/14/2003 7:58Summary Description:Remarks Description:Closure Description:CLOSED TO ACTIONS TAKEN

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7Entergy ASSIGNMENTS CR-IP3-2003-01166Version: 1Significance Code: C -REVIEW & CORRECTClassification Code: NON-SIGNIFICANTOwner Group: Operations Proc StaffPerformed By: Sorrell,WilliamAssignment Description:Close to actions takenHistorical Human Performance Precursor03/13/2003 12:58 Entergy I CONDITION REPORT I CR-IP3-2003-03264Originator: Tagliamonte,Reid J Originator Phone: 7157392Originator Group: Tech Support Mgmt Operability Required: NSupervisor Name: LePere,John C Reportability Required: NDiscovered Date: 05/23/2003 14:52 Initiated Date: 05/23/2003 15:07Condition Description:During P.M. dissassembly of the spent fuel pit filter the upper and lower devider plate gaskets were found to be installedwrong. The bottom divider plate gasket was installed on the top of the devider plate. The hardware assembly waspre-assembled by the vendor PAL trinity with the gaskets and was installed as a retrofit unit to convert to a single filterelement. New divider plate gaskets were installed in the proper configuration during re-assembly. All other filter assembliesretrofitted with this hardware have been inspected during P.M. filter replacements and have not had this problem. Reactorcoolant filter, boric acid filter and the spent fuel pool skimmer filter.No further action is required.Immediate Action Description:Removed old gaskets and installed new divider plate gaskets in the proper orientation.Suggested Action Description:NoneEQUIPMENT:Ta2 Name Ta2 Suffix Name Component Code Process System Code0012 Entergy ADMIN I CR-IP3-2003-03264Initiated Date: 5/23/2003 15:07 Owner Group :Tech Radiation Protection MgmtCurrent Contact:Current Significance: C -REVIEW & CORRECTClosed by: Schmidt,George P 6/18/2003 7:44Summary Description:Remarks Description:Closure Description:Per CA&A review, concur with the CR owner's recommendation to close the CR. The issue was resolved or further tracking isvia the referenced lower tier process identifier, therefore this CR closed.

Entergy A S S I G N M E N T S I CR-IP3-2003-03264Version: 1Significance Code: C -REVIEW & CORRECTClassification Code: NON-SIGNIFICANTOwner Group: Tech Radiation Protection MgmtPerformed By: Sorrell,WilliamAssignment Description:Please evaluate and assign further corrective actions as required.Historical Human Performance Precursor05/27/2003 11:22 Entergy I CORRECTIVE ACTION I CR-IP3-2003-03264CA Number:IGroup.IName.IAssigned By: CRG/CARB/OSRCAssigned To: Tech Radiation Protection MgmtSubassigned To : Tech Radiation Protection StaffSorrell,WilliamLePere,John CLavera,RonaldOriginated By: Sorrell,William 5/27/2003 11:24:38Performed By: Lavera,Ronald 6/17/2003 15:21:48Subperformed By:Approved By:Closed By: Lavera,Ronald 6/17/2003 15:21:48Current Due Date: 06/17/2003 Initial Due Date: 06/17/2003CA Type: DISP -CORR ACTION CA Priority:Plant Constraint: #NONECA Description:Please evaluate and assign further corrective actions as required. Is there a Part 21 issue?Response:I spoke with Procurment Engineering regarding the need for a 1 OCFR2 1 notification. They agreed with our assessment that anotification was not required.The condition has been corrected. No other actions are required. This action can be closed.Subresponse :Closure Comments:

I Entergy I CONDITION REPORT ICR-IP3-2003-04700 ZOriginator: Post,Richard EOriginator Group: Operations Shift Manager StaffSupervisor Name: Smyers,CarlDiscovered Date: 08/15/2003 06:43Originator Phone: 8221Operability Required: NReportability Required: NInitiated Date: 08/15/2003 06:46Condition Description:This CR written for trending. During the unit trip of 8/14 SFP cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and temperaturewent from 100 F to a max of 114 F.Immediate Action Description:Suggested Action Description:REFERENCE ITEMS:Type CodeCRKEYWORDRX EVT REVIEWEDTEAM 3CDescriptionIP3-2003-04719ReactivityNon-eventTRENDING (For Reference Purposes Only):Trend TypeKEYWORDSRX MANANGEMENTMAINT RULETrend CodeKW-REACTIVITYRXM-NON-EVENTMR-FF Entergy I ADMIN I CR-IP3-2003-04700Initiated Date: 8/15/2003 6:46 Owner Group :Operations Shift ManagerCurrent Contact: R PerraCurrent Significance: D -ADMIN CLOSUREClosed by: Perra,Ralph T 10/8/2003 5:30Summary Description:Remarks Description:Closure Description:CR closed issue resolved.

Entergy A S S I G N M E N T S CR-IP3-2003-04700Version: 1Significance Code: D -ADMIN CLOSUREClassification Code: NON-SIGNIFICANTOwner Group: Operations Shift ManagerPerformed By: Harrison,Christine B 08/16/2003 13:39Assignment Description:8/16/03: Per CRG the evaluation of this CR will be included in the apparent cause evaluation assigned to Operations underCR-IP3-2003-04719.

Entergy CORRECTIVE ACTION CR-IP3-2003-04700CA Number: 1.... ... G ro u p ] :~~~ ........ ...... .... ... .. N e ..... ... ..Group INameAssigned By: P&S Outage Mgmt Sullivan,Brian AAssigned To: Operations Staff LibbyEarl RSubassigned To: Operations Shift Manager O'Donnell,Eugene EOriginated By: Sullivan,Brian A 8/15/2003 22:54:39Performed By: Haynes,James S 10/2/2003 13:19:30Subperformed By: Haynes,James S 10/2/2003 13:18:53Approved By:Closed By: Sullivan,Brian A 10/2/2003 17:21:22Current Due Date: 10/03/2003 Initial Due Date: 10/03/2003CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:This CA results from the post transient evaluation effort following the 8/14/03 U3 reactor trip. Reference is item 3 on page 30of the post trip eval."Operations to evaluate whether training or labeling of the spent fuel building exit pushbutton is necessary to informpersonnel that this pushbutton will not operate on a loss of power to the lighting distribution panel."Response:Close CA.Subresponse:Disscussed issue with U3 AOM, determined it is not necessary to label the spent fuel building exit pushbutton. Shift orderentry describing this issued issued 10/3/03. No further action required.Closure Comments:Closue is acceptable Entergy CORRECTIVE ACTION I CR-IP3-2003-04700CA Number:2Group.. ... ... INameIAssigned By: CA&A StaffAssigned To: Operations Shift ManagerSubassigned To :Schmidt,George PLibby,Earl ROriginated By: Schmidt,George P 10/6/2003 10:59:35Performed By: Haynes,James S 10/7/2003 16:08:05Subperformed By:Approved By:Closed By: Perra,Ralph T 10/8/2003 05:29:53Current Due Date: 10/21/2003 Initial Due Date: 10/21/2003CA Type: CR CLOSURE REVIEW CA Priority:Plant Constraint: #NONECA Description:CAT-D, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION5.8.Response:No further actions required. Close CR.Subresponse :Closure Comments:CA / CR can be closed based on the provided response.

Entergy I CONDITION REPORT lCR-IP3-2003-04719Originator: Sicard,Michael D Originator Phone: 6151Originator Group: Operations Mgmt Operability Required: NSupervisor Name: Ventosa,John A Reportability Required: NDiscovered Date: 08/15/2003 22:06 Initiated Date: 08/15/2003 22:09Condition Description:Condition identified during post transient evaluation. (Note: CR IP3-2003-04700 documents that this condition occurred.This condition report seeks an evaluation to determine if we need to change the design of the control system.)Spent Fuel Pool (SFP) cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the trip. Temperature in the SFP increased fromabout 100 deg F to a maximum of 114 deg F. SFP power was lost as well as power to 120VAC distribution panel 32(lighting circuit). The loss of this lighting panel, and not Rad Monitor # 5 (RM5) alarming (since trace was flat) aspreviously surmised, caused the SFP bldg door seals to engage and prevent operator entry until some time during the posttransient activities. When this lighting panel was restored and circuit was reset upon offsite power recovery, this caused thedoor seals to deflate allowing entry into the SFP building to manually restore SFP cooling.CR-IP3-2003-xxxxxx was written to pursue resolution of this issue.Immediate Action Description:None. This CR is to request the evaluation. From a review of the post transient evaluation (8/14/03, U3 reactor trip), it isapparent that the system is functioning per design.Suggested Action Description:REFERENCE ITEMS:Type Code DescriptionCR IP3-2003-04698CR IP3-2003-04700DOC Operations Procedure Feedback IP3-7067DOC Operations Procedure Feedback IP3-7067DWG 9321-LL-31313 Sheet 28DWG 9321-F-32043TRENDING (For Reference Purposes Only):Trend Type Trend CodeKEYWORDS KW-SELF-REVEALING Entergy ADMIN I CR-IP3-2003-04719Initiated Date: 8/15/2003 22:09 Owner Group :Operations Shift ManagerCurrent Contact: Joe REynoldsCurrent Significance: B -ACE & NO CARBClosed by: Reynolds,Joseph A 4/12/2004 17:25Summary Description:Remarks Description:Closure Description:Per CA&A Review, concur with the CR owners recommendation to close the CR. The issue was resolved, procedures revised,ER determined not needed, and therefore this CR closed.

Entergy I ASSIGNMENTS I CR-IP3-2003-04719Version: 1Significance Code: B -ACE & NO CARBClassification Code: NON-SIGNIFICANTOwner Group: Operations Shift ManagerPerformed By: Harrison,Christine BAssignment Description:08/16/2003 13:29 Entergy I CORRECTIVE ACTION I CR-IP3-2003-04719CA Number:IGroupINameIAssigned By: CRG/CARB/OSRCAssigned To: Operations Shift ManagerSubassigned To:Harrison,Christine BO'Donnell,Eugene EOriginated By: Harrison,Christine B 8/16/2003 13:31:28Performed By: Haynes,James S 9/12/2003 15:38:18Subperformed By:Approved By:Closed By: Perra,Ralph T 9/15/2003 03:16:30Current Due Date: 09/12/2003CA Type: DISP -ACEInitial Due Date: 09/08/2003CA Priority:Plant Constraint: #NONECA Description:Please perform apparent cause evaluation and assign further corrective actions as required. Include CR-IP3-2003-04700(Condition Description copied below) in your apparent cause evaluation assigned under this CR:"This CR written for trending. During the unit trip of 8/14 SFP cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and temperaturewent from 100 F to a max of 114 F."Response:See attached.Report did not include review for generic implications so CA-3 has been issued to perform this review.Subresponse :Closure Comments:ACE report was reviewed and it was determined the CR issue was adequately answered with the following exceptions.1) In previous IPEC OE's, concurrence from System Engineering on loss of SFP cooling is necessary.2) The explainations provided in the ACE report doesn't specifically provide a conclusion that an equipment or componentfailed, if there was a failure than an Equipment Failure Check list is required, resolve.3) A CA should be issued to Licensing for evaluation to the issue on bypassing the seal feature to see if it violates anydesign/tech spec issues/safety issues. CA 4 issued for resolution to these issues.Attachments:Response DescriptionPRSResponse DescriptionACE

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HeaderDocument Name:ICR-IP3-2003-04719 CA-OOOO1Document LocationJResponse Description,,Attach Title:FPRS Issue/Problem Resolution SheetINSTRUCTIONS:Complete this form for all investigations (Apparent Cause, Root Cause). This form may be used forbroke/fix reviews. Identify the issue(s) and corresponding corrective action(s). For all corrective actions,Condition Report Evaluation Type:Number: __ Root Cause X Apparent Cause __ Broke/FixCR-IP2-2003-04719 (optional)note whether the corrective action is "Preventive" or "Corrective". Identify any corrective actions that wereclassified as CAPRs or Long Term CAs (Long Term CAs cannot be completed in less than 150 days due toan identified process/program restriction). Reference any other tracking processes (e.g. duplicate CR, WorkOrder, MOD, ER, procedure feedback number, etc.) by their unique identifier to ensure tracking capabilityfrom this CR to the lower tier process. Document the date the CRG approved the closure to the othertracking process.TNTTr]D T1%/F[Nr1% U A T1' C DD TICTT1'7 A 'TT(Th.rfn C-rDI Urr T1J DD"AWDUQI1ITEM ISSUE / PROBELM SOLUTION / RESOLUTION TYPE Assigned Due CA ## [Note any WRs, MODs, other] CA Department dateI Loss of Spent Fuel cooling due Restore Spent Fuel cooling pump N/A Operations Comp N/Ato station blackout.PROPOSED/ASSIGNED CORRECTIVE ACTIONSISSUE / PROEM .. SOLUTION , RESOLUTION -- TYPE Assigned- e DateITEM # [Note any WRs, MODs, other] CA DepartmentSFB doors sealed on loss of Write ER for engineering to2 power preventing access to evaluate bypassing seal feature on a Perform Operations 10/08/03 2building, loss of power. CA

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HeaderDocument Name:ICR-1P3-2003-04719 CA-0o0o1Document LocationIResponse DescriptionAttach Title:FCEE IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~E terg( MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 1 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATECondition Report Number: Category Level: Assigned Department:CR-IP3-2003-04719 B OperationsCR-IP3-2003-04700Evaluation Type: Program/Process X Equipment ProblemSTATE THE PROBLEM:Spent Fuel Pool cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the Unit trip on 8/14/03. Powerwas lost to the Spent Fuel building as well as to 120vac distribution panel 32 (lighting circuit).The loss of this panel caused the Spent Fuel building door seals to inflate preventing operatorentry. When power to this panel was restored following offsite power recovery, the door sealsdeflated allowing entry into the building and subsequent restart of Spent Fuel Pool cooling.Temperature had increased from approximately 100 degrees to a maximum of 114 degrees.STATE THE CAUSE (S):At the time of the event, it was not clear why the doors were sealed since radiation monitor R-5was in a normal state with no alarms up. I&C was contacted to assist in researching why thedoor seals had inflated. It was not understood at the time that a lighting bus was the powersource for the solenoids that supplied air to the seals. Due to the complexity of the trip thatincluded a loss of all air in the station and the EDG's the only power supply to the plant, it tooksome time before all panels and busses were energized. Adding to this was the report that eventhough offsite power had been restored to the plant, it was not initially considered to be reliableand had to be loaded cautiously.CORRECTIVE ACTIONS:See Problem Resolution Sheet.Was the Event Classified as a Human Error or Station Reset? I Yes I X NoGENERIC IMPLICATIONS:

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~~Enterg( MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 2 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATESAFETY SIGNIFICANCE:During the event, there was never a challenge to Nuclear or Radiological safety. Duringrefueling outages when the core is offloaded, we routinely maintain temperatures in excess of130 degrees in the pool. Also, the "Spent Fuel Pit High Temp." alarm in the Control Roomremained clear during the event. This alarm requires operator action at 135 degrees. Also, iftemperature reaches 150 degrees, System Engineering must provide further guidance andresolution (as per ARP- 13)There was no impact on Industrial Safety.Previous IPEC Operating Experience:A search of PCRS revealed no CR since 2000 relating to loss of Spent Fuel Cooling.External (Industry) Operating Experience:A search on the INPO website using "Spent Fuel" was performed. Two noteworthy events werefound. At IP-3 on 5/8/0 1, SFP cooling was lost for twenty minutes due to a GFCI trippingcausing the BUSFPCS to shutdown (normal cooling OOS for MTC) during a refueling outagewith the core fully offloaded to the pool. At that time, temperature was being maintained at 151degrees and reached a high of 155 degrees in twenty minutes. This event was noted as NOTSIGNIFICANT and the risk of fuel damage was minimal.On 1/26/01 at the Zion Station, SFP cooling was lost for 1.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> during a loss of all ACpower to their Spent Fuel nuclear island. Temperature increased only 1 degree in that time.Calculated time to boil was 3.5 days. This event was rated as NOT SIGNIFICANT.NARRATIVE, EVENT DESCRIPTION:Spent Fuel Pool (SFP) cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after a Unit trip with acomplete loss of offsite power on 8/14/03. Temperature in the SFP increased from about 100deg F to a maximum of 114 deg F. SFP power was lost as well as to 120VAC distribution panel32 (lighting circuit). The loss of this lighting panel, and not Rad Monitor # 5 (RM5) alarming(since trace was flat and no alarm condition existed) as previously surmised, caused the SFPbuilding door seals to inflate and prevent operator entry until some time during the post transientactivities. When this lighting panel was restored and circuit was reset upon offsite powerrecovery, the door seals deflated allowing entry into the building to manually restore SFPcooling.Was the event caused by, or identify, an equipment or component __failure? IYes I X NOIF Yes, THEN, coordinate with the appropriate Engineering Department organizations tocomplete the Equipment Failure Checklist form (Attachment 18 of IP-SMM-LI/CAA-100)and attach the completed form to the CR response. Discuss the equipment failure reviewresults in the narrative section of this report.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~ntergy MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 3 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATECARB Presentation Required? (See CRG notes on YES X NOassigned CA in PCRS)INVESTIGATOR Date report completed Phone Extension of InvestigatorPrint NameE. Gurina December 13 2012 736-8281 Entergy I CA DUE DATE EXTENSION [CR-IP3-2003-04719Corrective Action : CR-IP3-2003-04719 CA-00001Version: 1 Approved:Requested Duedate: 09/12/2003 Previous Duedate: 09/08/2003Requested By: Haynes,James S 09/08/2003Approved By: Lewandowski,Paul R 09/08/2003Request Description:Acceptable because spent fuel cooling has been restored.Necessary to extend because responsible individual has been away from the station and will return 9/8/03. Report iscomplete, however, request additional time to ensure proper corrective actions are issued.Ops Tech Support supervisor approves of extension.Approved Description:Per CA&A review, the request does not pose a safety hazard, interim controls are not required, supervisor approval hasbeen obtained, and the extension does not exceed the 30-day limit. Therefore, the extension is approved.

Entergy I CORRECTIVE ACTION ICR-IP3-2003-04719CA Number:2GroupHansJaeINameIAssigned By: Operations StaffAssigned To: Operations StaffSubassigned To:Haynes,James SEtzweiler,Joan FOriginated By: Haynes,James S 9/12/2003 14:35:17Performed By: Etzweiler,Joan F 10/8/2003 17:05:33Subperformed By:Approved By:Closed By: Etzweiler,Joan F 10/8/2003 17:05:33Current Due Date: 10/08/2003CA Type: PERFORM CAInitial Due Date: 10/08/2003CA Priority:Plant Constraint: #NONECA Description:Write ER for engineering to evaluate allowing the ability to bypass Spent Fuel Building door seals under conditions similarto those of this CR (not caused by high rad).Response:As a result of walking down the IP3 Fuel Storage Building (FSB) with the Operations Support Manager, the subject of thisCondition Report was broken down into several issues:I -- Safety of personnel who might be in the building when 120 Vac power is lost. Knowledge, signage, lighting,communications equipment to allow them to get out safely. Safety (x5080) advised that ability to quickly leave the buildingis a life safety code issue. Safety accepts a Corrective Action (CA #5) with a two month due date to provide short and longterm recommendations.2 -- Re-entry to restore forced cooling of the Spent Fuel Pit (SFP). More urgent when fuel has recently been dischargedfrom the Reactor.3 -- Long-term resolution of both above issues would include consideration of a design change. Possibilities includede-pressurization on loss of power, automatic back-up power, or unpowered manual override of seal pressurization.Licensing advised that IP3 Tech. Spec. Amendment #215 removed the requirement for FSB air filtration following apostulated Fuel Handling Accident. The basis for the Amendment was the new IP3 source term. The pressurized door sealswere intended to ensure that negative pressure was maintained in the FSB, so that all exiting air would be forced throughthe filters. Because the licensing basis was changed to remove the requirement for FSB air filtration, it is expected that thedesign can be changed to facilitate personnel exit. A follow-up Corrective Action (CA #6) is assigned for OperationsSupport to work with Safety, Engineering and Licensing to determine whether a design change is warranted, and if so, todevelop a specific design change recommendation in an Engineering Request.Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2003-04719CA Number:3GroupHansJaeINameIAssigned By: Operations StaffAssigned To: Operations StaffSubassigned To:Haynes,James SHaynes,James SOriginated By: Haynes,James S 9/12/2003 15:40:47Performed By: Haynes,James S 9/18/2003 13:36:03Subperformed By:Approved By:Closed By: Haynes,James S 9/18/2003 13:36:03Current Due Date: 09/18/2003 Initial Due Date:CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:Review ACE report for generic implications and attach revised report.09/18/2003Response:The automatic door sealing feature is not installed at Unit 2 Fuel Storage building. ACE report updated and attached.Subresponse :Closure Comments:Attachments:Response DescriptionACE rev 1

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HeaderDocument Name:ICR-IP33-2003-04719 CA-00003Document LocationIResponse DescdptionAttach Title:lACE rev 1 IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0Entergy MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 1 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATECondition Report Number: CaBegory Level: Assigned Department:CR-IP3-2003-04719 B OperationsCR-IP3-2003-04700Evaluation Type: Program/Process X Equipment ProblemSTATE THE PROBLEM:Spent Fuel Pool cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the Unit trip on 8/14/03. Powerwas lost to the Spent Fuel building as well as to 120vac distribution panel 32 (lighting circuit).The loss of this panel caused the Spent Fuel building door seals to inflate preventing operatorentry. When power to this panel was restored following offsite power recovery, the door sealsdeflated allowing entry into the building and subsequent restart of Spent Fuel Pool cooling.Temperature had increased from approximately 100 degrees to a maximum of 114 degrees.STATE THE CAUSE (S):At the time of the event, it was not clear why the doors were sealed since radiation monitor R-5was in a normal state with no alarms up. I&C was contacted to assist in researching why thedoor seals had inflated. It was not understood at the time that a lighting bus was the powersource for the solenoids that supplied air to the seals. Due to the complexity of the trip thatincluded a loss of all air in the station and the EDG's the only power supply to the plant, it tooksome time before all panels and busses were energized. Adding to this was the report that eventhough offsite power had been restored to the plant, it was not initially considered to be reliableand had to be loaded cautiously.CORRECTIVE ACTIONS:See Problem Resolution Sheet.EWas the Event Classified as a Human Error or Station Reset? Yes IX NoGENERIC IMPLICATIONS:The automatic door sealing feature is not installed at Unit 2 Fuel Storage building.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0fEnh ) MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 2 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATESAFETY SIGNIFICANCE:During the event, there was never a challenge to Nuclear or Radiological safety. Duringrefueling outages when the core is offloaded, we routinely maintain temperatures in excess of130 degrees in the pool. Also, the "Spent Fuel Pit High Temp." alarm in the Control Roomremained clear during the event. This alarm requires operator action at 135 degrees. Also, iftemperature reaches 150 degrees, System Engineering must provide further guidance andresolution (as per ARP-13)There was no impact on Industrial Safety.Previous IPEC Operating Experience:A search of PCRS revealed no CR since 2000 relating to loss of Spent Fuel Cooling.External (Industry) Operating Experience:A search on the INPO website using "Spent Fuel" was performed. Two noteworthy events werefound. At IP-3 on 5/8/01, SFP cooling was lost for twenty minutes due to a GFCI trippingcausing the BUSFPCS to shutdown (normal cooling OOS for MTC) during a refueling outagewith the core fully offloaded to the pool. At that time, temperature was being maintained at 151degrees and reached a high of 155 degrees in twenty minutes. This event was noted as NOTSIGNIFICANT and the risk of fuel damage was minimal.On 1/26/01 at the Zion Station, SFP cooling was lost for 1.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> during a loss of all ACpower to their Spent Fuel nuclear island. Temperature increased only 1 degree in that time.Calculated time to boil was 3.5 days. This event was rated as NOT SIGNIFICANT.NARRATIVE, EVENT DESCRIPTION:Spent Fuel Pool (SFP) cooling was lost for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after a Unit trip with acomplete loss of offsite power on 8/14/03. Temperature in the SFP increased from about 100deg F to a maximum of 114 deg F. SFP power was lost as well as to 120VAC distribution panel32 (lighting circuit). The loss of this lighting panel, and not Rad Monitor # 5 (RM5) alarming(since trace was flat and no alarm condition existed) as previously surmised, caused the SFPbuilding door seals to inflate and prevent operator entry until some time during the post transientactivities. When this lighting panel was restored and circuit was reset upon offsite powerrecovery, the door seals deflated allowing entry into the building to manually restore SFPcooling.Was the event caused by, or identify, an equipment or component __failure?Yes X NOIF Yes, THEN, coordinate with the appropriate Engineering Department organizations tocomplete the Equipment Failure Checklist form (Attachment 18 of IP-SMM-LI/CAA-100)and attach the completed form to the CR response. Discuss the equipment failure reviewresults in the narrative section of this report.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0MANAGEMENT ADMINISTRATIVE PROCEDUREMANUALINFORMATIONAL USEATTACHMENT 9.12 PAGE 3 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATECARB Presentation Required? (See CRG notes on YES X NOassigned CA in PCRS)INVESTIGATOR Date report completed Phone Extension of InvestigatorPrint NameE. Gurina December 13. 2012 736-8281 Entergy CORRECTIVE ACTION CR-IP3-2003-04719CA Number: 4Group .NameAssigned By: CA&A Mgmt Perra,Ralph TAssigned To: Operations Shift Manager O'Donnell,Eugene ESubassigned To :Originated By: Perra,Ralph T 9/15/2003 03:22:36Performed By: Main,Dennis E 9/22/2003 14:43:57Subperformed By:Approved By:Closed By: Perra,Ralph T 9/23/2003 03:45:54Current Due Date: 09/22/2003 Initial Due Date: 09/22/2003CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:CA I ACE report was reviewed and it was determined the following issues require resolution.1) In previous IPEC OE's, concurrence from System Engineering on loss of SFP cooling is necessary.2) The explainations provided in the ACE report doesn't specifically provide a conclusion that an equipment or componentfailed, if there was a failure than an Equipment Failure Check list is required, resolve.3) A CA should be issued to Licensing for evaluation to the issue on bypassing the seal feature to see if it violates anydesign/tech spec/safety issues.Response:1) E-Plan was actuated within 45 minutes of event. This would man the TSC and System Engineering would be availableto provide advice just like any emergency event.2) As stated in the ACE there was no equipment failure. Seals were inflated when solenoid valves lost power due to theblackout. Power was restored when off-site power was available and stable and time permitted. Since the SFP did not haveany freshly irradiated fuel in it, there was no excessive heat load and plenty of time was available to restore cooling.3) Licensing has to review all modifications prior to implementation. A separate CA to licensing is not necessary since thenormal mod process will capture their comments on whether this modification would violate any design, Tech Spec, orsafety issue.Subresponse :Closure Comments:CA can be closed based on the provided response.

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719CA Number:5GroupINameIAssigned By: Operations StaffAssigned To: Safety StaffSubassigned To :Etzweiler,Joan FStockwell,Lisa LOriginated By: Etzweiler,Joan FPerformed By: Bianco,ScottSubperformed By:Approved By:CIn~ted Rv" F.10/8/2003 16:45:5412/10/2003 13:42:M~12/10/2003 14:10:21....... B Main.. De ni E....Current Due Date: 12/10/2003CA Type: PERFORM CAInitial Due Date: 12/10/2003CA Priority:Plant Constraint: #NONECA Description:See CR IP3-2003-04698, Post Transient Review Report for the 8/14/03 plant trip. If someone is inside the IP3 Fuel StorageBuilding (FSB) when loss of 120 Vac power occurs, the building will be dark and the doors will be pressuized closed. Theemergency door push button does not work upon loss of power.Walkdown this building, assess the personnel safety issues involving personnel egress, and recommend corrective actions toOperations Support staff.(Note: The x5080 Safety Hotline staffer approved the assignment of this action and due date.)Response:There are several issues raised in this CA:? During a loss of 120 Vac power the Fuel Storage Building will not be dark since there are eight Emergency Lights in theUnit 3 Fuel Storage Building.Per discussion with Zvi Eisenberg? It is also expected that the exhaust fan will also be lost and there for the door will be easy to operate. In addition if forsome reason the exhaust fan is not lost there should only be about ?" of water negative pressure on the door and someoneshould be able to operate it.? Telephones will also be operable so personnel could call the CCR and Operations could secure the exhaust fan ifnecessary.Subresponse:Closure Comments:Close CA Entergy CORRECTIVE ACTION CR-IP3-2003-04719CA Number: 6Group I NameAssigned By: Operations Staff Etzweiler,Joan FAssigned To: Operations Staff Etzweiler,Joan FSubassigned To:Originated By: Etzweiler,Joan F 10/8/2003 17:03:37Performed By: Etzweiler,Joan F 1/6/2004 13:17:24Subperformed By:Approved By:Closed By: Etzweiler,Joan F 1/6/2004 13:17:24Current Due Date: 01/06/2004 Initial Due Date: 01/06/2004CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:Loss of 120 Vac to the lighting panel that powers the FSB door pressurization SOVs results in the following concerns:1 -- Safety of personnel who might be in the building when 120 Vac power is lost. Knowledge, signage, lighting,communications equipment to allow them to get out safely. Safety (x5080) advised that ability to quickly leave the buildingis a life safety code issue. Safety accepts a Corrective Action with a two month due date to provide short and long termrecommendations.2 -- Re-entry to restore forced cooling of the Spent Fuel Pit (SFP). More urgent when fuel has recently been dischargedfrom the Reactor.Long-term resolution of both above issues would include consideration of a design change. Possibilities includede-pressurization on loss of power, automatic back-up power, or unpowered manual override of seal pressurization.Licensing advised that IP3 Tech. Spec. Amendment #215 removed the requirement for FSB air filtration following apostulated Fuel Handling Accident. The basis for the Amendment was the new IP3 source term. The pressurized door sealswere intended to ensure that negative pressure was maintained in the FSB, so that all exiting air would be forced throughthe filters. Because the licensing basis was changed to remove the requirement for FSB air filtration, it is expected that thedesign can be changed to facilitate personnel exit.Obtain input from Safety, Engineering and Licensing as needed, determine whether a design change is warranted, and if so,initiate an Engineering Request for the design change.

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719Response:Reviewed documents and obtained input from various groups and as follows:Reviewed drawings to verify that:The IP3 FSB door seal SOVs are de-energized to inflate seals.The elev. 95' door emergency operating push button requires power to defate the door seal.The SOV and push-button power is from circuit 6 of 120 VAC Distributiion Panel 32, powered from Lighting Bus 32,powred from Lighting Transformer 32 on Bus 6A.References: 9321-LL-31313 Sheet 28 rev 11 and 9321-F-32043 rev 43.Reviewed Operations Procedures:SOP SFP-001, rev 19, Spent Fuel Pit Cooling and Purification System OperationONOP-SFP-l, rev 12, Loss of Spent Fuel Pit CoolingARP-0 11, rev 29, page 60, LIGHTING FEEDER AUTO-TRIPONOP-EL-4, rev 12, Loss of Offsite PowerONOP-EL-7, rev 6, Loss of a 480V Bus -Above Cold ShutdownSOP-EL-015, rev 15, Operation of Non-Safeguards Equipment During Use of EOPsDiscussed potential design change to eliminate the pressuized door seals with Systems Engineering and EngineeringPrograms, with results captured in Attachment of e-mail. The conclusion was that the engineers did not feel that the doorpressurization needs to be eliminated to resolve this concern.Walkdown with the Safety Supervisor on 12/10/03 resulted in the following advice:Personnel safety is adequately assured based on present conditions.Emergency lights illuminate the walkways and stairways for exit routes.The building does not normally contain hazards such that egress is urgently required.Optional enhancements that would benefit personnel safety are:Add four emergency lights, one at each elevation 95' door, one in the elevation 55' truck bay, and one in the Spent FuelPool Cooling pumps' cellAdd an illuminated EXIT sign at each of the three personnel doors.Sign near main elevation 95' door to indicate location of telephone inside the building.Based on the document review and input from Engineering and Safety as described above, the action taken was to issue thefollowing Operations Procedure Feedbacks:IP3-7067 -- Revise ARP-0 I1 to identify as Automatic Actions the FSB door seal pressurization and FSB elev. 95' dooremergency operation push-button inoperatbility upon loss of power to 20 VAC Distribution Panel 32.IP3-7068 -- Revise SOP SFP-001 to add similar information to the Precautions and Limitations section.Subresponse:Closure Comments:Attachments:Response DescriptionE-Mails About FSB Door Seals

Attachment

HeaderDocument Name:[CR-IP3-2003-04719 CA-00006Document LocationIResponse DescriptionAttach Title:IE-Mails About FSB Door Seals, From: Tesoriero, MichaelSent: Thursday, December 18, 2003 7:28 AMTo: Catano, John; Eisenberg, Zvi; Sinert, Ivan; Etzweiler, loanCc: Lee, UzSubject: RE: IP3 FSB Pressurized Door SealsI believe the SOV's are powered from a lighting bus that is not powered by the EDG's until certainpanels are reset.However, MCC-37 gets reset early to start the SFP pumps, only you can't get in the building tostart the pumps locally due to the door seals. John is probably right. Maybe move the reset ofthe panel that powers the sov's up in the procedure before starting SFP pumps. A test and/ormodification is not warranted.This is my opinion, not a decision. If Ivan and Zvi want to do other stuff, have a blast.Mike----- Original Message -----From: Catano, John: ....... .. ....Sent: Wednesday, December 17, 2003 2:06 PMTo: Eisenberg, Zvi; Sinert, Ivan; Etzweiler, JoanCc: Lee, Liz; Tesoriero, MichaelSubject: RE: IP3 FSB Pressurized Door SealsALL,NO, THERE IS NO REASON TO TEST AND/OR MODIFY ANYTHING. THEDOOR SEALS INFLATE TO KEEP BAD THINGS IN, AND IF THEY AREINFLATED, AREN'T THEY TO KEEP PEOPLE OUT WHILE THERE IS A FUELHANDLING TYPE ACCIDENT, WHY WOULD YOU WANT TO GO IN THERETHEN? IF WE HAD TO GET IN THERE WITH R-5 ACTUATED AND ABLACKOUT TAKING PLACE WOULDN'T ALL IT TAKE TO DEFLATE THEDOOR SEALS IS PULLING THE FUSES ON R-5? IF NOT PUT A BOXCUTTER BY EACH DOOR AND CUT THE SEALS FROM THE INSIDE IFNEEDED. DON'T THE D/G'S START ON A BLACKOUT AND WOULDN'TTHEY PROVIDE POWER TO THE SOV'S? JUST BECAUSE SOMEONE ASKSA "QUESTION" IT DOESN'T AUTOMATICALLY BECOME A MONUMENTALPROBLEMJohn L. Catano Jr.Entergy Nuclear Northeast-IPECPrograms and Component Engineering914-736-8348914-736-8350 FAX888-451-8562 PAGERJCATANO@ENTERGY.COM----- Original Message-----From: Eisenberg, ZviSent: Wednesday, December 17, 2003 1:33 PMTo: Sinert, Ivan; Etzweiler, JoanCc: Lee, Uz; Catano, JohnSubject: RE: IP3 FSB Pressurized Door SealsI recommend to performed some kind of test to review the operation of the FSB ventilation andthe ability to open the personal door under the loss of power.----- Original Message-----

From: Sinert, IvanSent: Wednesday, December 17, 2003 1:14 PMTo: Etzweiler, JoanCc: Eisenberg, Zvi; Lee, UzSubject: RE: IP3 FSB Pressurized Door SealsThe door seals inflate with air and are backed up. So when power is lost the Vent System is downbut the door seals are maintained. The pressure from the seal on the latch makes the door hardto open, if opened, the seals would keep the door from closing. A modification to deflate the sealand allow for re-inflation would need to be studied by Engineering if Operations requests. I'm notsure we should do this because we would be loosing reserve air/nitrogen each time we use it andat some point we would loose the building seal. Licensing as well as Engineering should look atlicensing basis to be sure we are not in a bad place if we mod. this system.Ivan----- Original Message-----From: Etzweiler, JoanSent: Monday, December 15, 2003 1:12 PMTo: Sinert, IvanCc: Eisenberg, Zvi; Lee, uzSubject: IP3 FSB Pressurized Door SealsIvan,Per discussions with LL and youself, you agreed to look into the design details of the doorpressurization system and personnel door latch for the FSB, to understand why operators couldnot open the doors on 8/14/03. This input is needed for my response to CR IP3-2003-04719, CA# 6 due 1/6/04. Thanks for your help, Ivan and Zvi.Joan Etzweiler, 914-736-8207, Operations Department, Technical Support----- Original Message-----From: Eisenberg, ZviSent: Monday, December 15, 2003 11:39 AMTo: Etzweiler, loanSubject: RE: Possible Elimination of IP3 FSB Door SealsPlease discuss this with Liz Lee.Thanks,Zvi----- Original Message-----From: Etzweiler, JoanSent: Monday, December 15, 2003 11:38 AMTo: Eisenberg, ZviSubject: RE: Possible Elimination of IP3 FSB Door SealsOkay, I'll write a Condition Report. Which organization do you think it should be assigned to?But, simultaneoulsy, I still need to find out the cost of eliminating an unnecessary plant system.Joan Etzweiler, 914-736-8207, Operations Department, Technical Support----- Original Message-----From: Eisenberg, ZviSent: Monday, December 15, 2003 11:13 AMTo: Etzweiler, Joan; Canavan, Gerald Cc: Head, Jerald; Prussman, Stephen; Ubby, Earl; Sicard, Michael; Lee, Liz; Sinert, Ivan; Putnam,Charles; Digenova, Mario; Orlando, TomSubject: RE: Possible Elimination of IP3 FSB Door SealsJoan,I believe we need to determine and understand the cause before we decide to change plantconfiguration.Zvi----- Original Message-----From: Etzweiler, JoanSent: Friday, December 12, 2003 9:25 PMTo: Canavan, GeraldCc: Head, Jerald; Prussman, Stephen; Libby, Earl; Sicard, Michael; Lee, Liz; Sinert, Ivan; Putnam,Charles; Digenova, Mario; Eisenberg, ZviSubject: Possible Elimination of IP3 FSB Door SealsGerry,IPEC Operations is evaluating whether to submit an Engineering Request for a design change toeliminate the Fuel Storage Building (FSB) door pressurization system at Indian Point Unit 3 (IP3).To support our evaluation, I am asking you to provide an estimate of the work-hours thatthe WPO Nuclear Eng. Analysis group would need to perform the technical evaluation tosupport our 10 CFR 50.59 review per ENN-LI-101. At this point, we need only a ballpark,budgetary estimate. Your reply is needed before the end of 2003 because the ER is due on1/6/04.BACKGROUNDAs a result of the loss of northeast power grid event on 8/14/30, Indian Point Unit 3 lost the abilityto open the Fuel Storage Building (FSB) doors.This was a problem because the Spent Fuel Pool Cooling (SFPC) Pumps are located inside theFSB. The SPFC Pumps lost power due to the black-out. Pump motor start is local only. Loss ofpower to a 120 VAC distribution panel caused the FSB door seals to engage. The sealed doorsprevented operator entry to manually restore SFPC. This problem would have been more urgentif fuel had recently been discharged from the Reactor. Without the FSB Exhaust Fan running, thedoor should not have been hard to open; yet it was. The automatic door-sealing feature is notinstalled at the IP2 FSB.An IPEC Licensing Engineer has advised that the need for pressurized seals was eliminatedbecause IP3 Tech. Spec. Amendment # 215 removed the requirement for FSB air filtrationfollowing a postulated Fuel Handling Accident. The pressurized door seals were intended toensure that negative pressure was maintained in the FSB, so that all exiting air would be forcedthrough the filters. Because the licensing basis was changed to remove the requirement for FSBair filtration, it is expected that the design can be changed to facilitate personnel entry and exit.The elimination of the IP3 FSB door pressurization system would:* Enhance ability to enter / exit the FSB to support personnel safety and spent fuel coolingduring loss of power events* Eliminate testing and maintenance of the system* Reduce the nuisance of system actuation due to spiking or malfunction of the FSB arearadiation monitor.Thanks for your input, Gerry.Joan Efzweiler, 914-736-8207, Operations Department, Technical Support Entergy CORRECTIVE ACTION CR-IP3-2003-04719CA Number: 7Group I NameAssigned By: CA&A Staff ReynoldsJoseph AAssigned To: Operations Shift Manager O'Donnell,Eugene ESubassigned To :Originated By: Schmidt,George P 1/6/2004 15:08:43Performed By: Haynes,James S 1/13/2004 10:43:58Subperformed By:Approved By:Closed By: ReynoldsJoseph A 1/13/2004 10:57:10Current Due Date: 01/15/2004 Initial Due Date: 01/15/2004CA Type: CR CLOSURE REVIEW CA Priority:Plant Constraint: #NONECA Description:CAT-B, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION5.8.Response:CR has been reviewed for closure per ENN-LI-102 section 5.8. Additional corrective actions have been assigned. DONOT close CR.Subresponse :Closure Comments:Per CA&A review, noted the CR owner did not approve the closure of this CR and issued new CAs to track the resolutionof the remaining issues, therefore this CR removed from the closure review process pending completion of the new CAs andthis CA closed.

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719CA Number:8GroupHansJaeINameIAssigned By: Operations Support StaffAssigned To: Operations Procedure MgmtSubassigned To:Haynes,James SJanicki.john WOriginated By: Haynes,James S 1/13/2004 09:41:16Performed By: Janicki,John W 4/7/2004 08:49:53Subperformed By:Approved By:Closed By: Janicki,John W 4/7/2004 08:49:53Current Due Date: 04/12/2004 Initial Due Date: 04/12/2004CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:IP3-7067 -- Revise ARP-01 1 to identify as Automatic Actions the FSB door seal pressurization and FSB elev. 95' dooremergency operation push-button inoperatbility upon loss of power to 20 VAC Distribution Panel 32.Response:Incorporated in ARP-0 11 revision 31.Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719CA Number:9GroupINameIAssigned By: Operations Support StaffAssigned To: Operations Procedure MgmtSubassigned To :Haynes,James SJanicki,John WOriginated By: Haynes,James S 1/13/2004 09:43:17Performed By: Janicki,John W 4/7/2004 08:51:46Subperformed By:Approved By:Closed By: Janicki,John W 4/7/2004 08:51:46Current Due Date: 04/12/2004 Initial Due Date: 04/12/2004CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:IP3-7068 -- Revise SOP SFP-001 to add similar information to the Precautions and Limitations section.Response:Incorporated into revision 20 of SOP-SFP-001.Subresponse :Closure Comments:

Entergy I CORRECTIVE ACTION ICR-IP3-2003-04719CA Number:10GroupHansJaeINameIAssigned By: Operations StaffAssigned To: Operations StaffSubassigned To :Haynesjames SEtzweilerjoan FOriginated By: Haynes,James S 1/13/2004 10:41:49Performed By: Etzweiler,Joan F 1/19/2004 18:10:05Subperformed By:Approved By:Closed By: Etzweiler,Joan F 1/19/2004 18:10:05Current Due Date: 02/17/2004 Initial Due Date: 02/17/2004CA Type: PERFORM CA CA Priority:Plant Constraint: #NONECA Description:Review recommended safety enhancements and issue additional corrective actions/ERs as required.(1) Add four emergency lights, one at each elevation 95' door, one in the elevation 55' truck bay, and one in the SpentFuel Pool Cooling pumps' cell(2) Add an illuminated EXIT sign at each of the three personnel doors.Sign near main elevation 95' door to indicate location of telephone inside the building.

Entergy CORRECTIVE ACTION CR-IP3-2003-04719Response:The Corrective Action assignment is to"Review recommended safety enhancements and issue additional corrective actions/ERs as required.(1) Add four emergency lights, one at each elevation 95' door, one in the elevation 55' truck bay, and one in the SpentFuel Pool Cooling pumps' cell(2) Add an illuminated EXIT sign at each of the three personnel doors.(3) Sign near main elevation 95' door to indicate location of telephone inside the building."BACKGROUNDThere were no safety enhancements recommended. The listed items were merely noted by Safety as possible optionalenhancements.[Per resonses to CA #5 and CA # 6, the Safety representive considered personnel safety already adequately assured basedon the following present conditions:a) Emergency lights illuminate the walkways and stairways for exit routes.b) The building does not normally contain hazards such that egress is urgently required.]In addition, Operator response to loss of power to 120 VAC Distribution Panel 32 will be expedited due to the procedurechanges requested in Operations Procedure Feedbacks IP3-7067 (CA #8) and IP3-7068 (CA # 9). An expedited operatorresponse would also enhance Safety.REVIEW OF POSSIBLE OPTIONAL SAFETY ENHANCEMENTS(1) Additional emergency lights and (2) illuminated EXIT signs would constitute a modification. Procedure ENN-DC- 113,Grading, assigns values of $65 to an engineering hour and $50 to a craft worker hour. Assuming electrical power is readilyavailable in the building, cost is estimated as at least $30,000, based on:160 eng. design hours x $65 / hr = $10,400, plus 2 electricians x 4 weeks x 40 hr/wk x $50/hr = $16,000, plus planning,support and materials. If additional electrical power is not readily available, the cost would be much higher.As indicated by Safety, the benefits are only enhancements, not requirements.Therefore, the cost/benefit evaluation does not justify an Engineering Request (ER) for a modification.(3) The telephone in the building is not a permanent hardwired installation. The telephone is plugged into a standardtelephone jack with a very long cord, and can be easily removed or re-located. It is used primarily for the convenience offuel movement activities. There are already numerous signs in the area. The addition of a permanently affixed sign wouldtherefore be confusing or misleading. Therefore, adding a sign to indicate a telephone is not justified.CONCLUSIONThe ideas for optional safety enhancements have been reviewed and are not considered to be worth pursuing. No furthercorrective action or ER is initiated. ME 1/19/04Subresponse :Closure Comments:

Entergy I CORRECTIVE ACTION I CR-IP3-2003-04719CA Number:11GroupINameIAssigned By: CA&A StaffAssigned To: Operations Watch MgmtSubassigned To:Reynolds,Joseph AVitale,Anthony JOriginated By: Schmidt,George P 4/7/2004 09:35:03Performed By: Main,Dennis E 4/9/2004 08:53:36Subperformed By:Approved By:Closed By: Reynolds,Joseph A 4/12/2004 17:24:14Current Due Date: 04/14/2004 Initial Due Date: 04/14/2004CA Type: CR CLOSURE REVIEW CA Priority:Plant Constraint: #NONECA Description:CAT-B, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION5.8.Response:All corrective actions have been answered as requested. Recommend CR closure.Subresponse :Closure Comments:Per CA&A Review, noted the CR owner recommended the closure of the CR.

I Entergy CONDITION REPORT I CR-IP3-2005-00239Originator: Goerres,Andrew POriginator Group: Operations Watch StaffSupervisor Name: PitsleyDavid KDiscovered Date: 01/21/2005 19:21Originator Phone: 8214Operability Required: YReportability Required: NInitiated Date: 01/21/2005 19:26Condition Description:During restoration following performance of 3PT-V055 (Exercise Close of Valve AC-726B, RWST Purification ReturnCheck Valve), Valve AC-719A (Spent Fuel Pit Purification Loop Supply Isolation) failed while opening. The valve failed insuch a way that the handwheel is unable to be used to close the valve. There was no leakage from the valve evidenced afterthis failure and the affected system was left in a stable condition.Immediate Action Description:Suggested Action Description:EQUIPMENT:Tag NameAC-719ATa2 Suffix Name Component Code Process System CodeVD SFPCREFERENCE ITEMS:Type Code#LEVEL OF DEFENSEKEYWORDSKEYWORDSKEYWORDSTEAM 3BWONTRENDING (For Reference Purposes CTrend TypeKEYWORDSDescriptionUnion operator initiated -surveillance testingValveSpent Fuel Cooling3PT-V055IP3-05-10939)nly):Trend CodeKW-SELF-REVEALING Entergy I ADMIN I CR-iP3-2005-00239Initiated Date: 1/21/2005 19:26 Owner Group :System Eng Primary System MgmtCurrent Contact:Current Significance: D -ADMTN CLOSUREClosed by: Harrison,Christine B 1/26/2005 10:38Summary Description:During restoration following performance of 3PT-V055 (Exercise Close of Valve AC-726B, RWST Purification ReturnCheck Valve), Valve AC-719A (Spent Fuel Pit Purification Loop Supply Isolation) failed while opening. The valve failed insuch a way that the handwheel is unable to be used to close the valve. There was no leakage from the valve evidenced afterthis failure and the affected system was left in a stable condition.Remarks Description:Closure Description:1/25/05: Per CRG, close to work order IP3-05-10939 (Y).

Entergy OPERABILITY CR-iP3-2005-00239OperabilityVersion: 1Operability Code: ADMIN -NAImmediate Report Code: NOT REPORTABLEPerformed By: Lyon,Daniel R 01/22/2005 05:34Approved By: Faughnan,Philip J 01/22/2005 06:23Operability Description:This condition does not meet the reporting criteria of SMM-LI-108. The valve has failed in its normal line up position(open), thus permitting continued operation of the SFP purification system. The valve does not require operation for anyDBA and does not affect the operation or function any safety related systems. There is no external leakage and nocompensatory actions are required.Approval Comments:Approved Entergy A S S I G N M E N T S CR-IP3-2005-00239Version: 1Significance Code: D -ADMIN CLOSUREClassification Code: NON-SIGNIFICANTOwner Group: System Eng Primary System MgmtPerformed By: Harrison,Christine BAssignment Description:1/25/05: Per CRG, close to work order IP3-05-10939 (Y).01/26/2005 10:37 Entergy CONDITION REPORT I CR-IP3-2007-00859Originator: Stubble,Mark DOriginator Group: Operations Watch StaffSupervisor Name: Baker 1I,John CDiscovered Date: 03/05/2007 22:50Originator Phone: 5431Operability Required: NReportability Required: NInitiated Date: 03/05/2007 22:52Condition Description:Spent Fuel Pit Filter delta P has been rising over the past 9 days. Currently at 17 psid. Maximum delta P on filter is 20 psid.Immediate Action Description:Informed CRS.Suggested Action Description:Change filter at or before 20 psid or as soon as possible.REFERENCE ITEMS:Type CodeCRDITGTEAM 2DDescriptionIP2-2007-01138IP2-07-00058TRENDING (For Reference Purposes Only):Trend TypeAWHEP FACTORINPO BINNINGKEYWORDSREPORT WEIGHTTrend CodeOPMGHOP1KW-DUPLICATE CRI Entergy ADMIN CR-IP3-2007-00859Initiated Date: 3/5/2007 22:52 Owner Group :Operations Watch MgmtCurrent Contact:Current Significance: D -ADMIN CLOSUREClosed by: Harrison,Christine B 3/6/2007 10:27Summary Description:Spent Fuel Pit Filter delta P has been rising over the past 9 days. Currently at 17 psid. Maximum delta P on filter is 20 psid.Remarks Description:Closure Description:3/6/07: Per morning CRG, close to CR-IP2-2007-01138 (duplicate).

Entergy I ASSIGNMENTS I CR-IP3-2007-00859Version: 1Significance Code: D -ADMIN CLOSUREClassification Code: NON-SIGNIFICANTOwner Group: Operations Watch MgmtPerformed By: Harrison,Christine BAssignment Description:3/6/07: Per morning CRG, close to CR-1P2-2007-01138 (duplicate).03/06/2007 10:26 I Entergy CONDITION REPORT I CR-IP3-2009-02219Originator: Roberts,Laurence ROriginator Group: Operations Support Staff IP3Supervisor Name: Jordan II,John BDiscovered Date: 05/05/2009 07:53Originator Phone: 5995Operability Required: NReportability Required: NInitiated Date: 05/05/2009 08:00Condition Description:RWST Purification Pump motor has two separate component IDs in PASSPORT. SI-P-B (M) is one component ID in theSI system. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two ofevery PM for this same component.Immediate Action Description:Suggested Action Description:EQUIPMENT:Ta2 NameSI-P-B (M)RWST PURIFICATI ON PMPREFERENCE ITEMS:Type CodeKEYWORDSTa2 Suffix Name Component Code Process System CodeLCLS/NSLCLM/NSMOTORMOTORSISFPCDescriptioncomponent IDTRENDING (For Reference Purposes Only):Trend TypeKEYWORDSKEYWORDSKEYWORDSREPORT WEIGHTKEYWORDSKEYWORDSHEP FACTORKEYWORDSINPO BINNINGTrend CodeKW-PASSPORTKW-CONFIGURATION OTHERKW-PUMP1KW-COMPUTER PROGRAMKW-PREVENTATIVE MAINTENANCEPKW-SOFTWAREER4ESDEKW-DOCUMENT CONTROLKW-PROCEDURE NOT UPDATEDKW-CHANGE MANAGEMENTKW-MODIFICATION CLOSE OUTAJKEYWORDSKEYWORDSKEYWORDSKEYWORDS Entergy I ADMIN I CR-iP3-2009-02219Initiated Date: 5/5/2009 8:00 Owner Group :Eng DE Config Mgmt IP3Current Contact: Joe ReynoldsCurrent Significance: CClosed by: Reynolds,Joseph A 9/11/2009 16:26Summary Description:RWST Purification Pump motor has two separate component IDs in PASSPORT. SI-P-B (M) is one component ID in the SIsystem. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of everyPM for this same component.Remarks Description:Closure Description:Per CAA review, acknowledge the CR owner (Eng DE Config) recommendation and approval to close the CR. The CR issue"RWST Purification Pump motor has two separate component IDs in PASSPORT. SI-P-B (M) is one component ID in the SIsystem. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of every PMfor this same component." resolution was captured, therefore CAA noted the trend codes applied and then closed the CR.

Entergy A S S I G N M E N T S I CR-IP3-2009-02219Version: 1Significance Code: CClassification Code: CORRECT/ADDRESSOwner Group: Eng DE Config Mgmt IP3Performed By: Harrison,Christine BAssignment Description:05/07/2009 11:26 Entergy CORRECTIVE ACTION CR-IP3-2009-02219CA Number: 1Group .NameAssigned By: Eng DE Config Mgmt IP3 McCaffirey,Thomas SAssigned To: Eng DE Config Mgmt IP3 Lee,Lizabeth AnnSubassigned To: Eng DE Config Staff IP3 RadvanskyMichael SOriginated By: zzip2crg 5/7/2009 11:45:06Performed By: Thoms,Rudolf 5/26/2009 14:10:48Subperformed By: Radvansky,Michael S 5/26/2009 14:06:03Approved By:Closed By: Thoms,Rudolf 5/26/2009 14:10:48Current Due Date: 05/28/2009 Initial Due Date: 05/28/2009CA Type: DISP -CA CA Priority:Plant Constraint: #NONECA Description:Please review and assign further corrective actions as required.Response:Sub Responce ApprovedSubresponse :Condition Description:RWST Purification Pump motor has two separate component IDs in PASSPORT. SI-P-B (M) is one component ID in the Stsystem. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of everyPM for this same component.Response:This item was researched and it was determined not to be an issue of a duplication of component ID numbers against asingle component.There are two separate and distinct pumps (and motors) involved. One pump is the RWST Purification pump (ID # RWSTPURIFICATI) shown on flow diagram 9321-F-27513 and a second pump, the RWST Recirculation Pump (ID # SI-P-B)shown on flow diagram 932 1-F-27503 Sheet 2.Although there are two pumps, the source of power for the RWST Recirc Pump MCC-2FK was disconnected. It was usedlater as a source of power for the CVCS Hold-up Tank Recirculation pump under modification MMP-93-3-242. Theelectrical one line diagram drawing 932 1-F-30053 reflects this change.Although there was a modification that removed the power from the RWST Recirculation pump, several areas ofdocumentation mainly in the mechanical area were not addressed to reflect this change. As an example, the Flow Diagramstill shows the pump as active with no note that it has been electrically disconnected. The Safety Injection System DesignBasis Document still references the pump and the equipment database still shows the pump and motor as being active.EC 15236 was written to deactivate the IAS equipment records for the RWST Recirculation pump and motor since thesource of power has been disconnected. CA # 2 was issued to track the closure of this EC.CA #3 was issued to update the DBD to reflect the current status of the pump i.e. that it has been electrically disconnectedand to ensure any other mod closeout actions have been satisfactorily completed.Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2009-02219CA Number: 2Group NameAssigned By: Eng DE Config Mgmt IP3 RadvanskyMichael SAssigned To: Eng DE Config Mgmt IP3 Lee,Lizabeth AnnSubassigned To: Eng DE Config Staff IP3 RadvanskyMichael SOriginated By: Radvansky,Michael S 5/26/2009 13:57:46Performed By: Lee,Lizabeth Ann 8/5/2009 19:18:21Subperformed By: Radvansky,Michael S 8/5/2009 13:14:52Approved By:Closed By: Lee,Lizabeth Ann 8/5/2009 19:18:21Current Due Date: 08/07/2009 Initial Due Date: 08/07/2009CA Type: ACTION CA Priority:Plant Constraint: #NONECA Description:This is a tracking CA for completion of EC for resolving status of equipment records for RWST Recirculation pump andmotor since the motor has been electrically disconnected. Note: Due to Passport being down at the time of writing nonumber was referenced.Response:Reviewed and approved. All doccuments have been corrected, no actions remain.Subresponse:EC 15236 was processed to retire the equipment records for SI-P-B pump and motor and to approve a Revision 50 todrawing 9321-F-27503.Closure Comments:

Entergy I CORRECTIVE ACTION I CR-IP3-2009-02219CA Number:3GroupINameIAssigned By: Eng DE Config Mgmt IP3Assigned To: Eng DE Mech Mgmt IP3Subassigned To: Eng DE Mech Staff IP3Radvansky,Michael SMyers,Valerie EUwechue,Godwin 0Originated By: Radvansky,Michael S 5/26/2009 14:02:23Performed By: Myers,Valerie E 9/9/2009 10:13:56Subperformed By: Uwechue,Godwin 0 9/9/2009 07:21:48Approved By:Closed By: Myers,Valerie E 9/9/2009 10:13:56Current Due Date: 09/17/2009CA Type: ACTIONInitial Due Date: 09/17/2009CA Priority:Plant Constraint: #NONECA Description:Update the Safety Injection System DBD to reflect the current status of the RWST Recirculation pump i.e. that it has beenelectrically disconnected and ensure any other mod closeout actions associated with this electrical disconnection have beensatisfactorily completed. Issue CAs as required to complete these actions.Response:Approved.Subresponse:Safety Injection System DBD and associated drawings have been updated to reflect the current status of the RWSTRecirculation pump (i.e. that it has been electrically disconnected) with an Admin Change Engineering Change, EC1683 1.All other mod closeout actions associated with this electrical disconnection have been satisfactorily completed.Closure Comments:

Entergy CA DUE DATE EXTENSION FcR-IP3-2009-02219Corrective Action : CR-IP3-2009-02219 CA-00003Version: IRequested Duedate: 09/17/2009Requested By: Uwechue,Godwin 0Approved By: Myers,Valerie EApproved: I-VPrevious Duedate: 08/14/200908/11/200908/11/2009Request Description:It is acceptable to extend the due date since the CA is only for updating the DBD.It is necessary to extend the due date due to higher priority work assignments.Supervisor is in agreement with extension.Approved Description:approved -No interim actions are required.

Entergy CORRECTIVE ACTION CR-IP3-2009-02219CA Number:4GroupINameIAssigned By: CAA Staff IP3Assigned To: Eng DE Config Mgmt IP3Subassigned To:Reynolds,Joseph ALee,Lizabeth AnnOriginated By: Jowitt,Roseann 9/9/2009 10:29:49Performed By: Lee,Lizabeth Ann 9/10/2009 05:40:31Subperformed By:Approved By:Closed By: Reynolds,Joseph A 9/11/2009 16:25:36Current Due Date: 09/24/2009 Initial Due Date: 09/24/2009CA Type: CR CLOSURE REVIEW CA Priority:Plant Constraint: #NONECA Description:CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH EN-LI-102, SECTION5.9.Response:Ok to close per EN-LI-102.Subresponse :Closure Comments:Per CAA review, noted the CR owner recommended and approved the closure of the CR.

Entergy CONDITION REPORT I CR-IP3-2011-03729Originator: PetersonJoseph F Originator Phone: 6899Originator Group: P&C Eng Codes Staff IP3 Operability Required: YSupervisor Name: Azevedo,Nelson F Reportability Required: YDiscovered Date: 07/26/2011 06:06 Initiated Date: 07/26/2011 06:37Condition Description:The following conditions were noted during a Boric Acid Walkdown of the Unit #3 PAB. All of the Boric Acid was dry andno material degradation or operability concerns exist. All of the Boric Acid was white with the exception of SI-MOV- 1 852Awhere the Boric Acid deposit is light brown in color.Valve AC-739A (31 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-739B (32 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-740A (PI-635, PC-635 Isolation) was found to have a very light dry packing leak.Valve AC-727B (Spent Fuel Pit Purification Loop to RWST Isolation) was found to have a very light dry packing leak.SI-MOV-1852A (Boron Injection Tank Inlet Stop) was found to have a light dry packing leak.Immediate Action Description:Notified P&CE Management, FSS, Issued a Condition Report and Generated a Work Request for each valve.Suggested Action Description:Tighten packing bolts or re-pack the valves.EQUIPMENT:Tag Name Tag Suffix Name Component Code Process System CodeAC-739A EX/SR/MR VALVE RHRAC-739B EX/SR/MR VALVE RHRAC-740A EX/SR/MR VALVE RHRAC-727B EX/SR/MR VALVE SFPCSI-MOV-1852A HCLS/SR/MR VALVE SIREFERENCE ITEMS:Type Code DescriptionKEYWORDS Boric AcidWON 00285361 YWON 00285362 YWON 00285360 YWON 00285364 YWON 00285363 YWRN 00244044WRN 00244045WRN 00244046WRN 00244048WRN 00244049TRENDING (For Reference Purposes Only):Trend Type Trend CodeINPO BINNING ER3HEP FACTOR EEL ESSEELESSE Entergy CONDITION REPORT CR-iP3-2011-03729TRENDING (For- Rafren, Pro~o niv):Trend TypeKEYWORDSKEYWORDSREPORT WEIGHTTrend CodeKW-VALVE PACKINGKW-LEAKS-BORONI Entergy ADMIN CR-IP3-2011-03729Initiated Date: 7/26/2011 6:37 Owner Group :P&C Eng Codes Mgmt IP3Current Contact: Joe ReynoldsCurrent Significance: DClosed by: Reynolds,Joseph A 8/3/2011 5:25Summary Description:The following conditions were noted during a Boric Acid Walkdown of the Unit #3 PAB. All of the Boric Acid was dry andno material degradation or operability concerns exist. All of the Boric Acid was white with the exception of SI-MOV- 1 852Awhere the Boric Acid deposit is light brown in color.Valve AC-739A (31 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-739B (32 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-740A (PI-635, PC-635 Isolation) was found to have a very light dry packing leak.Valve AC-727B (Spent Fuel Pit Purification Loop to RWST Isolation) was found to have a very light dry packing leak.SI-MOV-1852A (Boron Injection Tank Inlet Stop) was found to have a light dry packing leak.Remarks Description:Closure Description:Per CAA review, noted the CRG approved the closure of this CR issue "The following conditions were noted during a BoricAcid Walkdown of the Unit #3 PAB. All of the Boric Acid was dry and no material degradation or operability concerns exist.All of the Boric Acid was white with the exception of SI-MOV-1852A where the Boric Acid deposit is light brown in color.Valve AC-739A (31 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-739B (32 RHR Pump Discharge Isolation) was found to have a light dry packing leak.Valve AC-740A (PI-635, PC-635 Isolation) was found to have a very light dry packing leak.Valve AC-727B (Spent Fuel Pit Purification Loop to RWST Isolation) was found to have a very light dry packing leak.SI-MOV-1852A (Boron Injection Tank Inlet Stop) was found to have a light dry packing leak." to the actions tracked via thereferenced work orders noted to have the PCRS control field Y attribute applied. Therefore with the BACC program reviewaction completed, CAA noted the trend codes applied and then closed the CR.7/28/11: Per CRG, close to referenced work orders. A corrective action is being assigned to Code Programs to include inBACC Program.

Entergy OPERABILITY CR-IP3-2011-03729OperabilityVersion: 1Operability Code: OPERABLEImmediate Report Code: NOT REPORTABLEPerformed By: ZastrowAndrew 07/26/2011 17:30Approved By: Faughnan,Philip J 07/26/2011 17:33Operability Description:Valves AC-739A, 739B, 740A, and SI-MOV- 1 852A are part of the ECCS system. Valve AC-727B is part of SFPPurification. The boron accumulations described are minor with no active leakage. The brown tint on SI-MOV- 1852Aappears to be grease that has mixed in with the boron and not any valve corrosion products. The small amount of boronpresent does not affect the ability of the valves to perform their safety-related functions. No material degradation is indicated.While the leakage of SI-MOV-1852A is 3PT-CO1 leakage, it is too small to be quantified and would not affect the 3PT-COIleakage quantificaiton. Additionally, since the leakage is too small to quantify, the leakage amount does not challengeIVSWS leakage specifications. RCS Leakage is within T.S. limits. Valves AC-739A, -739B, -740A, SI-MOV-1852A andAC-727B are OPERABLE. This is not reportable per SMM-LI-108.Approval Comments:Approved Entergy A S S I G N M E N T S CR-IP3-2011-03729Version: 1Significance Code: DClassification Code: CLOSE TO WMSOwner Group: P&C Eng Codes Mgmt IP3Performed By: Harrison,Christine B 07/28/2011 12:21Assignment Description:7/28/11: Per CRG, close to referenced work orders. A corrective action is being assigned to Code Programs to include inBACC Program.

Entergy I REPORTABILITY I CR-IP3-2011-03729Reportability Version: 1Report Number:Report Code: NOT REPORTABLEBoilerplate Code:Performed By : BurneyMichael WReportability Description:This condition does not meet the reporting criteria of SMM -LI-108.07/27/2011 14:47 Entergy CORRECTIVE ACTION I CR-IP3-2011-03729CA Number:IGroup..... ... ... IName.... IAssigned By: P&C Eng Codes Mgmt IP3Assigned To: P&C Eng Codes Mgmt IP3Subassigned To : P&C Eng Codes Staff IP3AzevedoNelson FAzevedo,Nelson FHerrmann,Robert DOriginated By: Zzip2crg 7/28/2011 12:25:19Performed By: Azevedo,Nelson F 8/2/2011 10:21:26Subperformed By: Herrmann,Robert D 8/2/2011 07:58:04Approved By:Closed By: Azevedo,Nelson F 8/2/2011 10:21:26Current Due Date: 08/11/2011 Initial Due Date: 08/11/2011CA Type: ACTION CA Priority:Plant Constraint: #NONECA Description:Please ensure these leaks are included in the BACC Program.Response:See sub response below.Subresponse :All 5 leaks have been added to the BACC Program. AIMI leaks are dry. All boron is white with the exception of some lightbrown staining around the stem of SI-MOV-1852A. There is no material degradation. All leaks have WOs for their repair.No further action required.Closure Comments:

Entergy CONDITION REPORT CR-I1P3-2009-04483Originator: Weglinski,Michael POriginator Group: Rad Protection Staff 1P3Supervisor Name: Burns,Thomas FDiscovered Date: 11/13/2009 08:15Originator Phone: 8440Operability Required: NReportability Required: NInitiated Date: 11/13/2009 08:20Condition Description:Rad Worker reported to U-3 Watch HP that his DLR # 8738 could not be located. Actions taken IAW EN-RP-203.Immediate Action Description:Restricted Worker's Access to the RCA. Filled out EN-RP-203 Attachment 9.3. Wrote CR. Notified HPS and sent worker toDosimetry to be issued a replacement DLR.Suggested Action Description:Actions as taken.REFERENCE ITEMS:Type CodePRCDescriptionEN-RP-203TRENDING (For Reference Purposes Only):Trend TypeINPO BINNINGHEP FACTORWRKEYWORDSRAD PROTECTION FOCUSRAD PROTECTION FOCUSKEYWORDSKEYWORDSREPORT WEIGHTTrend CodeRPIHRPMGKW-RAD PROTECTION MANAGMENTRP-DOSIMETRY, LOSTRP-EXPOSURE CONTROLKW-MANAGEMENT EXPECTATIONSKW-DOSE ASSESSMENTI Entergy ADMIN I CR-IP3-2009-04483Initiated Date: 11/13/2009 8:20 Owner Group :Rad Protection Mgmt IP3Current Contact:Current Significance: DClosed by: Harrison,Christine B 11/17/2009 13:15Summary Description:Rad Worker reported to U-3 Watch HP that his DLR # 8738 could not be located. Actions taken IAW EN-RP-203.Remarks Description:Closure Description:11/17/09: Per CRG, close to actions taken as described in Immediate Action Description.

Entergy IAS SI GN ME N TS CR-IP3-2009-04483Version: 1Significance Code: DClassification Code: ACTIONS TAKENOwner Group: Rad Protection Mgmt IP3Performed By: Harrison,Christine B 11/17/2009 12:34Assignment Description:11/17/09: Per CRG, close to actions taken as described in Immediate Action Description.

I Entergy CONDITION REPORT I CR-IP3-2011-04515Originator: Carballo,Edgardo NOriginator Group: Maint FIN Staff IP2Supervisor Name: Downes,Oliver PDiscovered Date: 09/29/2011 06:10Originator Phone: 7551Operability Required: NReportability Required: NInitiated Date: 09/30/2011 06:33Condition Description:While replacing the filter in the SFP under WO# 291282, discovered that the filter vessel cover bolts were of differentsize (Head of bolt). This job, potentially having high dose, should be looked at, because we can't have two mechanicswaiting on a high dose area until someone gets the right tool.Immediate Action Description:Informed supervisor, and wrote CRSuggested Action Description:Recommend that on the next filter change, replace all the bolts to the same sizeEQUIPMENT:Tag NameACFLSF1Tag Suffix Name Component Code Process System CodeNC/NS FILTER SFPCREFERENCE ITEMS:Type CodeCRWONWONDescriptionIP3-2011-0452100291282292955 YTRENDING (For Reference Purposes Only):Trend TypeCBINPO BINNINGREP FACTORKEYWORDSKEYWORDSKEYWORDSKEYWORDSKEYWORDSREPORT WEIGHTTrend CodeESSECM2PKW-SPENT FUEL STORAGEKW-CONFIGURATION OTHERKW-WORK PACKAGE PLANNINGKW-ALARACEC1 Entergy ADMIN CR-IP3-2011-04515Initiated Date: 9/30/2011 6:33 Owner Group :Maintenance Mgmt IP3Current Contact:Current Significance: CClosed by: Ferretti,Michael D 10/11/2011 13:51Summary Description:While replacing the filter in the SFP under WO# 291282, discovered that the filter vessel cover bolts were of differentsize (Head of bolt). This job, potentially having high dose, should be looked at, because we can't have two mechanicswaiting on a high dose area until someone gets the right tool.Remarks Description:Closure Description:This Condition Report has been reviewed for closure in accordance with EN-LI-102, Section 5.9. All Corrective Actions havebeen satisfactorily completed and no additional Corrective Actions are required.

Entergy AS SIGN ME NT S I CR-IP3-2011-04515Version: 1Significance Code: CClassification Code: CORRECT/ADDRESSOwner Group: Maintenance Mgmt IP3Performed By: Harrison,Christine BAssignment Description:10/4/11: Level 2 HPER for Maintenance-FIN.10/05/2011 06:19 Entergy CORRECTIVE ACTION CR-IP3-2011-04515CA Number: 1GroupP- NameAssigned By: Industrial Safety-HU Mgmt IP3 Eisenstadt,CharlesAssigned To: Maint FIN Mgmt IP3 Bailey,Timothy HSubassigned To :Originated By: Eisenstadt,Charles 10/4/2011 11:03:39Performed By: Ferretti,Michael D 10/6/2011 09:05:56Subperformed By:Approved By:Closed By: Eisenstadt,Charles 10/6/2011 17:22:41Current Due Date: 10/11/2011 Initial Due Date: 10/11/2011CA Type: HUMAN PERF CA Priority:Plant Constraint: #NONECA Description:Level 2 HPER: Conduct an HPER in accordance with EN-HU-103. In order to complete this action you must.?L2Complete the HPER in accordance with the procedure.?LlUpon discovery of a potential error, the supervisor shall have the individuals involved complete Attachment 9.2,Individual Recollection Form.?LAttach the HPER form to this CA?[2Enter all trend codes to this CR?OPresent a clock reset at the operational focus meeting?02Have the department manager/superintendent electronically approve this CA for concurrenceNO HPER REQUIRED IF: (PLEASE ENSURE THIS IS DOCUMENTS IN THE RESPONSE)?LThe error occurred > 12 months ago. Due to the fallibility of memory, the older the information, the less reliable it is.?OCondition Report identifies a trend.?Ol1t cannot be determined who was involved, provided an effort was made to identify the involved parties.?flPersonnel no longer work at the station.?KlThe error was administrative in nature and has no operational or safety concerns.Response:This issue was reviewed with the FIN Superintendent and determined that there was no error committed. The CR initiatoridentified an existing condition that was intended to improve this specific job. A work request will be initiated anddocumented in CA2 to change out the bolting so that it is all the same size to save time and dose in the future. It cannot bedetermined who was involved in making all of the filter cover bolts different head sizes. Most likely this is an historic issuethat has happened over the years.Subresponse :Closure Comments:Close to actions taken .See response Entergy CORRECTIVE ACTION I CR-IP3-2011-04515CA Number:2GroupINameIAssigned By: Maintenance Mgmt IP3Assigned To: Maintenance Mgmt IP3Subassigned To : Maint FIN Mgmt IP3Kirkpatrick,JohnKirkpatrick,JohnBailey,Timothy HOriginated By: Zzip2crg 10/5/2011 06:37:16Performed By: Ferretti,Michael D 10/11/2011 13:50:2ýSubperformed By:Approved By:Closed By: Ferretti,Michael D 10/11/2011 13:50:2[Current Due Date: 10/26/2011CA Type: DISP -CAInitial Due Date: 10/26/2011CA Priority:Plant Constraint: NONECA Description:You have been assigned as the Responsible Manager for this Category "C", Non-Significant Condition Report by the CRGAddress/correct the identified condition per EN-LI-102. Perform disposition review, investigate as needed, and ensureactions are assigned as applicable to correct the problem.Response:W0292955 has been initiated to correct the bolt sizes. The "Y" value has been added to the WO.Subresponse :Closure Comments:

Entergy CONDITION REPORT I CR-IP3-2012-01710Originator: Stuart,ChristopherOriginator Group: Operations Watch Staff IP3Supervisor Name: Dignam,John MDiscovered Date: 06/05/2012 09:58Originator Phone: 8214Operability Required: YReportability Required: YInitiated Date: 06/05/2012 10:00Condition Description:It was noticed on operator rounds that the Spent fuel pit filter delta p is approaching the max spec. of 15 psid. The filter deltap is roughly reading 12-13 psid and trending up slowly. This filter should be changed out soon. WRT# 00274556Immediate Action Description:Contacted FSS of slowly increasing trend.Suggested Action Description:Change the filter out.EQUIPMENT:Tae NameACFLSF1Tag Suffix Name Component Code Process System CodeNC/NSFILTERSFPCREFERENCE ITEMS:Type CodeCRKEYWORDSKEYWORDSKEYWORDSKEYWORDSTEAM 3EWONWRNDescriptionIP3-2012-01741SPF Filterhigh delta PfilterSpent fuel pit filter00317376 Y00274556TRENDING (For Reference Purposes Only):Trend TypeEMINPO BINNINGHEP FACTORREPORT WEIGHTKEYWORDSKEYWORDSKEYWORDSKEYWORDSTrend CodeESSEER3EIKW-LOGSKW-FUEL POOL COOLINGKW-STRAINERKW-PRESSURE TRANSMITTER Entergy ADMIN I CR-IP3-2012-01710Initiated Date: 6/5/2012 10:00 Owner Group :System Eng Primary System Mgmt IP3Current Contact:Current Significance: DClosed by: Harrison,Christine B 6/23/2012 5:52Summary Description:It was noticed on operator rounds that the Spent fuel pit filter delta p is approaching the max spec. of 15 psid. The filter deltap is roughly reading 12-13 psid and trending up slowly. This filter should be changed out soon. WRT# 00274556Remarks Description:Closure Description:6/7/12: Per CRG, close to work order 00317376 (Y).

Entergy OPERABILITY CR-IP3-2012-01710OperabilityVersion: 1Operability Code: EQUIPMENT FUNCTIONALImmediate Report Code: NOT REPORTABLEPerformed By: ZastrowAndrew 06/05/2012 11:17Approved By: Faughnan,Philip J 06/05/2012 15:09Operability Description:The Spent Fuel Pool Filter supports cooling of the SFP. The log requirement is less than or equal to 15 psid, so it will need tobe replaced shortly. SFP filter remains in service and is FUNCTIONAL.Approval Comments:Approved Entergy I ASSIGNMENTS I CR-IP3-2012-01710Version: 1Significance Code: DClassification Code: CLOSE TO WMSOwner Group: System Eng Primary System Mgmt IP3Performed By: Harrison,Christine BAssignment Description:6/7/12: Per CRG, close to work order 00317376 (Y).06/07/2012 11:39 Entergy REPORTABILITY I CR-IP3-2012-01710Reportability Version: 1Report Number:Report Code: NOT REPORTABLEBoilerplate Code:Performed By : BurneyMichael WReportability Description:This Non-TS equipment is functional, not reportable.06/11/2012 14:51 Entergy I CONDITION REPORT CR-IP3-2012-01741Originator: Leenig,Scott ROriginator Group: Operations Watch Staff IP3Supervisor Name: Lizzo,NicholasDiscovered Date: 06/07/2012 10:03Originator Phone: 8214Operability Required: YReportability Required: YInitiated Date: 06/07/2012 10:08Condition Description:Upon performing rounds it was discovered that the SFP filter was high out of spec at 27 lbs dp. The CRS was notified and thefilter was bypassed per 3-sop-sfp-00 1. An existing WRT was written for this when the filter was approaching its upper limitat 14 lbs the wrt number is 00274556 and the CR # is CR-IP3-2012-01710.Immediate Action Description:Suggested Action Description:EQUIPMENT:Taa NameACFLSFIREFERENCE ITEMS:Type CodeCRPRCWONWRNTag Suffix Name Component Code Process System CodeNC/NS FILTER SFPCDescription017103-SOP-SFP-0010031737600274556TRENDING (For Reference Purposes Only):Trend TypeHEP FACTORINPO BINNINGEMKEYWORDSKEYWORDSKEYWORDSKEYWORDSREPORT WEIGHTTrend CodeEER3ESSEKW-LOGSKW-PRESSURE TRANSMITTERKW-FUEL POOL COOLINGKW-STRAINERI Entergy ADMIN I CR-IP3-2012-01741Initiated Date: 6/7/2012 10:08 Owner Group :System Eng Primary System Mgmt IP3Current Contact:Current Significance: DClosed by: Harrison,Christine B 6/23/2012 7:00Summary Description:Upon performing rounds it was discovered that the SFP filter was high out of spec at 27 lbs dp. The CRS was notified and thefilter was bypassed per 3-sop-sfp-00 1. An existing WRT was written for this when the filter was approaching its upper limit at14 lbs the wrt number is 00274556 and the CR # is CR-IP3-2012-01710.Remarks Description:Closure Description:6/11/12: Per CRG, close to work order 00317376 (Y).

Entergy OPERABILITY CR-IP3-2012-01741OperabilityVersion: 1Operability Code: NOT REQUIREDImmediate Report Code: NOT REPORTABLEPerformed By: Andersen,Robert Jon 06/07/2012 10:33Approved By: Lewis,Matthew W 06/07/2012 11:11Operability Description:The spent fuel pit filter does not affect the ability of the spent fuel pool to perform its design function which is to maintain aminimum water level to provide sufficient iodine scrubbing and shielding in the event of a fuel handling accident. Furtheroperability review is therefore not required. This condition is not reportable per IP-SMM-LI-108Approval Comments:Approve.

Entergy I ASSIGNMENTS I CR-IP3-2012-01741Version: 1Significance Code: DClassification Code: CLOSE TO WMSOwner Group: System Eng Primary System Mgmt IP3Performed By: Harrison,Christine BAssignment Description:6/11/12: Per CRG, close to work order 00317376 (Y).06/11/2012 11:22 Entergy REPORTABILITY I CR-IP3-2012-01741Reportability Version: 1Report Number:Report Code: NOT REPORTABLEBoilerplate Code:Performed By : Rokes,Charles B 06/08/2012 08:32Reportability Description:Recorded condition does not meet reporting criteria of SMM-LI- 108 based on operations concllusion the spent fuel pit filterdoes not affect the ability of the spent fuel pool to perform its design function which is to maintain a minimum water level toprovide sufficient iodine scrubbing and shielding in the event of a fuel handling accident.

Entergy CONDITION REPORT CR-IP3-2012-01768Originator: Conroy,Patric WOriginator Group: NSA Director IP3Supervisor Name: VentosaJohn ADiscovered Date: 06/08/2012 14:05Originator Phone: 9142546668Operability Required: YReportability Required: YInitiated Date: 06/08/2012 14:20Condition Description:Based on questions raised by NRC resident regarding mode restrictions on use of RWST Purification system associatedwith CR-IP3-2012-00485 (IP3 LER 2012-002-00), it appears that additional procedural restrictions for use of this systemand operation of its associated valves are required to prevent the RWST being connected to non-seismic systems or portionsthereof when in Modes 1, 2, 3 and 4.The review of this issue performed under CR-IP3-2012-00485 identified the need to revise 3-SOP-SI-003 (Recirculationand/or Purification of the Refueling Water Storage Tank) to place mode restrictions on use of this procedure which werecompleted under CA#3 to this CR. However, a review of 3-SOP-SFP-001 (Spent Fuel Pit Cooling and Purification SystemOperation), Section 4. 1.1 (Filling SFP Transfer Canal form RWST) identifed that RWST Purification system boundaryvalves may not be adequatley controlled to prevent connection of the RWST to non-seismic piping while in Modes 1,2,3and 4.Immediate Action Description:Spoke with Shift Manager to verify SFP Transfer Canal not currently being filled from RWSTSuggested Action Description:Revise 3-SOP-SFP-001 to include mode restriction for filling SFP transfer canal from RWST; perform additional extent ofcondition review for other procedures.EQUIPMENT:Tag NameRWST-31Tag Suffix Name Component Code Process System CodeHCLS/SR/MR VESSELSIREFERENCE ITEMS:Type CodeCRLERPRCPRCDescriptionIP3-2012-004852012-002-003-SOP-SI-0033-SOP-SFP-00 1TRENDING (For Reference Purposes Only):Trend TypeREPORT WEIGHTCUINPO BINNINGHEP FACTORKEYWORDSKEYWORDSKEYWORDSTrend Code3OPMGCM]1PKW-PROCEDURAL DEFICIENCYKW-TANKKW-NRC Entergy ADMIN I CR-IP3-2012-01768Initiated Date: 6/8/2012 14:20 Owner Group :Operations Support Mgmt IP3Current Contact:Current Significance: CClosed by: Main,Dennis E 10/15/2012 8:49Summary Description:Based on questions raised by NRC resident regarding mode restrictions on use of RWST Purification system associated withCR-IP3-2012-00485 (IP3 LER 2012-002-00), it appears that additional procedural restrictions for use of this system andoperation of its associated valves are required to prevent the RWST being connected to non-seismic systems or portionsthereof when in Modes 1, 2, 3 and 4.The review of this issue performed under CR-IP3-2012-00485 identified the need to revise 3-SOP-SI-003 (Recirculationand/or Purification of the Refueling Water Storage Tank) to place mode restrictions on use of this procedure which werecompleted under CA#3 to this CR. However, a review of 3-SOP-SFP-001 (Spent Fuel Pit Cooling and Purification SystemOperation), Section 4.1.1 (Filling SFP Transfer Canal form RWST) identifed that RWST Purification system boundaryvalves may not be adequatley controlled to prevent connection of the RWST to non-seismic piping while in Modes 1,2,3and 4.Remarks Description:Closure Description:Per Operations Department review, this CAT C CR issue was approved for closure by the Operations department. The issueresolution was captured, therefore the DPIC verified/performed the quality closure review, noted the trend codes applied andthen closed the CR.

Entergy OPERABILITY CR-IP3-2012-01768OperabilityVersion: 1Operability Code: ADMIN -NAImmediate Report Code: NOT REPORTABLEPerformed By: Andersen,Robert Jon 06/08/2012 14:27Approved By: Ras,Thomas 06/08/2012 15:28Operability Description:The condition described in the body of the CR describes a procedural issue and is adminstrative in nature and thereforeAdmin-N/A. Note that the RWST purification loop is currently not in service. This condition is not reportable perIP-SMM-LI- 108.Approval Comments:approved Entergy I ASSIGNMENTS I CR-IP3-2012-01768Version: 1Significance Code: CClassification Code: CORRECT/ADDRESSOwner Group: Operations Support Mgmt IP3Performed By: Harrison,Christine BAssignment Description:06/12/2012 11:06 Entergy REPORTABILITY I CR-IP3-2012-01768Reportability Version: 1Report Number:Report Code: NOT REPORTABLEBoilerplate Code:Performed By : BurneyMichael WReportability Description:This condition is administrative related not reportable.06/12/2012 12:47 Entergy I CORRECTIVE ACTION ICR-IP3-2012-01768CA Number:IGrouoINameIAssigned By: Operations Support Mgmt 1P3Assigned To: Operations Support Mgmt 1P3Subassigned To : Operations Procedure Staff IP3Dinelli,JohnSmyers Jr,Carl DennisGander,Thomas EOriginated By: Zzip2crgPerformed By: Balletta,John FSubperformed By: Balletta,John FApproved By:Closed By: Balletta,John F6/13/2012 07:40:557/3/2012 12:37:407/3/2012 12:36:397/3/2012 12:37:40Current Due Date: 07/06/2012 Initial Due Date: 07/06/2012CA Type: DISP -CA CA Priority: 3Plant Constraint: NONECA Description:Please review, including extent of condition, and assign further corrective actions as required.Response:CAs 2,3, and 4 issued.

Entergy CORRECTIVE ACTION CR-IP3-2012-01768Subresponse :Revised 3-SOP-SFP-001, Rev. 25, to include new P&L 2.1 and CAUTIONS indicating The RWST is inoperable wheneverit is connected to the purification system due to connection to non-qualified seismic piping. Sections 4.1.1 and 4.3.7SHALL NOT be performed in Modes 1 through 4 per LCO 3.5.4. (CR-IP3-2012-01768, CA-i)NSE 99-3-035 SFPC, Rev. 1, states that check valve AC-726B must be tested ( i.e. exercise closed ) prior to placing thepurification loop in service to demonstrate isolation capability and take credit for this passive, Safety Related, Class Iisolation boundry. This is accomplished by scheduleing and implementing WR 00-05301-00. This implies if WR00-05301-00 is NOT implemented prior to placing the purification loop in service, procedures need to prohibit openingAC-727B or SI-841 in modes I through 4 to ensure the purification loop return line is isolated.WR 00-05301-00 was canceled on 1/12/01.Noted 3-SOP-SFP-001, Rev. 25, Section 4.7.1, directs opening AC-727B and SI-841.Added the same new CAUTION to 3-SOP-SFP-001, Rev. 25, Section 4.7.1, indicating The RWST is inoperable wheneverit is connected to the purification system due to connection to non-qualified seismic piping. Section 4.7.1 SHALL NOT beperformed in Modes 1 through 4 per LCO 3.5.4. (CR-IP3-2012-01768, CA-I)Noted 3-PT-V055, EXERCISE CLOSE OF AC-726B, RWST PURIFICATION RETURN CHECK VALVE is currentlyactive. This test references SP-LIC-03-02, Reissue SP-LIC-03-01 with Supplemental Guidance on Dedicated Operator forCR-IP3-2003-308, CA-3: NRC Guidance on Use of Operator Action, dated March 4, 2003.Issue CA to determine if SP-LIC-03-02, Reissue SP-LIC-03-01 with Supplemental Guidance on Dedicated Operator forCR-IP3-2003-308, CA-3: NRC Guidance on Use of Operator Action, dated March 4, 2003 is still effective and valid.Issue CA to identify other procedures that may open valves AC-727B or SI-841 in modes I through 4. Revise procedures asnecessary to meet the requirements of NSE 99-3-035 SFPC, Rev. 1Issue CA to determine if 3-PT-V055, EXERCISE CLOSE OF AC-726B, RWST PURIFICATION RETURN CHECKVALVE may be used in place of WO 00-05301-00 to meet the requirements of NSE 99-3-035 SFPC, Rev. 1.Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768CA Number: 2NameAssigned By: Operations Procedure Mgmt IP3 Balletta,John FAssigned To: Licensing Mgmt IP3 Walpole,Robert WSubassigned To: Licensing Staff lP3 Prussman,Stephen GOriginated By: Balletta,John F 7/3/2012 12:31:23Performed By: Walpole,Robert W 9/24/2012 16:39:56Subperformed By: Prussman,Stephen G 9/24/2012 11:42:47Approved By:Closed By: Walpole,Robert W 9/24/2012 16:39:56Current Due Date: 09/27/2012 Initial Due Date: 09/27/2012CA Type: ACTION CA Priority: 4Plant Constraint: #NONECA Description:Determine if SP-LIC-03-02, Reissue SP-LIC-03-01 with Supplemental Guidance on Dedicated Operator forCR-IP3-2003-308, CA-3: NRC Guidance on Use of Operator Action, dated March 4, 2003 is still effective and valid.Response:see discussion below.Subresponse :SP-LIC-03-02 dated March 4, 2003 was issued to update SP-LIC-03-01. The memo referenced 4 NRC documentsproviding guidance on manual action. ?The need for manual action can arise in a number of contexts (e.g. to support asurveillance test, to support a temporary system configuration during maintenance or to address a degraded ornon-conforming condition). The NRC guidance was written primarily for use of manual action whendegraded/non-conforming conditions are not accepted as is (e.g., manual testing of boron versus N32 shutdown indicationfor TRM) but are also applicable to other cases such as temporary operation of a system in a configuration that it wasdesigned for such as surveillance testing (e.g., opening normally closed manual containment isolation valves, SI pumprecirc test, RWST purification).?The NRC identified other examples in which licensees failed to recognize that aligning nonseismic piping to the RWSTwould require TS LCO action statement entry, system modifications, or license amendments in Information Notice2012-01. ?LCO 3.0.2 does allow intentionally relying on TS actions for reasons that include, but are not limited to,performance of surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.However, TS would not allow applying compensatory measures, such as manual actions in place of the closed boundaryvalve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expresslypermit operation under such measures or the licensee can demonstrate that the RWST still meets the TS definition ofoperability without reliance on compensatory measures.? ?Applying compensatory measures for TS required equipment inlieu of meeting the requirements of the LCO could constitute a change to the TS, which is prohibited by 10 CFR50.59(c)(1)(i) without prior NRC approval. NRC Inspection Manual Part 9900, ?Operability Determinations &Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety,? doesallow licensees to use compensatory measures when a licensee discovers a structure, system, or component is degraded,nonconforming, or inoperable; however, the Part 9900 guidance is not applicable to planned maintenance activities. ?Conclusion ? Reliance on manual action still requires the provisions identified in SP-LIC-03-02 to be met when manualaction is taken. However, planned maintenance cannot rely on manual action for a longer period of time than the allowedoutage time for the affected LCO absent NRC approval.Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768Attachments:Subresponse DescriptionIN-2012-01Subresponse DescriptionSP-LIC-03-02

Attachment

HeaderDocument Name:luntitledDocument LocationPSubresponse DescriptionAttach Title:

UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONOFFICE OF NEW REACTORSWASHINGTON, DC 20555-0001January 26, 2012NRC INFORMATION NOTICE 2012-01: SEISMIC CONSIDERATIONS-PRINCIPALLYISSUES INVOLVING TANKSADDRESSEESAll holders of an operating license or construction permit for a nuclear power reactor underTitle 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing ofProduction and Utilization Facilities," except those who have permanently ceased operationsand have certified that fuel has been permanently removed from the reactor vessel.All holders of or applicants for a standard design certification, standard design approval,manufacturing license, or combined license issued under 10 CFR Part 52, "Licenses,Certifications, and Approvals for Nuclear Power Plants."PURPOSEThe U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to informaddressees of recent operating experience related to seismic concerns. The NRC expectsrecipients to review the information for applicability to their facilities and consider actions, asappropriate, to avoid similar problems. Suggestions contained in this IN are not NRCrequirements; therefore, no specific action or written response is required.DESCRIPTION OF CIRCUMSTANCESLaSalle County StationIn October 2010, NRC inspectors raised concerns about the adequacy of the seismic analysisfor the standby liquid control (SLC) test tanks at LaSalle County Station. The test tanks arenonsafety related but are located near safety-related components in the SLC system. Theinspectors determined that the seismic analysis had several errors and omissions. The analysisdid not include the tank legs and one of the pipe connections.The licensee revised its seismic analysis using the correct inputs and determined that when theSLC test tanks contain water they could potentially fall over or collapse during a seismic eventand impact safety-related equipment located nearby. By procedure, the water levels in the testtanks were allowed to be maintained at 75 percent full following testing. As a corrective action,the licensee drained the test tanks and revised its procedure to require that the test tanks bedrained after testing. The revised analysis also determined that the test tanks would notcollapse during a seismic event if they are empty.ML11292A175 IN 2012-01Page 2 of 5The licensee stated that the original design for LaSalle County Station did not consider thepossibility of nonsafety-related, nonseismically-qualified items falling over during a seismicevent. This was identified as an industry issue near the completion of the plant's construction.The site took action to address this issue; however, the original design analysis for the SLC testtanks was determined to be inadequate.Besides the corrective actions mentioned above, the licensee revised its procedure for the SLCsystem testing to state that the SLC system must be declared inoperable when the test tankscontain water. The licensee is considering additional corrective actions.The following documents contain additional information on these issues at LaSalle CountyStation:NRC, "LaSalle County Station, Units 1 and 2 Component Design Basis Inspection(CDBI) 05000373/2010006(DRS); 05000374/2010006(DRS)," dated February 15, 2011,Agencywide Documents Access and Management System (ADAMS) AccessionNo. ML110460708Exelon Generation Company, "Licensee Event Report 2010-003-00," LaSalle CountyStation, dated December 21, 2010, ADAMS Accession No. ML103560658River Bend StationOn January 14, 2009, a licensee investigation of operational practices related to the SLCsystem concluded that, from March 14, 2003, to October 28, 2008, a seismic event could haverendered the SLC system incapable of performing its design safety function as credited in thestation accident analysis. Although the safety significance of this event was low, the licenseereported it in accordance with 10 CFR 50.73, "Licensee Event Report System," as an operationprohibited by technical specifications (TS) and a loss of the safety function of the SLC.This condition resulted from an inadequately evaluated change made to a surveillance testprocedure that allowed water to remain in the SLC test tank following testing. The test tank isclassified as a seismic Class 2 component, which means that it is designed and installed so thatits failure cannot damage equipment important to safety as a result of a seismic event.However, the test tank is not seismically qualified while water is in the tank because thiscondition was not analyzed. Therefore, a seismic event could potentially render both trains ofSLC inoperable if it occurred when water was left in the test tank. As a corrective action, thelicensee put administrative controls in place to ensure that the tank is drained after testing andrevised its surveillance test procedures.On August 27, 2009, following maintenance on SLC pump B, operators filled the SLC test tankto perform a test. The test was aborted when the pump failed to start. The test tank wasdrained and normal system lineup was restored. On August 28, 2009, NRC inspectorsobserved 3 to 5 inches of water in the test tank and informed the licensee. The licenseedeclared both trains of SLC inoperable and entered an 8-hour action statement for theassociated limiting condition for operation (LCO). The licensee determined that the two valvesused to fill the test tank for the SLC pump operability test were not tightly closed, allowing slowleakage into the test tank. The licensee closed the two valves and drained the test tank to exitthe action statement for the LCO. The as-found condition was evaluated and it was determined IN 2012-01Page 3 of 5that the amount of water present would not have caused a failure of the tank with a design basisseismic event.The following documents contain additional information on these issues at River Bend Station:Entergy Operations, Inc., "Licensee Event Report 50-458/09-001-00," River BendStation, dated March 11, 2009, ADAMS Accession No. ML090760981NRC, "River Bend Station-NRC Integrated Inspection Report 05000458/2009002,"dated May 8, 2009, ADAMS Accession No. ML091280577NRC, "River Bend Station-NRC Integrated Inspection Report 05000458/2009004,"dated November 12, 2009, ADAMS Accession No. ML093160691Shearon Harris Nuclear Power PlantOn May 24, 2010, the refueling water storage tank (RWST) at Shearon Harris Nuclear PowerPlant was aligned to the nonseismic fuel pool purification system (FPPS), causing the RWST tobe made inoperable. The RWST is a safety-related system that is seismically qualified anddescribed in TS. The FPPS is a nonsafety-related, nonseismic system that can becross-connected to the RWST by a safety-related boundary valve that is normally closed.On March 3, 2006, the licensee revised a procedure for the FPPS to permit purification of theRWST in plant operating Modes 1 through 4. The evaluation under 10 CFR 50.59, "Changes,Tests and Experiments," to support the procedure revision credited an operator action tomanually close the open boundary valve and incorrectly concluded that this compensatorymeasure would maintain the RWST operable. NRC inspectors determined that opening theboundary valve while the plant was operating in Modes 1 through 4 would make the RWSTinoperable regardless of what administrative controls were in place to close the valve.The licensee determined that one of the causes of the event was ambiguous guidance used forits 10 CFR 50.59 evaluations. It determined that the FPPS procedure change resulted in adeviation from General Design Criterion 2, "Design Bases for Protection against NaturalPhenomena," of Appendix A, "General Design Criteria for Nuclear Power Plants," to10 CFR Part 50, which requires prior NRC approval to perform the activity. The licensee'scorrective actions include changing the FPPS procedure to remove the capability to purify theRWST in Modes 1 through 4 and clarifying its procedural guidance for 10 CFR 50.59evaluations regarding the impact of proposed activities on the design and licensing basis.The following documents contain additional information on these issues at Shearon HarrisNuclear Power Plant:Progress Energy, "Licensee Event Report 50-400/2010-003-00," Shearon Harris NuclearPower Plant, dated November 15, 2010, ADAMS Accession No. ML1 03270052NRC, "Shearon Harris Nuclear Power Plant-NRC Integrated InspectionReport 05000400/2010005," dated January 28, 2011, ADAMS AccessionNo. ML110280469 IN 2012-01Page 4 of 5A description of other plants that have also had seismic-related issues involving the SLC orRWST is available at ADAMS Accession No. ML1 1292A190.BACKGROUNDRecent events have increased industry focus on the potential impact of seismic events. Theseinclude the earthquake and tsunami in Japan on March 11, 2011, that affected the FukushimaDai-ichi nuclear plant and the U.S. earthquake near the North Anna Power Station site onAugust 23, 2011 (Event Notice 47201). On September 1, 2011, the NRC issued, in the FederalRegister, "Draft Generic Letter 2011-XX: Seismic Risk Evaluations for Operating Reactors"(ADAMS Accession No. ML1 11710783), to solicit public comment on the potential NRC requestthat licensees reevaluate their vulnerability to seismic events.Lists of recent NRC generic communications, inspection findings, and licensee event reportsrelated to seismic issues are available at ADAMS Accession Nos. ML1 1292A191,ML1 1292A1 92, and ML1 1292A1 97, respectively.DISCUSSIONThis IN provides examples and references to events in which licensees failed to recognizevarious seismic considerations and system alignment issues that could impact safety. The NRCstaff has identified recent concerns about SLC test tanks that were not seismically qualifiedwhen they contained water. This operating experience may apply to other tanks found on site atnuclear plants. The NRC identified other examples in which licensees failed to recognize thataligning nonseismic piping to the RWST would require TS LCO action statement entry, systemmodifications, or license amendments.The SLC test tanks described in this IN were not safety-related but those at River Bend Stationwere required to be seismically qualified because they could potentially impact nearbysafety-related equipment during a seismic event. Incorrect seismic structural analyses orinadequately reviewed procedure changes led to licensees using tanks, such as the SLC testtanks, in a manner that left them vulnerable to seismic hazards. Operating experience indicatesthat it is important to verify that the SLC system test tanks and similar tanks have adequateseismic analysis and are procedurally controlled to ensure that seismic vulnerabilities areappropriately managed and TS are followed.TS requirements for safety systems are derived from a licensee's Final Safety Analysis Report,and are designed to ensure that the plant is operated in accordance with the current licensingbasis. In accordance with 10 CFR 50.36, "Technical Specifications," when an LCO is not met,the licensee is required to "shut down the reactor or follow any remedial action permitted by thetechnical specifications until the condition can be met." Intentionally aligning the seismicallyqualified RWST piping to the nonseismic FPPS piping by opening a boundary valve,immediately calls into question the full seismic qualification and, subsequently, the operability ofthe RWST system. LCO 3.0.2 requires that upon discovery of a failure to meet an LCO, therequired actions of the associated conditions must be met. If a boundary valve is discovered tobe open when it must be closed to support RWST operability, then the RWST is inoperable; TSfor the RWST would be met by following the required actions of the associated conditions.LCO 3.0.2 does allow intentionally relying on TS actions for reasons that include, but are notlimited to, performance of surveillances, preventive maintenance, corrective maintenance, orinvestigation of operational problems. However, TS would not allow applying compensatory IN 2012-01Page 5 of 5measures, such as manual actions in place of the closed boundary valve, for periods longerthan the TS completion time for restoring the RWST to operable status, unless the TS expresslypermit operation under such measures or the licensee can demonstrate that the RWST stillmeets the TS definition of operability without reliance on compensatory measures. In the caseof the RWST alignment to the FPPS, the TS for the RWST specified no such allowance, and thelicensee had not demonstrated RWST operability with the FPPS boundary valve open.Licensees should exercise caution when considering the use of compensatory measures forplanned maintenance activities. Applying compensatory measures for TS required equipment inlieu of meeting the requirements of the LCO could constitute a change to the TS, which isprohibited by 10 CFR 50.59(c)(1)(i) without prior NRC approval. NRC Inspection ManualPart 9900, "Operability Determinations & Functionality Assessments for Resolution of Degradedor Nonconforming Conditions Adverse to Quality or Safety," does allow licensees to usecompensatory measures when a licensee discovers a structure, system, or component isdegraded, nonconforming, or inoperable; however, the Part 9900 guidance is not applicable toplanned maintenance activities.The NRC expects recipients to review the information in this notice for applicability to theirfacilities and consider actions, as appropriate, to avoid similar seismic concerns at their sites.CONTACTThis IN requires no specific action or written response. Please direct any questions about thismatter to the technical contacts listed below or to the appropriate Office of Nuclear ReactorRegulation (NRR) project manager.RA/ by JLuehman for RA/ by SBahadur forLaura A. Dudes, Director Timothy J. McGinty, DirectorDivision of Construction Inspection Division of Policy and Rulemakingand Operational Programs Office of Nuclear Reactor RegulationOffice of New ReactorsTechnical Contact: Mark King, NRR301-415-1150E-mail: Mark.Kinqa-nrc..ovNote: NRC generic communications may be found on the NRC public Web site,http://www.nrc.qov, under NRC Library/Document Collections/Generic Communications.

IN 2012-01Page 5 of 5measures, such as manual actions in place of the closed boundary valve, for periods longerthan the TS completion time for restoring the RWST to operable status, unless the TS expresslypermit operation under such measures or the licensee can demonstrate that the RWST stillmeets the TS definition of operability without reliance on compensatory measures. In the caseof the RWST alignment to the FPPS, the TS for the RWST specified no such allowance, and thelicensee had not demonstrated RWST operability with the FPPS boundary valve open.Licensees should exercise caution when considering the use of compensatory measures forplanned maintenance activities. Applying compensatory measures for TS required equipment inlieu of meeting the requirements of the LCO could constitute a change to the TS, which isprohibited by 10 CFR 50.59(c)(1)(i) without prior NRC approval. NRC Inspection ManualPart 9900, "Operability Determinations & Functionality Assessments for Resolution of Degradedor Nonconforming Conditions Adverse to Quality or Safety," does allow licensees to usecompensatory measures when a licensee discovers a structure, system, or component isdegraded, nonconforming, or inoperable; however, the Part 9900 guidance is not applicable toplanned maintenance activities.The NRC expects recipients to review the information in this notice for applicability to theirfacilities and consider actions, as appropriate, to avoid similar seismic concerns at their sites.CONTACTThis IN requires no specific action or written response. Please direct any questions about thismatter to the technical contacts listed below or to the appropriate Office of Nuclear ReactorRegulation (NRR) project manager.IRA/ by JLuehman forLaura A. Dudes, DirectorDivision of Construction Inspectionand Operational ProgramsOffice of New ReactorsIRA/ by SBahadur forTimothy J. McGinty, DirectorDivision of Policy and RulemakingOffice of Nuclear Reactor RegulationTechnical Contact:Mark King, NRR301-415-1150E-mail: Mark.Kinqp(nrc..ovNote: NRC generic communications may be found on the NRC public Web site,http://www.nrc.-ov, under NRC Library/Document Collections/Generic Communications.ADAMS Accession Number: ML1 1292A175*via emailOFFICE NRR/DIRS/IOEB Tech Editor BC:NRR/DIRS/IOEB BC:RIII/DRP/BR2NAME MKing* JDougherty* JThorp NShah for KRiemer*DATE 12/19/11 12/21/11 12/21/11 12/19/11OFFICE D:NRR/DIRS BC: NRO/DSRA/SBPA BC:NRR/DSS/STSB BC:NRR/DE/EMCBNAME FBrown EMcKenna* REIliott* MMurphy*DATE 12/22/11 1/6/12 1/20/12 116/12OFFICE LA:NRR/DPR/PGCB PM:NRRPDPR/PGCB BC:NRR/DPR/PGCB LA:NRR/DPR/PGCBNAME CHawes BPurnell KMorganButler CHawesDATE 1/9/12 1/9/12 1/20/12 1/23/12OFFICE D:NRO/DCIP D:NRR/DPRNAME LDudes (JLuehman for) TMcGinty (SBahadur for)DATE 1/25/12 1/26/12OFFICIAL RECORD COPY

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HeaderDocument Name:luntitledDocument LocationFSubresponse DescrptionAttach Title:ISP-LIC-03-02 EntergyInteroffice CorrespondenceMarch 4, 2003SP-LIC-03-02MEMORANDUM TO: G. O'DonnellFROM: S. PrussmanSUBJECT: Reissue SP-LIC-03-01 With Supplemental Guidance On Dedicated Operator forCR-IP3-2003-308, CA-3: NRC Guidance on Use of Operator ActionReferences: 1. NRC Generic Letter NO. 91-18, Revision 1: Information to LicenseesRegarding NRC Inspection Manual Section on Resolution of Degradedand Nonconforming Conditions.2. NRC Inspection Manual, Part 9900 Technical Guidance," Section 1.0 -"Operable/Operability."3. Generic Letter 91-08, "Removal of Component Lists From TechnicalSpecifications," May 6, 1991.4. NRC Information Notice 97-78, "Crediting of Operator Actions in Place ofAutomatic Actions and Modifications of Operator Actions, IncludingResponse Times," October 23, 1997.CR-IP3-2003-308 was written to question the adequacy of TPC-02-0091 to SOP-CVCS-002.The issue was the adequacy of the administrative controls to assure continued operability of acontainment isolation valve. This memo is a reissuance of SP-LIC-03-01 issued to provideOperations with a summary of NRC guidance on the use of operator action and to apply thatguidance to the current SOP controls. This memo revises the prior memo to provide guidance on"dedicated operator."NRC GUIDANCEReferences I to 4 provide an overview of NRC guidance for manual action. The need formanual action can arise in a number of contexts (e.g. to support a surveillance test, to support atemporary system configuration during maintenance or to address a degraded or non-conformingcondition). The NRC guidance was written primarily for use of manual action whendegraded/non-conforming conditions are not accepted as is (e.g., manual testing of boron versusN32 shutdown indication for TRM) but are also applicable to other cases such as temporaryoperation of a system in a configuration that it was designed for such as surveillance testing (e.g.,opening normally closed manual containment isolation valves, SI pump recirc test, RWSTpurification).Degraded / Non-conforming ConditionsThe NRC guidance (Reference 1) for degraded/non-conforming conditions references theManual Chapter (Reference 2) guidance for determining operability. In that document isguidance on manual actions for determining operability as follows:

SP-LIC-03-01Page 2 of 4The first step in assessing the use of manual action is to define the significance of that actionconsidering:1. It is not appropriate to take credit for manual action in place of automaticaction for protection of safety limits to consider equipment operable.2. It is not expected that many determinations of operability for safety relatedequipment will be successful for manual action in place of automatic actionsince credit for manual initiation to mitigate the consequences of design basisaccidents should have been established as part of the licensing review of aplant.3. Manual action by a dedicated operator has been credited in the TS to closenormally isolated containment isolation valves that are opened (Reference 3).This was considered acceptable under administrative controls when thecapability of the operator to perform had to be assessed under guidelinessimilar to those identified below. The operator action is credited for renderinga valve operable while open and under administrative controls.Having defined the significance of the action and deciding to proceed, the NRC guidance says"using a dedicated operator for manual action is not acceptable without written procedures and afull consideration of all pertinent differences." Written procedures could include actions that arepart of a maintenance package that qualify as administrative controls. The pertinent differencesmust focus on the physical differences between manual and operator action and must include, butnot be limited to (adds guidance of Reference 3):1. The scope of the activity (specific actions required) and the licensedconditions (e.g., after an earthquake, after a LOCA, etc) with theirconsequences under which it must be performed,2. the ability to recognize input signals for action (includes operator recognitionand control room recognition),3. ready access to or recognition, of setpoints, design nuances that maycomplicate subsequent manual operation such as auto-reset, repositioning ontemperature or pressure,4. timing required for automatic action (include the ability and timing in gettingto the area if not stationed and the ingress /egress paths, use ANS 58.1 foroperator response time for non-dedicated operators),5. minimum manning requirements,6. emergency operation procedures written for the automatic mode of operation,7. training of personnel to accomplish the task before substitution of any manualaction for the loss of an automatic action,8. occupational hazards to be incurred such as radiation, temperature, chemical,sound, or visibility hazards that could affect the action,9. consideration of single failure (typically no single failure for dedicatedoperator but credible errors for non-dedicated operator) and effects, and10. identification of support personnel and/or equipment required.The guidelines used for operability can also be used for inoperable equipment where credit is tobe taken for compensating action. Equipment not in TS that is inoperable does not require plantshutdown unless required by an assessment of plant safety. To justify continued plant operation,compensating action can be taken to minimize the need for or substitute for a function that hasfailed. Manual action is acceptable in these situations. The guidelines used above should be SP-LIC-03-01Page 3 of 4followed except that requirements for dedicated operators and single failure are not requiredwhere adequately justified. This justification must be approved using the 50.59 process andrecognize that the TS bases say dedicated operator. For purposes of the TS bases, dedicatedoperator is an operator who has been set aside for the purpose of the sole purpose of performingthe manual action. A non-dedicated operator is one who has other functions. Analysis can showthat there is sufficient time for the operator to perform the manual action based on proceduralrequirements or CR direction but the single failure must be taken as noted above. A recentexample is the Unit 3 loss of N32 source range used for Appendix R. The use of manual actionto assess shutdown by taking boron samples was contemplated as a compensating action until theN32 was fixed. This would have been justified as not requiring a dedicated operator but theavailability of trained personnel in a timely manner and a procedure would be necessary. A50.59 is required for compensating actions but the purpose is to verify that the compensatingaction did not impact other aspects of the facility as described in the FSAR.Temporary Operation of a System in a Condition it was Designed ForAs we have discovered during the course of operation, systems that were designed for operationsin a specific configuration may not meet all the requirements committed to in that configuration.Use of the guidance for making an operability call for a degraded / non-conforming condition isacceptable for this case for evaluation the change. One such case was the purification loop usedfor cleaning the RWST. That loop was non-seismic and did not have redundant and automaticisolation valves. Safety Evaluation 99-3-035 SFPC was written to allow operation of thepurification loop using manual action to meet design criteria and the evaluation was based uponthe criteria for the degraded /non-conforming conditions. The change is a design change since a50.59 was used for the action.Design Change Using Manual ActionDesign changes using manual action are generally considered unacceptable to the NRC staffunless they have reviewed and approved them. This does not mean all such changes areunacceptable as described previously. Reference 4 presents a number of instances where theNRC has found such modifications unacceptable. For example, operator action was credited toisolate nonessential SWS loads and to give the operator time to complete the action theevaluators assumed that the non-seismic intake canal would not fail for an hour. There are otherexamples that should be considered when taking this action.APPLICABILITY TO SOP-CVCS-002The guidance above for the preparation of a change to SOP-CVCS-002 would indicate that theprocedural change preparation should have considered in the screen the following:The scope of the activity -the activity is clear, close the valve.The conditions for performing the activity -following a CIS as directed by the CR (the valve isnot an auto closure valve since charging may be in use so the timing of the CR directive must beassessed based on system need and operator ability to perform the function)Input signal for action -CR notificationAffects on repositioniong -considers system operations that may affect ability to close.Timing required for action -considers when the action had to be complete and the ability of theoperator to complete it (e.g., most CIV require immediate closure so the operator is dedicatedand nearby whereas the charging closure is required when system will not be used). In this case SP-LIC-03-01Page 4 of 4a non-dedicated operator may be practical. To use a non-dedicated operator, it must be shownthat the procedure would direct the CR to have the operator close the valve, that here is sufficienttime to close the valve (e.g., operator closes consistent with design function and beforeenvironment precludes operation), and that single failure would be acceptable. Note that here theneed to change the TS bases would be identified.Minimum manning -one person to close the valve is sufficient.Procedures for auto actuation -intends that procedures that would contemplate an automaticactuation are modified (here it is the SOP modified by a note).Training -limited training is needed where the action is this simple and at CR direction.Occupational hazards -the specific environment needs to be defined to assure that the operatorcan perform the action (e.g., our design criteria is GDC 19 dose limits for operation of manualcontainment isolation valves and this should have been assessed). The flashlight requirementindicates some consideration of this.Single failure -Historically we have said no single failure of a dedicated operator (presumptionis that this is the only task and therefore error likelihood much lower) while a single failure couldoccur if there were a non-dedicated operator (standard design practice). Apply based ondedicated or non-dedicated.Support equipment / personnel -here that is flashlight, radio and CR direction.cc: J. McCannP. RubinJ. JaneckyA. WilliamsS. PetrosiJ. VentosaJ. BubniakR. LongA. Small Entergy CORRECTIVE ACTION I CR-IP3-2012-01768CA Number:3GroupINameIAssigned By: Operations Procedure Mgmt IP3Assigned To: Operations Procedure Mgmt IP3Subassigned To:Ballettajohn FGander,Thomas EOriginated By: Balletta,John FPerformed By: Gander,Thomas E7/3/2012 12:33:599/20/2012 10:14:42Subperformed By:Approved By:Closed By: Gander,Thomas E9/20/2012 10:14:42Current Due Date: 09/27/2012CA Type: ACTIONInitial Due Date: 09/27/2012CA Priority: 4Plant Constraint: #NONECA Description:Identify other procedures that may open valves AC-727B or SI-841 in modes 1 through 4. Revise procedures as necessary tomeet the requirements of NSE 99-3-035 SFPC, Rev. IResponse:The 4 other Unit 3 procedures that may open valves AC-727B or SI-841 in modes 1 through 4 are as follows:1. 3-ONOP-SFP-1 -This procedure was voided on 7/17/2002, but is still on the Operations G:\ drive as an activeprocedure. 3-ONOP-SFP-1, Rev. 12 moved from the Operations G:\ drive to the History directory. Action Complete2. 3-PT-V055, Rev. 2 -Currently contains P&L 2.1.2 which indicates a dedicated operator is required in Modes 1 through4 per SP-LIC-03-02. CA-2 was issued to Licensing to determine if SP-LIC-03-02 is valid.3. 3-SOP-RP-020 -This procedure currently does NOT contain any mode restrictions, but would probably only be usedduring refueling. A mode restriction was added to 3-SOP-RP-020 in revision 38 as an additional barrier to preventperforming this procedure in Modes 1 through 4. Action Complete4. 3-SOP-SI-003, Rev. 23 -Currently contains P&L 2.1 which indicates this procedure cannot be performed in modes Ithrough 4 until LER-2012-002-00 is resolved. No action requiredSubresponse :Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768CA Number: 4Group NameAssigned By: Operations Procedure Mgmt IP3 Balletta,John FAssigned To: Operations Procedure Mgmt IP3 Gander,Thomas ESubassigned To:Originated By: Balletta,John F 7/3/2012 12:36:12Performed By: Gander,Thomas E 7/25/2012 11:47:35Subperformed By:Approved By:Closed By: Gander,Thomas E 7/25/2012 11:47:35Current Due Date: 09/25/2012 Initial Due Date: 09/25/2012CA Type: CAT C-CORRECT CA Priority: 3Plant Constraint: #NONECA Description:Revise 3-SOP-SFP-001, Rev. 25, to include new P&L 2.1 and CAUTIONS indicating The RWST is inoperable whenever itis connected to the purification system due to connection to non-qualified seismic piping. Sections 4.1.1 and 4.3.7 SHALLNOT be performed in Modes 1 through 4 per LCO 3.5.4.Response:3-SOP-SFP-001, Rev. 25, contains new P&L 2.2 and steps indicating The RWST is inoperable whenever it is connected tothe purification system due to connection to non-qualified seismic piping. Sections 4.1.1, 4.7. 1, and 4.3.7 SHALL NOT beperformed in Modes 1 through 4 per LCO 3.5.4. (CR-IP3-2012-01768, CA-I)Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768CA Number: 5Group, NameAssigned By: Operations Support Staff lP3 Main,Dennis EAssigned To: Operations Support Mgmt IP3 Cramer,Thomas ASubassigned To :Originated By: Zzip2crg 9/25/2012 08:25:20Performed By: Main,Dennis E 9/28/2012 07:58:03Subperformed By:Approved By:Closed By: Main,Dennis E 9/28/2012 07:58:03Current Due Date: 10/04/2012 Initial Due Date: 10/04/2012CA Type: CR CLOSURE REVIEW CA Priority: 4Plant Constraint: #NONECA Description:CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW THE CR IN ACCORDANCE WITH EN-LI-102, SECTION 5.10. AND THE EN-LI-102-02CLOSURE CHECKLIST AND APPROVE / DISAPPROVE FOR CLOSURE.Response:CR is not ready for closure. Review of Licensing's response to CA-2 determined that 3-PT-V55 still needs to be revised.CA-6 issued to Ops Procedure group to revise 3-PT-V55.Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768, I UmleUEiUGroupINameIAssigned By:Assigned To:Subassigned To:Operations Support Staff IP3Operations Procedure Staff IP3Main,Dennis EBalletta,John FOriginated By: Main,Dennis E 9/28/2012 07:57:46Performed By: Balletta,John F 10/12/2012 07:00: 1ISubperformed By:Approved By:Closed By: Balletta,John F 10/12/2012 07:00:1"Current Due Date: 10/17/2012 Initial Due Date:CA Type: CAT C-CORRECT CA Priority:Plant Constraint: #NONECA Description:Revise 3-PT-V55 based on Licensing response to CA-2.10/17/20123Response:3-PT-V055 has been revised and approved. It is available in MERLIN on 10/15/12.Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION CR-1P3-2012-01768CA Number:7GroupINameIAssigned By: Operations Support Staff IP3Assigned To: Operations Support Mgmt IP3Subassigned To:Main,Dennis ECramer,Thomas AOriginated By: Zzip2crg 10/12/2012 09:27:4(Performed By: Main,Dennis E 10/15/2012 08:48:3(Subperformed By:Approved By:Closed By: Main,Dennis E 10/15/2012 08:48:3(Current Due Date: 10/24/2012 Initial Due Date: 10/24/2012CA Type: CR CLOSURE REVIEW CA Priority: 4Plant Constraint: #NONECA Description:CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TOCLOSE. REVIEW THE CR IN ACCORDANCE WITH EN-LI-102, SECTION 5.10. AND THE EN-LI-102-02CLOSURE CHECKLIST AND APPROVE / DISAPPROVE FOR CLOSURE.Response:CR has been reviewed in accordance with EN-LI-102, section 5.10 and the CAT C closure checklist of EN-LI-102-002.Procedure revision referenced in CA-6 has been verified to be in Merlin. CR is approved for closure.Subresponse :Closure Comments:

Entergy CONDITION REPORT CR-IP3-2012-03339Originator: De Donato,Anthony JOriginator Group: P&C Eng Codes Staff IP3Supervisor Name: Azevedo,Nelson FDiscovered Date: 10/23/2012 10:04Originator Phone: 6683Operability Required: NReportability Required: NInitiated Date: 10/23/2012 10:10Condition Description:During response to Incoming Letter RA-12-128 RAI Regarding Proposal to Align RWST and SFP Purification System forUnit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last ISTProgram (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, ithas been determined that they should be added to the U3 IST Program. There are no operability issues, since the operabilityof these four manual valves and the one check valve has been demonstrated every two years during system usage, and thecheck valve is closure tested every two years.Immediate Action Description:Suggested Action Description:Assign to Codes Programs.TRENDING (For Reference Purposes Only):Trend TypeHEP FACTORAUKEYWORDSKEYWORDSINPO BINNINGREPORT WEIGHTKEYWORDSTrend CodePESPCKW-VALVEKW-ISTER4WKW-PROGRAMMATIC DEFICIENCY Entergy ADMIN CR-IP3-2012-03339Initiated Date: 10/23/2012 10:10 Owner Group :P&C Eng Codes Mgmt IP3Current Contact:Current Significance: CClosed by:Summary Description:During response to Incoming Letter RA-12-128 RAI Regarding Proposal to Align RWST and SFP Purification System forUnit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last ISTProgram (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, ithas been determined that they should be added to the U3 IST Program. There are no operability issues, since the operabilityof these four manual valves and the one check valve has been demonstrated every two years during system usage, and thecheck valve is closure tested every two years.Remarks Description:Closure Description:

Entergy I ASSIGNMENTS I CR-IP3-2012-03339Version: 1Significance Code: CClassification Code: CORRECT/ADDRESSOwner Group: P&C Eng Codes Mgmt IP3Performed By: Harrison,Christine BAssignment Description:10/25/2012 10:36 Entergy CORRECTIVE ACTION CR-IP3-2012-03339CA Number: 1Group .Name IAssigned By: P&C Eng Codes Mgmt IP3 Tesoriero,Michael VAssigned To: P&C Eng Codes Mgmt IP3 Zarrella,JosephSubassigned To : P&C Eng Codes Staff IP3 De Donato,Anthony JOriginated By: Zzip2crg 10/25/2012 13:26:21Performed By: De Donato,Anthony J 11/9/2012 09:31:18Subperformed By:Approved By:Closed By: De Donato,Anthony J 11/9/2012 09:31:18Current Due Date: 11/15/2012 Initial Due Date: 11/15/2012CA Type: DISP -CA CA Priority: 3Plant Constraint: NONECA Description:You have been assigned as the Responsible Manager for this Category "C", Non-Significant Condition Report by the CRGAddress/correct the identified condition per EN-LI- 102. Perform disposition review, investigate as needed, and ensureactions are assigned as applicable to correct the problem.Response:CONDITION DESCRIPTION:During response to Incoming Letter RA-12-128 RAI Regarding Proposal to Align RWST and SFP Purification System forUnit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last ISTProgram (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, ithas been determined that they should be added to the U3 IST Program. There are no operability issues, since the operabilityof these four manual valves and the one check valve has been demonstrated every two years during system usage, and thecheck valve is closure tested every two years.RESPONSE:Valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 will be added to the U3 IST Program.CA-2 has been issued as follows: Update Unit 3 IST database to include valves AC-725, AC-727A, AC-726B, AC-727B,and SI-841. IST Program Owner is to work with Ops Testing and determine how stroke test requirements will be satisfiedand document these requirements in the IST database.There are no operability issues, since the operability of these four manual valves and the one check valve has beendemonstrated every two years during system usage, and the check valve is closure tested every two years.Subresponse :Closure Comments:

Entergy CORRECTIVE ACTION I CR-IP3-2012-03339CA Number:2GrouDINameIAssigned By: P&C Eng Codes Staff IP3Assigned To: P&C Eng Codes Staff lP3Subassigned To :De Donato,Anthony JDe Donato,Anthony JIOriginated By: De Donato,Anthony JPerformed By:Subperformed By:Approved By:Closed By:11/9/2012 09:29:27Current Due Date: 01/10/2013 Initial Due Date: 01/11/2013CA Type:. ACTION CA Priority: 4Plant Constraint: #NONECA Description:Update Unit 3 IST database to include valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841. IST Program Owner isto work with Ops Testing and determine how stroke test requirements will be satisfied and document these requirements inthe IST database.Response:Subresponse :Closure Comments: