NL-12-155, 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

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=Entergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President NL-12-155 December 13, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to Request for Additional Information on Proposed License Amendment Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank (TAC No. ME9263)Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64

REFERENCES:

1. Entergy Letter NL-12-090 to NRC Regarding Proposed License Amendment Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank, dated August 14, 2012 2. Entergy Letter NL-12-143 to NRC Regarding Response to Request for Additional Information on Proposed License Amendment Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank (TAC No. ME9263), dated October 25, 2012 3. Entergy Letter NL-12-154 to NRC Regarding Response to Request for Additional Information on Proposed License Amendment Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank (TAC No. ME9263), dated November 14, 2012 4. NRC Letters to Entergy, Request for Additional Information Regarding Proposal to Align the Refueling Water Storage Tank and The Spent Fuel Pool Purification System (TAC No. ME9263), (ML12284A446, ML12299A156, and ML12313A511), Dated November 15, 2012

Dear Sir or Madam:

Entergy Nuclear Operations, Inc, (Entergy) requested a License Amendment, Reference 1, to Operating 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. The proposed amendment would revise Technical Specification 3.5.4, to allow the non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system to be connected to the Refueling Water Storage Tanks (RWST) seismic piping by manual operation of a RWST seismically qualified Ao NL-12-155 Docket 50-286 Page 2 of 2 boundary valve under administrative controls for a limited period of time. On November 15, 2012 the 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 (see Attachments 1, 2 and 3 for the three letters).There are no new commitments being made in this submittal.

If you have any questions or require additional 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 in accordance with 10 CFR 50.91.I declare under penalty of perjury that the foregoing is true and correct. Executed on December 13, 2012.Sincerely, JAV/sp Attachments:

1. Response to Request for Additional Information (ML1 2284A446)Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank 2. Response to Request for Additional Information (ML1 2299A1 56)Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank 3. Response to Request for Additional Information (ML12313A51 1)Regarding Connection of Non Seismic Purification Line to Refuel Water Storage Tank

Enclosure:

Requested Documents cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service ATTACHMENT 1 TO NL-12-155 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (ML12284A446)

REGARDING CONNECTION OF NON SEISMIC PURIFICATION LINE TO REFUEL WATER STORAGE TANK ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 NL-12-155 Docket 50-286 Attachment 1 Page 1 of 5 By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request for additional 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 Water Storage 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 a RWST seismically qualified boundary valve under administrative controls for a limited period of time for filtration for removal of suspended solids from the RWST water. The NRC staff, in its letter of November 15, 2012 (ML12284A446), identified that additional information was required in their review as follows: Question 1 A single failure of these now open RWST boundary valves needs to be considered.

IP3's licensing basis 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 of Alternative Source Te.rm (TAC No. MC3351)" (ADAMS Accession No. ML050750431) assumed the RWST 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 and containment spray systems [ESF systems that recirculate sump water] are switched to the recirculation phase. This requires that water from the containment sump replace the RWST as the ESF systems water supply by realigning several system valves that interface between these ESF systems and the RWST and the pathways leading back to the RWST. If these system valves leak by design or the leakage of these valves is unknown, a leakage path between the containment sump and the RWST and any interfacing piping may exist. For the design basis LOCA radiological analyses, it is assumed that 40% of the core iodine inventory is mixed homogeneously and instantaneously 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.

Per Regulatory Guide 1.183, Regulatory Position 5.1.2, any piping downstream of the failed valve that is non-safety related or not in technical specifications would not be credited in the design basis radiological analyses.

Therefore, the proposed change would create a potential release pathway for radioactivity to the environment which is not considered in the current design basis accident analyses.An active failure of the boundary valve would allow any radioactive ESF leakage to the RWST tank or 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, impact the assumptions for the most limiting Single active failure considered in the licensing basis accident analysis and the resulting consequences.

If this proposed change results in a new limiting single active failure assumption, please provide the inputs, methods 1 and results for the revised accident analysis in order for the staff to conduct an independent analysis to confirm radiological doses would remain below the criteria in 10 CFR 50.67.As an alternative to the information requested above, to address NRC staff concerns, provide a justification for creditable actions 2 to be taken to prevent and/or mitigate a radiological release through non-seismic piping while in the proposed configuration.

Justify how these actions would NL-12-155 Docket 50-286 Attachment 1 Page 2 of 5 not allow any increase in leakage of radioactivity to the environment which would increase the radiological 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 piping after a design basis accident, 2) the worst case single active failure (i.e. failure of the open boundary 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 time after a design basis accident for the plant to recirculate sump water, 6) the design leakage of any credited 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 methods 3 used to determine that any increased leakage (beyond the leakage in the current accident analyses), before or after closure of a credited boundary valve, does not increase the design basis accident doses used to confirm compliance with 10 CFR 50.67.Please provide any design drawings showing the valves and flow pathways described in the LAR or references to docketed material with this information.

Indicate which credited valves and piping are safety related, required to be operable by technical specifications and are powered by emergency power sources.In addition, the staff believes that the proposed note to Technical Specification

3.5.4 should

be modified to 1) identify the manual valves requiring operator action to close and 2) reference the administrative controls as described in the Technical Specification Bases. In this regard, an expanded discussion of the administrative controls should be included in the TS Bases. The discussion should address planned actions, use of dedicated/designated operators, procedures employed, timeliness goals, and operator shift turnover discussions.

1 Regulatory Guide 1.183 provides a method acceptable to the NRC for demonstrating compliance with 10 CFR 50.67.2 Regulatory Guide 1.183, Regulatory Position 5.1.2, provides a method acceptable to the staff for crediting mitigating systems.3 Regulatory Guide 1.183 provides a method acceptable to the NRC for demonstrating compliance with 10 CFR 50.67.Response Entergy is not proposing to revise the most limiting single failure so, as an alternative, Entergy is providing justification for creditable actions to be taken to prevent and/or mitigate a radiological release through non-seismic piping while in the proposed configuration.

As noted in our previous submittals, administrative controls would be put into place to close isolation valves 725 and 727A on the suction line from the RWST and to close valve 727B on the return line to the RWST. The check valve 726B does not require operator action to close. These valves are all seismic 1 as noted on drawing 9321-F27513 sheet 2 sent to you-in our letter of November 14, 2012. Since these pairs of valves are in series the single failure of one of the valves would be mitigated by the other valve. Note that original plant design and licensing did not consider the failure of a check valve as an active failure and failure of a manual valve is a passive failure. 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 and not on the potential for source term leakage. The time to isolate the flow from the RWST, based NL-12-155 Docket 50-286 Attachment 1 Page 3 of 5 upon 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 Computer System sends a signal to provide an alarm prior to the RWST level reaching 36 feet (the Critical Functions Monitoring System was recently integrated with other computer systems as the Plant Integrated Computer System (PICS)). The time to drain from below the overflow point (e.g., 36.7 feet) to the required RWST level of 35.4 feet is 100.3 minutes. The time to drain from the 36 foot level to the required RWST level of 35.4 feet is about 46 minutes. If the need for the RWST were to occur due to an accident or earthquake then 100.3 minutes or more is available because there are indications and contact with the CR is maintained.

A pipe break during normal operation is possible without the operator seeing the flow. Therefore 46 minutes is considered the time available for operator action under all circumstances.

The occurrence of the RWST alarm at 36 feet is presumed to initiate action to close the RWST isolation 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 closely coordinate with the CR and be in radio communication.

A verification walkdown was last performed on November 19, 2012 with the Nuclear NPO in the Unit 3 Control Room to simulate an end of shift meeting. After a simulated alarm, the NPO proceeded to the PAB at a normal pace and 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 the following 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' SI Pump Room).d) SI-841, Spent Fuel Pit Demineralizer To RWST Isolation (34' SI Pump 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 margin of time. Should this action be initiated by a DBE, there would be more time available and the pathways are lighted by Appendix R lights.The time to isolate the flow from the RWST is not based on the potential for source term leakage This is because no source term is available for leakage through any valves until the plant enters external 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 Full Scope Adoption of Alternative Source Term (TAC MC3351) dated March 22, 2005). After the RWST is injected into the containment the redundant internal recirculation pumps will be used instead of the external RHR pumps for suction from the sumps to inject into the core in order to minimize dose design basis accident doses. The internal recirculation pumps are also used to provide containment spray by opening motor operated valve 889A or 889B on the outlet line from the residual heat exchangers that are inside containment.

All of these pathways and valves are NL-12-155 Docket 50-286 Attachment 1 Page 4 of 5 part of the ECCS, controlled by TS, and powered by emergency power sources. After 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> the internal recirculation pumps are used to provide flow to the high head pumps through the 888A and 888B valves outside of containment for hot leg injection.

These flow paths are shown on Drawings 9321 -F-27353 (in the enclosure) and 9321 -F-27503 (provided in the Entergy letter of November 14, 2012).The single active failure assumptions for the boundary valves are also a function of the pathway used for the low head to high head external recirculation.

In the low head to high head injection pathway described above, the discharge of the internal recirculation pumps is directed to the 31 and 33 high head safety injection (HHSI) pumps through valves 848A (31 pump) and 848B (33 pump). When using this pathway there are dual isolation valves preventing pressurization of the suction line from the RWST (see check valve 847 and MOV 1810 on one line, and MOV 887A and 887B to the 32 HHSI pump are closed). The potential leakage path between the containment sump and the RWST occurs when a passive failure is postulated that prevents low head to high head 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 from the Containment Sump through MOV 885A and 885B. The RHR pump discharge to the suction line 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 MOV 882. The RHR pump discharge goes to HHSI pump 32 through manual valve 898. This discharge does not go to the 31 and 33 HHSI pumps because MOV 887A and 887B are closed (as well as 1810 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 would not have to be postulated.

Valves AC-727B and AC-726B do not require leak testing because they are located on the downstream side of the Class III piping boundary and are isolated from post LOCA recirculation fluid 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 is pressurized with sump fluid only following a single failure so that an additional single failure of a valve to close is not required.

Valve AC-727A is a boundary valve for the leak testing of valve 846 in 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 revised as follows: The proposed note to be added directly under actions will be revised to add the requested valves and 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 piping may be opened under administrative controls for up to 14 days per fuel cycle for filtration until the end of refuel outage 18.The bases ACTION section will be revised as follows:

NL-12-155 Docket 50-286 Attachment 1 Page 5 of 5"A note allows the RWST valves AC-727A, AC-727B and AC-725 that isolate non seismic piping to be opened under administrative control until the end of RO 18. The administrative controls will require a designated operator to be assigned to isolate the RWST as needed. The operator will be trained 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 as possible.

The operator will coordinate with the CR if leaving the PAB for activities such as shift turnover.

The operator shall discuss the functions to be performed when turning over to a designated operator during shift change. The controls are sufficient to assure that the TS required amount of water will be available under all conditions.

"

ATTACHMENT 2 TO NL-12-155 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (ML12299A156)

REGARDING CONNECTION OF NON SEISMIC PURIFICATION LINE TO REFUEL WATER STORAGE TANK ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 NL-12-155 Docket No. 50-286 Attachment 2 Page 1 of 3 By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request for additional 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 Water Storage 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 a RWST seismically qualified boundary valve under administrative controls for a limited period of time for filtration for removal of suspended solids from the RWST water. The NRC staff, in its letter of November 15, 2012 (ML12299A156), identified that additional information was required in their review as follows: Question 1 Describe 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 purification system or operation of the RWST boundary valves, or if too numerous, provide a summary of problems and the preventive actions taken.Response Operational Experience was not reviewed since this manual action had been credited by safety evaluation under RIS 2005-20 until the NRC position in Information Notice 2012-01 was reviewed and addressed.

Condition Reports of potential interest from November 1, 2002 have been identified and are in the enclosure.

Question 2 On page 4 of 7 of Attachment 1 to the licensee's submittal, it is stated, "The calculated time for operator action to close AC-725 or AC-727A and terminate flow is 46 minutes based on discharge from one end of the purification loop." Further down on that same page, it is stated, "The calculated time to reach the TS level of 35 feet 4 inches from 36 feet is 46 minutes." By these statements it appears that there is no margin, that is, it will take the operator the full 46 minutes to terminate flow from the RWST in time to comply with the TS limit. Please clarify or justify why no margin is necessary.

Response The 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 required functions based on the time it takes the operator to perform the function which is discussed in the response in Attachment 1.Question 3 On page 3 of 7 of Attachment 1 to the licensee's submittal, it is stated, "There is no dedicated operator..." On page 4 of 7, the licensee states that the procedure associated with purifying the NL-12-155 Docket No. 50-286 Attachment 2 Page 2 of 3 RWST requires "designated operators" to walk down the location of the refueling water purification pump switch and the four relevant valves. Traditionally, the NRC defines "dedicated" as being assigned to a certain task and no other(s), while "designated" means that a specific person is assigned to a task, but may have other assignments.

Clarify whether a dedicated or a designated operator will be used, or whether operators will be neither dedicated nor designated.

The NRC staff has not approved this kind of TS change, to date, without the use of a dedicated operator.Response The operator action requested was for a designated operator (one assigned and briefed on the task) rather than a dedicated operator (one assigned to a certain task and no other). This is based upon the indications available and the training provided as discussed in the original request (Entergy Letter NL-12-090 to NRC Regarding Proposed License Amendment Regarding Connection 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 in design by having internal recirculation pumps so that sump fluid is not recirculated outside containment 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 major LOCA (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 of Alternative Source Term (TAC No. MC3351)" (Accession No. ML050750431) contains this discussion).

The actual valve lineups are discussed in Attachment 1.Question 4 Describe the process used to validate the effectiveness of the procedures referenced in the submittal.

Response This action is a Time Critical Operator Action per OAP-1 15. A copy of the procedure is included in the Enclosure (see pages 25, 26 and 69).Question 5 Provide a copy of Procedure 3-SOP-SI-003, "Recirculation and or Purification of the Refueling Water Storage Tank".Response A copy is provided in the Enclosure.

Question 6 What verification and validation (V&V) processes were used to determine that the relevant operator actions could be done effectively and within the time constraints involved?

What sample of operators was used during V&V testing?

NL-12-155 Docket No. 50-286 Attachment 2 Page 3 of 3 Response This action is a Time Critical Operator Action per OAP-1 15, see Enclosure, which describes the validation required for this.Question 7 Does IP3 have a Time-critical Action Program to protect high-risk, time-limited actions from inadvertent change? If yes, is the proposed task sequence included in that program? If no, what controls are used to prevent inadvertent changes to the proposed operator actions or the time available to perform them?Response IPEC has a time critical action program as described in the responses to questions 4 and 6.Question 8 What cue(s) call the operators' attention to the Critical Functions Monitoring System when a computer point is in alarm?Response The CFMS has been replaced with PICS, but the process is the same. Per 3-SOP-SI-003 step 4.1.1 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 Users Guide. If this alarm is generated then the operator action to initiate isolation of the RWST is taken per the operator training.

ATTACHMENT 3 TO NL-12-155 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (ML12313A511)

REGARDING CONNECTION OF NON SEISMIC PURIFICATION LINE TO REFUEL WATER STORAGE TANK ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 NL-12-155 Docket No. 50-286 Attachment 3 Page 1 of 1 By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent request for additional 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 Water Storage 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 a RWST seismically qualified boundary valve under administrative controls for a limited period of time for filtration for removal of suspended solids from the RWST water. The NRC staff, in its letter of November 15, 2012 (ML12313A51 1), identified that additional information to supplement the October 25, 2012 letter was required in their review as follows: Question 2 In your response noted above, you indicated that the American Society of Mechanical Engineers (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 (10 CFR) 50.55a(b)(3)(vi), wherein the frequency for exercise testing for manual valves is required to be at intervals no longer than two years. Will the revised Indian Point Unit 3 (IP3) Inservice Testing (IST) Plan show the required test frequency for these manual valves as two years or less?Response The frequency will be two years.Question 3 In your response noted above, you indicated that ASME OM Code exercise testing was applicable 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., position indication verification or seat leakage testing)?

Other licensees have revisited their NRC Information Notice 91-56 evaluations, to ensure that leakage past these valves would not adversely affect their calculations of control room and offsite dose from post-Loss of Coolant Accident recirculation fluid.Response Valves AC-727B and SI-841 do not require leak testing since they are located on the downstream side of the Class III piping boundary and are isolated from post LOCA recirculation fluid by valves that are leak tested (SI-MOV-842, SI-MOV-843).

Valve AC-727A is part of the pressure boundary for the testing to valve SI-846 (RWST suction).

These tests are confirmatory of the post loss of coolant accident recirculation fluid dose analyses.

See attachment 1 for a more detailed discussion.

ENCLOSURE TO NL-12-155 REQUESTED DOCUMENTS 1. Drawings 9321-F-27353

2. Procedure OAP-1 15, "Operations Commitments and Policy Details" 3. Procedure 3-SOP-SI-003, "Recirculation and or Purification of the Refueling Water Storage Tank" 4. CR-IP3-2002-5092

5. CR-IP3-2003-1166, 3264, 4700, 4719 6. CR-IP3-2005-0239 7. CR-IP3-2007-0859 8. CR-IP3-2009-2219 9. CR-IP3-2-11-3729, 4483, 4515 10. CR-IP3-2012-1710, 1741, 1768, 3339 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 8 6 5 3 3540 8571 1-514 1~ -19352 SC SIT 7tF213'3.S-8599 2 S35 LIS.- 815 05, 12-- 'lL 1 9 3R 2-SISI- I --1 --~~~~~LN -11OCF 28 1315 T- EIR 0 2 1 1,-RE (T I SS aPLR85 IN117 1, 92 2 LSTH 316. 01 0 'S-47~Y~S3 06 5550 SE.., '%sS-ICs -S -R RS -ST~S -3 055 0C 1 "S R1 ~ -18 0r~ 14E S ' M3838 LIS U218 4 I -S -I.I 1A.86 3' 410.LE83 318C -IS-12 -S4. 2--2IO z~E" F HIPT5310 -.2 -N~ lC 50 -C-63 " C "-SS,86-023 C1-SI-SaCS 2O~ __________

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REFERENCES:

G E SF -- 11.C9 803 OE S05C. G-6751- REV. I 3. FIEE- SS.05 3T9RV O.. S530. 4-47D89 RFV.I o E 7:C 0-67639eS IEV, 3 H[] TE7EEEySTE 59508-LE- L1EI4-RSEERER ECJE0 FEAR TRW-0 ll ON83 E LOW LE IN _0 1=ýIITIONN m] -ONc _:n C , I TEST F- E ECIILL85.LCAI) MI.-IG ST.E 01 -I IN -OA -1G POINT D, ORTFOEF IS -TLED WITH -pUMP EM DWITH 1IT-11SIOPISON FL L IEFRSI. L 5 I -.E B I.LO* T LOW PINTI OH PEll M. NS IT-ED FIS NT DIS-E It, ET .S P.LINES IIN DI-TED TO THIRD S-TION OF THE SL 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 MITEO 2171, 2172 IS NE DTERMIAM BY 1 5Y1- FLOW 85S TO -T PIPI-REFERENCE INGS : 27193 -I~ IS SYSTM SHET I -CONTaINWENT 27201 _jIL rY --T SYS -iNSIO -T.1-NT 2-1 Z: _ IN IS & T 2 27363 CVL CHENIIOX O OUN T-C SYSTEM 1..... ""c CHEMIA -orc SYSTEM SHEET 27173 --T OOO T SYSTEM SHEET 2 2_33 N TO NL~- M EQUIPEN 27245 W THIM -WITEI SYSTEMI S SINNILING I- I-ATIN -ý SYSIEN 13 I-C-27-3 L E E I-THIS -WITH F-11-1 SF8854 P1OINT N. 68663C R & 1-3ER64 1055010N1N EINE -E. I -ofE-E -OSE 1-1 3OI3T~TS OS 1FLCI' DIESGRAMN-SAFETY INJECTION SYSTEM SHEET NO.I F321%F273S3142 8 6 T TYPE A/ISI/FSiR 4

a-Entergy Nuclear Northeast Procedure Use Is: O3 Continuous

[o Reference I Information Control Copy: Effective Date: 3//2 Page 1 of 79 OAP-115, Revision:

15 OPERATIONS COMMITMENTS AND POLICY DETAILS Approved By:ý " ý /I jk- -/ I R-E-SI-L Procedure Sponsor6SM/Desig~ee Date Team Staff Procedure Owner EDITORIAL REVISION ry OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 2 of 79 REVISION

SUMMARY

(Page 1 of 2)1.0 REASON FOR REVISION 1.1 Incorporated Supervisor feedback to clarify supervisory use of NA.2.0

SUMMARY

OF CHANGES 2.1 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 of misapplication".

The corrective action though, requested that a feedback be submitted to "clarify Supervisory use of N/A" in the specified situation.

Upon review with AOM, it was decided to re-apply the step with clarifications as to the conditions when N/A can be used by supervisory personnel only. This is an ALARA concern and safety concern. {Editorial 4.6.11}

z--Entergy OPERATIONS COMMITMENTS AND No: QAP-115 Rev. 15 POLICY DETAILS Page 3 of 79 TABLE OF CONTENTS Section Title Page 1.0 PURPOSE .........................................................................................................................

5 2.0 PRECAUTIONS AND LIMITATIONS

............................................................................

5 3.0 PREREQUISITES

..........................................................................................................

5 4.0 PROCEDURE

...........................................................................................................

6 4.1 Standard W atch Routine/Practices

....................................................................

6 4.1.1 CCR Conduct (Ref: 7.1.33) ...................................................................

6 4.1.2 Response to Annunciators:

...................................................................

7 4.1.3 Control Room Annunciator Tracking Log ...............................................

8 4.1.4 CCR Access {Ref: 7.1.14 and 7.1.20} ..................................................

9 4.1.5 Non-Outage CCR Activities

..................................................................

9 4.1.6 Response to Plant Events .....................................................................

9 4.1.7 Operations Department Briefs .............................................................

10 4.1.8 NRC Authentication Codes ..................................................................

12 4.1.9 Peer Checking .....................................................................................

12 4.1.10 Movements of Operators assigned duties under 0-AOP-SEC

-1 ...... 13 4.2 Expectations Related to I&C Activities in the CCR ...........................................

13 4.2.1 General Access ...................................................................................

13 4.2.2 Communications

...............................................................................

.14 4.2.3 Component Manipulations

..................................................................

14 4.3 Equipment Operation

.......................................................................................

15 4.3.1 General Guidelines

..............................................................................

15 4.3.2 Starting Equipment

/ Returning Equipment to Service: .........................

16 4.3.3 W ork Step List .....................................................................................

16 4.4 Use of Procedures

............................................................................................

17 4.4.1 General Guidelines

..............................................................................

17 4.4.2 Continuation of Partially Performed Procedures

..................................

19 4.4.3 Completed Procedures

.......................................................................

20 4.4.4 10 CFR 50.54 (x) and (y): ..................................................................

20 4.4.5 Components Out Of Desired Position ..................................................

22 4.5 Management Expectations

...............................................................................

22 OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 4 of 79 4.6 Fire Brigade Requirements

.............................................................................

23 4.7 Unit 2 Annunciator Window Color Coding .........................................................

24 4.8 Time Critical Operator Actions .........................................................................

26 4.9 Site Tagging Guidance .....................................................................................

27 5.0 RESPONSIBILITIES

...................................................................................................

29 6 .0 D E F IN IT IO N S ..................................................................................................................

3 1 7 .0 R E F E R E N C E S ................................................................................................................

32 8.0 RECORDS AND DOCUMENTATION

.........................................................................

35 Attachments ATTACHMENT 1, Siren Activation Event Data Sheet ................................................

37 ATTACHMENT 2, Work Step List ..................................................................................

39 ATTACHMENT 3, Authentication Code Log ..................................................................

41 ATTACHMENT 4, Unit 2 Time Critical Operator Actions ...............................................

42 ATTACHMENT 5, Unit 3 Time Critical Operator Actions ...............................................

61 ATTACHMENT 6, Time Critical Operator Action Validation

...........................................

79 IEnte& OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 5 of 79 1.0 PURPOSE 1.1 To provide guidance on implementing IPEC Operations Department commitments, policies, and expectations.

2.0 PRECAUTIONS

AND LIMITATIONS

2.1 Plant

operations personnel SHALL: 2.1.1 Operate safety-related systems and components within procedural operating limits (including log sheet operating bands) UNLESS a formal review process (e.g. NSEs, operability determinations) demonstrates the acceptability 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 PREREQUISITES None

4.0 tergy

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 6 of 79 PROCEDURE 4.1 Standard Watch Routine/Practices 4.1.1 CCR Conduct {Ref: 7.1.33)4.1.1.1 A professional CCR atmosphere SHALL be maintained as follows:* CCR access is limited to official business ONLY.* All shift team members SHALL be in conformance with the dress code specified in step 4.5.1." All personnel entering the CCR SHALL dress professionally including the wearing of shirts with collars.Hats/caps, shorts, t-shirts, and sneakers SHALL not be worn 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 communication is limited.* Personality conflicts SHALL NOT interfere with performance.

• Cursing is NOT allowed.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 7 of 79 4.1.1.2 Personnel permitted to enter the CCR controls area SHALL allow the operator clear access to controls and indications.

4.1.1.3 Food and drink in the CCR SHALL be limited to watch team members:* Food and drink SHALL be kept away from control panels.* Eating SHALL NOT detract from plant monitoring activities.

• Empty food containers/dishes SHALL NOT be left out for an 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 as soon as possible.4.1.2.2 Nuisance annunciators are defined as CCR alarms that satisfy one of the following:

• NOT valid for existing plant, system, or equipment conditions

• Result from loop or circuit failure* Valid, but at a repeat frequency that produces operator distraction 4.1.2.3 IF all of the following conditions are met, THEN nuisance annunciators may be removed from service without a T-Alt: 0 ARP evaluated and applicable actions taken based on plant, system, or equipment conditions.

• IF the annunciator is required to support operability, or is required by Emergency Procedures, THEN annunciator is declared inoperable and appropriate actions taken for inoperability.

• Alternate monitoring methods or other compensatory actions (i.e., increased tours, special log) implemented as necessary.

0 Removal from service entered in the Unit Log, and if applicable, the CCR Annunciator Tracking Log.0 Associated alarms are marked with an OUT OF SERVICE label.

OPERATIONS COMMITMENTS AND NO: QAP-li1 Rev. 15 POLICY DETAILS Page 8 of 79 SM approved disabling the alarm.4.1.2.4 IF a nuisance annunciator return to service is NOT anticipated before turnover, THEN the annunciator SHALL be entered on the CRS Turnover Sheet.4.1.2.5 IF a nuisance annunciator return to service is NOT anticipated within 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 document evaluation of operability and reportability, and to assess implementation of a Temporary Alteration.

4.1.3 Control

Room Annunciator Tracking Log 4.1.3.1 At Unit 3 The Control Room Annunciator Tracking Log SHALL be used to track the status of all illuminated/out-of-service control board annunciators in the Control Room.4.1.3.2 The Reactor Operator/Balance of Plant Operator is responsible for maintaining this log. This log SHALL be updated prior to each shift turnover as follows: a) All illuminated annunciators that are in service SHALL be annotated as such by placing an 'X' on the appropriate window of the laminated sheet in the tracking log.b) All out-of-service/impaired annunciators SHALL be annotated as such by placing a circle on the appropriate window of the laminated sheet in the tracking log.c) The reason for each illuminated or out of service annunciator SHALL be noted in the comments section on 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 test procedure number, etc.).4.1.3.3 During the shift turnover process, a review of the Control Room Annunciator Tracking Log SHALL be performed by the oncoming shift crewmembers to ensure that an accurate and thorough understanding of illuminated and out-of-service annunciators are clearly understood by the oncoming shift.4.1.3.4 Configuration Control of Annunciators during testing is controlled under OAP-21, Configuration Control of CCR Evolution/Test Interface.

OPERATIONS COMMITMENTS AND No: QAP-li1 Rev. 15 POLICY DETAILS Page 9 of 79 4.1.4 CCR Access {Ref: 7.1.14 and 7.1.201 4.1.4.1 The CRS OR RO SHALL authorize and manage Control Room access.4.1.5 Non-Outage CCR Activities 4.1.5.1 Maximum permitted concurrent tasks that affect the CCR SHALL be:* Determined by the SM: {Ref: 7.1.29}* IF differing concerns can NOT be resolved, THEN the SM SHALL make the final determination." Nominally 3 Tasks on U-3 4 Tasks on U-2 4.1.5.2 On-shift review of system issues is authorized as follows:* Special projects SHALL NOT interfere with the STA primary duties (Unit 2) {Ref: 7.1.23)4.1.6 Response to Plant Events 4.1.6.1 IF the CCR announces a plant fire, THEN:* A currently, or previously licensed IPEC operator meeting the minimum qualification requirements defined in IP-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 System Siren is sounding, THEN Unit 2 CCR SHALL:* COMPLETE ATTACHMENT 1, Siren Activation Event Data Sheet .{Ref: 7.1.16)

OPERATIONS COMMITMENTS AND No:QAP-ilS Rev. 15 POLICY DETAILS Page 10 of 79 4.1.7 Operations Department Briefs 4.1.7.1 The guidance provided in IP-SMM-HU-102, Pre-job Briefing and Post Job Critiques, SHALL normally be referred to for most briefs conducted by Operations Department personnel.

a) An exception to the above applies in the cases of reactivity management and plant transients where placards in the control rooms which are controlled by the Operator Aid Program shall be used for conducting these briefs.4.1.7.2 There are numerous sources of information available to enhance the pre-job briefings and post job critiques performed by 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 a means of enhancing or improving these communications processes.

4.1.7.3 The tools referenced in Step 4.1.7.2 may be employed at the discretion of the supervisor in charge. With the exception of transient briefs and reactivity management briefs (per Step 4.1.7.1 a)), IP-SMM-HU-102 provides adequate guidance for the conduct of Operations Department briefs, the supervisor may elect to use any of the sources referenced in Step 4.1.7.2 or 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 or Engaged" briefs. In circumstances where in the judgment of the supervisor (e.g. a tag out prepared by the supervisor to support an emergent job is being hung on short notice) a Reverse or Engaged brief is inappropriate.

The supervisor or other designated personnel should lead the brief. In those cases the lead should point out during the brief the reason for the exception.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 11 of 79 4.1.7.5 NO tasks should be assigned to field operators over the phone. All tasks are to be assigned and reviewed in the following manner: a) A face to face meeting between the person directing the task and the field operator.b) During the face to face meeting the operator and the person assigning the task SHALL ensure the operator has the correct procedure in hand.c) At the conclusion of the task, the operator SHALL return the marked up copy of the procedure to the FSS or CRS.d) The supervisor SHALL ensure proper place keeping was performed (the optimum being the supervisor was present to observe the evolution, providing feedback on the spot)." Feedbacks are to be submitted by the operator for any procedural enhancement

• Ensure the operator knows NOT to interpret steps.The operator is to stop, make the equipment safe and get the procedure clarified by the supervisor or the procedure revised.e) Exceptions to Step 4.1.7.5 of this procedure are: 1) Emergency Operating Procedures

2) Abnormal Operating Procedures

3) Alarm Response Procedures

-However, field ARP's shall be returned to the Control Room Supervisor for review of: Steps performed Place keeping Ensure replacement of marked up field copies 4) As directed by Shift Manager 5) Skill of the craft item, as designated in EN-OP-115, IPEC site specific attachment.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev._15 POLICY DETAILS Page 12 of 79 4.1.8 NRC Authentication Codes 4.1.8.1 The following apply to the reception and use of the daily NRC Authentication Codes: " NRC will generate and provide a single, four-digit alphanumeric sequence to each CCR during the daily plant communications check. (approximately 0400)" The NRC will state the current authentication code and give the new authentication code." The Control Room Operator taking the call will ensure the new code is written to ATTACHMENT 3 (Authentication Code 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 Checking 4.1.9.1 Peer Checking SHALL be performed as determined by the Operations Supervisor (CRS/FSS/SM) for equipment manipulations per EN-OP-1 15, Section 5.8 and Aft. 9.4 (flow chart), except during the performance of EOPs, AOPs, and ONOPs.4.1.9.2 WHEN Peer Checking is not used, THEN operators and supervisors SHALL USE Self Checking, STAR, and other error prevention techniques to ensure operational events do not occur.4.1.9.3 During off-normal or emergency conditions, Peer Checking should be restored when the plant has been stabilized or personnel become available, as determined by the CRS/SM.

OPERATIONS COMMITMENTS AND No: QAP-il1 Rev._15 POLICY DETAILS Page 13 of 79 4.1.10 Movements of Operators assigned duties under 0-AOP-SEC-1 4.1.10.1 Reactor Operators assigned to the ABFP building:* May leave the Control Room provided they take with them:* Radio OR other portable communication device* Assigned keys May not exit the building in an area that they are able to be observed from the site fence line. This includes any part of the river front, and any location the fence line is visible.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 to be observed from the site fence line. This includes the river front, the north hill, etc." Areas of movement shall be limited to the following areas:* Unit 1 from 15' to 53' inside the turbine hall, admin building, superheater building, house service boiler 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 keys 4.1.10.3 These assignments shall be made and understood at the SOW meeting to ensure all parties are clear on responsibilities and movement restrictions 4.1.10.4 These assignments will NOT apply upon entry into an EOP, ONOP, or AOP (other than 0-AOP-SEC-1) and shall be resumed immediately upon exit from an EOP, ONOP, or AOP.4.2 Expectations Related to I&C Activities in the CCR 4.2.1 General Access I&C should always get permission prior to entering the operating area of the CCR. This includes following breaks and or lunch. (i.e. I&C should not be granted free access in and out of the operating area as plant conditions may change throughout the day).

OPERATIONS COMMITMENTS AND No: QAP-li1 Rev. 15 POLICY DETAILS Page 14 of 79" Traffic through the ATC area should be kept to a minimum and limited 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 racks to access the key box or enter the back of the panels. (To minimize traffic 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 all communications related to performance of a test or activity.

This is for both I&C communications with each other and I&C communications with the operators.

• Slang or informal terminology shall not be used.* Non-work related conversations should be kept to a minimum and held outside of the operating area.4.2.3 Component Manipulations 4.2.3.1 All component manipulations performed by operations in accordance I&C testing shall be communicated via proper 3 point communication and peer checked in accordance with management expectations.

There are 2 methods for I&C to request these component manipulations, via the CRS or via the RO: a) Requesting Component Manipulations via the CRS: 1) The I&C technician will inform/request the CRS of the desired component manipulation utilizing 3 point communications.

2) The CRS will then direct the operator to perform the manipulation utilizing 3 point communication.

3) The operator will perform the manipulation with the required peer check. The Peer checker can be another operator or an I&C technician as determined by CRS.b) Requesting Component Manipulations via the RO: 1) The manipulations required are discussed with the CRS in the pre-job brief.

ergy OPERATIONS COMMITMENTS AND No: QAP-il1 Rev. 15 POLICY DETAILS Page 15 of 79 2) The I&C technician will inform/request the RO of the desired component manipulation utilizing 3-point communications.

3) The RO will then inform the CRS of the manipulation to be performed utilizing 3 point communication.

4) The operator will perform the manipulation with the required peer check. NOTE: the Peer checker can be another operator or an I&C technician as determined by CRS.4.3 Equipment Operation 4.3.1 General Guidelines 4.3.1.1 WHEN necessary for authorized Non-Operations personnel to operate plant equipment, THEN perform the following:

{Ref: 7.1.6)a) CONTACT the CCR prior to operating plant equipment." Obtain SM authorization." Certain equipment manipulations per approved procedures by other departments (i.e. FIN) may be excluded from this requirement.

b) OPERATE plant equipment per approved plant procedures OR within the scope of the work package.IF equipment is being operated under minor maintenance, THEN ENSURE all component manipulations are documented by annotating on Minor Maintenance Sheet.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 16 of 79 c) WHEN equipment operation is complete, THEN: " INFORM the CCR.* RESTORE to As Found position and Independently VERIFY.* VERIFY As Left position per COL or governing procedure:

May be accomplished by contacting the on-watch CRS, FSS, or SM to ensure the correct component position is identified.

4.3.2 Starting

Equipment I Returning Equipment to Service: 4.3.2.1 During non-abnormal/non-emergency situations, when starting equipment, alternative indication SHALL be used to ensure a successful start of the equipment.

Acceptable alternative indications are pressure, flow, local observation or amps (component or bus amperage before and after the start).4.3.3 Work Step List 4.3.3.1 Work Step lists SHALL NOT be used to troubleshoot equipment. (Refer to EN-MA-125, Troubleshooting Control of Maintenance Activities).

4.3.3.2 Work step lists are to be used only for the following circumstances: " Preparing a System, Subsystem, Component or Device for maintenance prior to or after Tagout is applied.* Restoration of a piece of equipment following work, after Tagout removal and prior to being declared operable.4.3.3.3 IF an item manipulated in the work step list requires double verification, those items SHALL be placed in their final position using the type of verification called for in the COL and documented on ATTACHMENT 2, Work Step List (Page 39).4.3.3.4 An individual Work Step List SHALL NOT be used more than once.4.3.3.5 ATTACHMENT 2, Work Step List, OR electronic substitute containing all information listed on ATTACHMENT 2 SHALL be used to outline a Work Step List.

t"6 OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 17 of 79 4.3.3.6 E mail electronic copy OR forward paper copy IF no electronic copy exists to the Operations Procedure Group Supervisor for possible procedure incorporation.

4.4 Use of Procedures

4.4.1 General

Guidelines 4.4.1.1 Ensure work is performed to the current revision including any outstanding changes by verifying document or record status through MERLIN.a) Personnel may verify current revision, including any outstanding changes by use of controlled hard copy set in the following locations.

{Ref: 7.3.1)* U2 Control Room" U3 Control Room* U2 FSS* U3 SM Office" U2 SM Office 4.4.1.2 Approved procedures SHALL be used to operate plant equipment:

{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 order deviations to any procedure pursuant to 10 CFR 50.54.Operators SHALL use their extensive training, qualification, and experience to ensure procedures are correct and appropriate for the activity being performed.

Operators may take actions that are NOT covered by procedures, but necessary to stabilize the plant: CRS permission should be obtained prior to taking actions.IF time does NOT permit prior approval, THEN the CRS SHALL be informed of actions taken as soon as possible.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev._15 POLICY DETAILS Page 18 of 79 4.4.1.3 Procedure steps cannot be written that address every circumstance, but are written assuming that all applicable equipment is available, and that the tasks addressed are being performed for the first time. Circumstances will arise that would warrant marking a step, or section as Not Applicable (N/A).a) Examples of circumstances applicable to the use of N/A are as follows:* Steps or sections that establish a condition that has already been established" Steps or sections that direct the use of equipment that is Out of Service Example: Place a charging pump controller in AUTO when the controller is NOT functioning would be N/A.* Prerequisites or initial conditions that DO NOT apply: Example: The initial condition to perform a COL for a system, when the task is to bump a pump for rotation during an outage, AND the system is NOT in service." Steps obviously NOT applicable to the plant condition:

Example: Performing a manual makeup with the RV Head removed, a step "OBSERVE Tave AND control rod bank position following addition of makeup" would be N/A." Any conditional step can be marked N/A.Conditional steps are those that begin with an IF statement.

b) Conditional steps that are NOT performed SHALL be marked N/A by the user, and DO NOT require prior approval of the SM/CRS/FSS.

c) Non-conditional steps SHALL ONLY be marked N/A with the approval of the SM/CRS/FSS.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 19 of 79 4.4.1.4 Restoration valve line ups for Surveillance tests and operations evolutions can have individual valve positions marked Not Applicable (N/A) if all of the following conditions are met;0 The As Found and As Left valve positions are the same as the COL valve position.* The valve was verified in the COL position when the As Found line up was performed.

0 The valve was NOT manipulated during the performance of the Surveillance test or Operations Evolution.

0 Only the on shift Surveillance Test Supervisor and / or Shift 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 maintained current to ensure the most recently performed COL is available.

IF only portions of a system OR selected equipment is to be operated, THEN ONLY applicable COL portions are required to satisfy the initial condition statement of COL complete.4.4.1.6 The performer and peer checker shall read the procedure and review expected response prior to usage.4.4.2 Continuation of Partially Performed Procedures 4.4.2.1 Prerequisites SHALL be performed prior to recommencing procedure performance.

4.4.2.2 Field Use procedures that are NOT completed in the same shift OR are carried over between shifts SHALL be annotated as to what step is in progress, brought to the CCR, and placed in the bin behind the CRS at the end of the shift. All completed steps SHALL be annotated.

If the original procedure is contaminated or destroyed, a copy SHALL be marked up showing what steps have been performed and what steps are still to be completed or in progress.

Some exceptions to this are: Procedures controlled from local workstations or local alarm panels (Regens in the CPF, Ul waste operations, GE water lineups)

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 20 of 79* Procedures that have been completed (swapping SFP pumps)" Procedures directed by or controlled from CCR (master copy of procedure is in CCR). As directed by the CRS/FSS/SM.

4.4.2.3 Procedures in use SHALL be tracked as necessary on appropriate turnover sheets.4.4.3 Completed Procedures 4.4.3.1 Completed procedures and/or procedure sections SHALL be submitted to the CRS/FSS for review.4.4.3.2 The CRS/FSS SHALL review the completed procedures for the following.

• Proper section and all required steps performed* Validate procedure quality and ensure feedback submitted 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 or guidance that conflicts with approved procedures, Technical Specifications, or a License Condition, with the exception of those actions pursuant to 50.54 (x) and (y).4.4.4.2 All actions that occur per 50.54 (x) and (y) SHALL be approved by a licensed Senior Reactor Operator: Those actions SHALL be immediately reported to the Unit Operations Manager, Site Operations Manager, Plant Operations General Manager, or the IPEC Site Vice President and documented via CR.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 21 of 79 4.4.4.3 Operations personnel MAY take responsible action that departs from a License Condition or Technical Specification pursuant to 10 CFR 50.54 (x) and (y), within the limits of the following: " Use of the provision is NOT optional: IF an emergency protective action is needed AND NO action consistent with the license is immediately apparent that can provide adequate or equivalent protection, THEN personnel are obligated to take protective action under this provision." Use of the provision does NOT require NRC concurrence:

• IF time permits, THEN NRC Operations Center telephone notification should be made before action is taken.* IF time does NOT permit, THEN NRC Operations Center telephone notification SHALL be made as soon as possible.* NRC notifications SHALL be made per ENN-LI-102, Corrective Action Process." Provision does NOT apply where time permits NRC amendment to Technical Specifications or License Condition.

• Provision SHALL NOT be used to prevent damage to the plant or machinery unless such damage is tied to a possible adverse effect on public health and safety.* Provision ONLY applies to emergencies where license compliance poses a barrier to effective protective action, and rapid action is needed to protect public health and safety: Immediate threat of injury to personnel is appropriate justification for the use of the provision.

Use of the provision is NOT tied to the declaration of any emergency classification in the Emergency Plan. Since emergencies can develop rapidly, use of the provision should NOT be encumbered by administrative prerequisites.

Ilk No: OAP- 115 lRev. 15 VEntergy OPERATIONS COMMITMENTS AND N POLICY DETAILS Page 22 of 79 4.4.4.4 Circumstances requiring use of the provision may occur during both analyzed or unanalyzed transients or accidents.

4.4.5 Components

Out Of Desired Position 4.4.5.1 WHEN a component is found that is NOT believed to be in the desired position AND NO procedure is found that would provide guidance on placing the component in the desired position, THEN: a) OBTAIN concurrence from an SRO prior to re-positioning the component b) ENTER the manipulation of the component in the Narrative Log c) INITIATE a Condition Report 4.5 Management Expectations

4.5.1 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.NOTE Approved 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 pants Bargaining 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. 15 POLICY DETAILS Page 23 of 79* Bargaining Unit Personnel:

• Hunter green or Navy blue button-down shirts (Cold Weather)* Grey or blue button-down shirts -(Warm Weather)* Black denim or cotton pants N O open-toed shoes or sandals* NO excessively worn or tattered clothing* When actively working in operating areas of the plant, around rotating equipment or hot pipes and valves, or when engaged in physical work, short sleeved shirts are NOT permitted.

• "Active work" does NOT include passive activities such as rounds taking, tours, and the like.4.6 Fire Brigade Requirements 4.6.1 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 be used to fulfill the requirements of step 4.6.1. Their Brigade responsibilities are delineated in IP-SMM-DC-901, (IPEC Fire Protection Program Plan):* Fire Brigade Leader (Qualified Individual)

• Station Rover NPO* Schedule designated NPO* Schedule designated NPO* Schedule designated NPO 4.6.3 The following limitations apply to Fire Brigade members: 4.6.3.1 The Fire Brigade leader can NOT concurrently hold the STA position.4.6.3.2 Fire Brigade Responders shall not be assigned duties without having established a means of direct communication with the Control Rooms.4.6.3.3 Fire Brigade Responders shall not be assigned to attend training outside of the protected area.

terg/ OPERATIONS COMMITMENTS AND No: 0AP-115 Rev. 15 POLICY DETAILS Page 24 of 79 4.6.3.4 IF needed outside the Protected Area but within the Owner Controlled Area, GT 2 and 3, OR the Buchanan Switch Yard, THEN the following criteria apply:* ONLY ONE member may leave the Protected area at any one time." The member must be in radio contact with the Control Room while outside the Protected Area.* The member must have a vehicle for travel while outside the Protected Area.* The member's turnout gear and SCBA must be staged at the Protected Area entrance while outside the Protected Area.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 to either the fire brigade room or the nearest fire brigade locker and don all necessary personal protective equipment, including Self-Contained Breathing Apparatus (SCBA), and proceed to the fire scene with appropriate extinguishers and equipment.

4.7 Unit 2 Annunciator Window Color Coding 4.7.1 Unit 2 annunciator windows SHALL be colored using the following guidelines:

{Reference 7.2.1)" Full Red -All reactor and turbine trips, imminent plant trip/safety injection/plant transient if operator action is not taken within approximately five minutes.* Half Red -All Safety Injection trips. Any potential plant transient leading to plant trip/safety injection/equipment damage if operator action is not completed within approximately 30 minutes.* White -Normal Annunciator Response Procedure usage and urgency applied.9 Green -Normally lit annunciator AI MEnteig OPERATIONS COMMITMENTS AND No:QAP-1iS Rev.15 POLICY DETAILS Page 25 of 79 4.7.2 The list of Unit 2 color coded annunciators is provided as follows: List of Unit 2 Color Coded Annunciators All Reactor Trips and Turbine Trips -Panel FAF and FDF Panel FBF Window 2-5, 3-5, 3-7, 3-8 Panel SAF Window 4-9 Panel SBF-2 Window 2-6, 3-6, 1-8, 2-8, 3-8, 4-8 Panel SCF Window 4-6 Full Red Panel SDF Window 4-1, 4-3 Panel SEF Window 3-8 Panel SFF Window 1-5, 3-5 Panel SGF Window 2-3, 3-3, 3-6, 3-7 Panel SJF Window 2-8 2-ARP-016 Window 3-1 All Safety Injection Trips -FDF Window 2-5, 3-5, 1-7, 2-7, 1-8 Half Red FBF Window 4-6 SAF Window 3-9 SCF Window 1-6 SEF Window 3-2, 1-4 SFF Window 3-6, 4-6, 3-7, 4-7 Half Red SGF Window 2-9 SJF Window 1-5 2-ARP-016 Window 1-1, 2-1, 1-2, 4-3 Green 2-ARP-005 Window 2-4 OPERATIONS COMMITMENTS AND No: QAP-liS Rev. 15 ery OPERATIONS COMMITMENTS AND N:OP 1 e.1 POLICY DETAILS Page 26 of 79 4.7.3 Red page sleeves SHALL be placed in the Annunciator Response Procedures corresponding to Full Red alarm annunciators for rapid location of red alarm responses.

First Out annunciator ARPs do NOT require page sleeves.4.8 Time Critical Operator Actions 4.8.1 Time critical operator actions (TCOAs) are identified on ATTACHMENT 4 and ATTACHMENT 5.4.8.2 A TCOA as defined in WCAP-1 6755-NP as a manual action or series of actions that must be completed within a specified time to meet the plant licensing basis.4.8.3 If a TCOA must be completed immediately, per Technical Specifications: "When 'immediately' is used as a Completion Time, the Required Action should 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 the required time to complete a TCOA, as listed in OAP-6 Operations Procedure Review and Control, Attachment 14.Plant modifications significantly affecting the required time to complete a TCOA. It is necessary to consider modifications changing equipment design and operation, changing access, etc." TCOAs should be validated either in simulator or by walkthrough, if possible and alternate means if not, and documented using ATTACHMENT 6, Time Critical Operator Action Validation.

• Simulator Validation

-Execution of procedures using the plant-specific simulator during a simulated event.* Walkthrough Validation

-A step-by-step in-plant walkthrough of procedures by plant personnel, simulating manipulation of controls and equipment.

• Validation can be waived if TCOA is determined to be of low risk significance OR performance is not expected to exceed 50% of required time.

erg OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 27 of 79 4.8.6 Staged equipment supporting TCOAs should be periodically inventoried.

4.9 Site Tagging Guidance 4.9.1 The following guidance is provided to support tagout preparation.

This guidance is a result of OE and an effort to promote consistency between units.4.9.1.1 Tag control power to the traveling water screens to ensure consistency between units.4.9.1.2 All tagouts prepared in Online Ops Planning are to be peer checked by an Operations Planning SRO/Equivalent before going to the watch. This is NOT the independent review. We want the independent review to remain with the watch. The peer 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 clear 4.9.1.3 Watch tagout review of online tagouts should be performed at T-4 (4 day shifts). Comments if any should be forwarded and final sign off should occur NO later than Sunday night of T-3 (4 night shifts).4.9.1.4 Any newcomers to Operations Planning (online or outage)need to complete the Familiarization Guide and return the guide to the Lead SRO for filing.4.9.1.5 Any big picture changes in how we implement EN-OP-102 will require a change management plan either from the online planning lead SRO or the outage planning lead SRO. This is necessary to ensure all stakeholders are aware and are NOT surprised in the field during walk-down.

This applies when we deviate from some long used, well known tagout that the craft are familiar with.4.9.1.6 When used as protection on a tagout, all breakers will be disconnected from the bus (Racked out, Racked into Test, or Removed), unless a different arrangement is approved by the Assistant Operations Manager.

OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 28 of 79 4.9.1.7 For outage emergent tagout revisions, during outage execution, 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 (OSS manager).

5.0 No: OAP-115 l e.1 fergy OPERATIONS COMMITMENTS AND Rev. 15 POLICY DETAILS Page 29 of 79 RESPONSIBILITIES 5.1 ALL OPERATIONS PERSONNEL 5.1.1 Attending training as scheduled UNLESS prior Site Operations Manager approval 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 responsibilities of the following programs:* Emergency Plan {Ref: 7.1.16)* Equipment Status and Configuration Control {Ref: 7.1.25, 7.1.301 5.3.2 Periodically conducting plant tours to inspect material condition and coach 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 per Technical Specifications and applicable testing documents PRIOR to removal 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 and guides 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, in progress or planned, and plant conditions to ensure reactor safety and reliability via the following:

{Ref: 7.1.30)* Reviews of Unit logs, completed COLs, the Protective Tagging database, and the LCO Tracking Log 0 Communications with the SM, FSS, STA, ROs, and NPOs teg OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 30 of 79 5.5 REACTOR OPERATOR (RO -OTC, BOP, 3 rd RO)5.5.1 Continually monitoring instrumentation and alarms, and remaining sufficiently proficient with all operations procedures and guides to recognize abnormal conditions, correctly diagnose the cause, and terminate 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 during evolutions involving reactivity changes, major transients, or accident conditions. (Ref: 7.1.211 5.6.3 Conducting control board walk-downs

{Ref: 7.1.26)5.6.4 Conducting joint, face-to-face discussions with the SM, FSS, and CRS at the beginning of shift and during significant changes to plant conditions to discuss the following: (Ref: 7.1.271* Current plant conditions

• Planned shift evolutions

• Any changes in plant status, expected transients, and possible contingencies

5.6.5 Conducting

a minimum of 2 Vital Area tours per shift and noting any abnormal conditions:

{Ref: 7.1.28)* The results of these tours and any corrective actions required SHALL be communicated to the SM/CRS/FSS.

• The performance and results of these tours SHALL be documented in the Unit Narrative Log.5.6.6 IF transiting to areas where the plant page may NOT be audible, THEN informing CCR personnel and obtaining other means of communications.

{Ref: 7.1.28)5.6.7 Expeditiously informing the Unit Operations Manager of identified conditions where corrective action is required and NOT taken: (Ref: 7.1.28)* IF required action is still NOT taken, THEN the Site Operations Manager SHALL be informed.

Ener y OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 31 of 79 5.7 FIELD SUPPORT SUPERVISOR (FSS)5.7.1 Authorizing removal of plant equipment and systems from service AND safety 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 following maintenance, 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 DEFINITIONS None I MEntergy OPERATIONS COMMITMENTS AND No: OAP-115 Rev. 15 POLICY DETAILS Page 32 of 79

7.0 REFERENCES

7.1 Commitment

Documents Unit 3 Commitments 7.1.1 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 Commitments 7.1.3 COM-95-05281 (IPN-95-01 0), Interruption of Switch Gear Continuous Fire Watch (Log 95-003-A)7.1.4 COM-95-05340 (IPN-95-021), Response to Request for Evaluation of Concern 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 Plant Outside Design Basis Due to Inadequate Procedures and Improper Document Use (Log 95-048-B)7.1.9 COM-95-05631 (LER 95-022), Plant Operating Outside Procedures and In 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 Conference Associated with IR-93-22.7.1.13 COM-95-05579 (IR 95-15), Resident Safety Inspection and NOV 50-286/95-15 (Log 95-065-D)

OPERATIONS COMMITMENTS AND No:_OAP-115 Rev. 15 POLICY DETAILS Page 33 of 79 Unit 2 Commitments 7.1.14 NL-73-A74-C02 Action taken to limit control room access 7.1.15 NL-73-A91-C01 When redundant system is removed from service, portion remaining functional will be tested 7.1.16 NL A91 -C19 Alerting of emergency personnel by CCR operators 7.1.17 NL-79-A65-C38 Shift Manager responsibilities for safe plant operation 7.1.18 NL-79-A65-C41 Shift Manager responsibilities for safe plant operation 7.1.19 NL-79-A65-C42 Requirement for Watch Engineer 7.1.20 NL-79-A65-C46 Limiting CCR access and establishing clear line of authority and responsibility in the CCR 7.1.21 NL-79-A91-C14 Requirement for Watch Engineer to assist SM 7.1.22 NL-80-A25-C05 Maintain 2 CRS in CCR during power operations or hot shutdown 7.1.23 NL-81-A01-C17 WE duties other than specified functions clarification 7.1.24 NL-83-A27-C05 Alteration of training schedules by Plant Manager 7.1.25 NL-87-01 1-C01 See commitment database for detail 7.1.26 NL-88-013-C04 SM, CRS and WE/STA board walk-downs 7.1.27 NL-88-013-C06 WE will be assigned to a shift and attend start of watch meeting 7.1.28 NL-88-013-C07 WE will be assigned to CCR, conduct 2 vital area tours and maintain a log book 7.1.29 NL-88-070-C17 Procedures and policies to resolve differing of opinions between SM, CRS, RO and WE 7.1.30 NL-92-045-C02 See commitment database for detail 7.1.31 NL-97-084-C08 Verification of local panel for alarm conditions 7.1.32 NL-98-066-C038 Reduce administrative burden on the SM 7.1.33 NL-98-066-C065 Improve standards for CCR decorum 7.1.34 NL-98-141-C01 Redundant equipment is available prior to removing safety-related equipment from service OPERATIONS COMMITMENTS AND NO: QAP-li1 Re1 POLICY DETAILS DM 13A avu ~ Uk I V 7.1.35 NL-98-141-C02 On watch CRS will grant permission to commence maintenance or testing 7.1.36 NL-99-035-C02 Operations procedures revised to be consistent with the "Standards and Expectations for Operations Personnel 7.1.37 PD-83-042-C03 Limiting use of the 25% annual tolerance Requirement and Commitment Cross Reference Procedure Procedure Procedure Section Section Section 73-A74-C02 4.1.4 79-A91-C14 5.6.2 88-070-C17 4.1.5.1 80-A25-C05 5.3.2 92-045-C02 5.3.1, 5.4.2 73-A91-C01 5.3.3 81-A01-C17 4.1.5.2 97-084-C08 4.1.2.1 79-A91-C19 5.3.1, 4.1.6.2 83-A27-C05 5.1.1 98-066-C038 5.2.1 79-A65-C38 5.2.2 87-011-C01 5.3.1 98-066-C065 4.1.1 5.1.1, 5.4.1, 79-A65-C41 5.2.2 88-013-C04 98-141 -C01 5.3.3 5.5.1, 5.6.3 79-A65-C42 5.6 88-013-C06 5.6.1, 5.6.4 98-141-C02 5.7.1, 5.7.2, 5 55.7.3 79-A65-C46 4.1.4 88-013-C07 5.6.5,5.6.6, 99-035-C02 4.4.1.3 5.6.7 U2 Other Procedure U2 Other Procedure U2 Other Procedure Section Section Section PD-83-042-C 5.1.1 03 U3 IPN Procedure Procedure Procedure ScinSection Section COM-95-05281 (IPN-95-010) 2.1.2 COM-96-05796 (IPN-96-103)4.3.1.1 COM COM-95-05340 05147 (IPN- (IPN-95-021) 4.1.6.1 94-091) (IPN-95-021)

COM COM-95-05543 05147 (IPN- (IPN-95-1512)94-112) (IPN-95-112 OPERATIONS COMMITMENTS AND No: OAP-115 POLICY DETAILS On ,-,A 7Q I Rev. 15 I %J.J ~JI I .1 Procedure Procedure Procedure U3 Other Scon U3 Other Scin U3 Other Seto Section Section Section COM COM-87-03066 03186 (IP3- (IER-87-08)

SMB-00 88-055) Operators COM COM-93-04831 PS 4114 05464(LER 2.1.1 (IR-93-22)

IP3 Letter 95-014) __ from COM Limitorque, 05631 (LER COM-95-05579 4.4.1 08/26/1995 95-022) (IR 95-15)7.2 Development Documents 7.2.1 Unit 2 Modification GMT FIX-98-1201 1-M (for local alarm window) and GMT-FIX-SNX-91-06681-M (for CCR alarm window)7.2.2 WCAP-1 6755-NP, Rev. 0, Operator Time Critical Action Program Standard, March 2007 7.2.3 SOER 09-1, Shutdown Safety 7.2.4 CR-IP3-2011-5166 CA-14 and CA-15 7.2.5 LO-WTIPC-2012-84 CA-3 7.2.6 CR-1P3-2011-5110 CA-13 7.3 Interface Documents 7.3.1 EN-AD-1 03, Document Control and Records Management Activities 7.3.2 IP-SMM-DC-901, IPEC Fire Protection Program 7.3.3 IP-SMM-OU-1 04, Shutdown Risk Assessment

8.0 RECORDS

AND DOCUMENTATION

8.1 Records

The following required records are generated by this procedure and SHALL be maintained in accordance with IPEC Records Retention Schedule: None 8.2 Documentation OPERATIONS COMMITMENTS AND NO: OAP-115 Rev.15 POLICY DETAILS Page 36 of 79 The following documentation resulting from this procedure are NOT required to be controlled and maintained in accordance with the IPEC Records Retention Schedule: 8.2.1 ATTACHMENT 6, Time Critical Operator Action Validation ATTACHMENT 1 Siren Activation Event Data Sheet (Page 1 of 2)1. IDENTIFY CALLER IF caller is other than event observer, THEN attempt to identify by Name, Address, and Telephone number of event observer.a. Name: b. Address: c. Telephone:

2. DATE: 3. TIME OF CALL: AM /PM 4. TIME OF EVENT: AM /PM 5. SIREN LOCATION: a. Town AND County: b. Street OR Intersection:

6. OPERATION REPORTED: a. Siren sounded? ..................................................................

Yes No b. Is siren still operating?

........................................................

Yes No c. Any unsafe conditions?

..............................

........................ Yes No d. Any damage assessed?

.....................................................

Yes No e. Approximate duration sounded? ...................................

Minutes 7. OTHER PERTINENT DETAILS: 8. Westchester Division requested to make safe?Yes No ATTACHMENT 1 Siren Activation Event Data Sheet (Page 2 of 2)WARNING POINTS Westchester County WP ...........................................................................

(914) 231-1905 Rockland County W P ................................................................................

(845) 364-8600 O range County W P ...................................................................................

(845) 615-0879 Putnam County W P ...................................................................................

(845) 225-4300 ATTACHMENT 2 Work Step List (Page 1 of 2)WSL Number: (Use "year / Month / day / time" as the number Example 200703031515)

Date: / / Page 1 of System / 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)

NOTE It MAY be acceptable to perform some steps concurrently OR NOT in the sequence presented 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 2 Work Step List (Page 2 of 2)Step List 1 st 2nd 1.2.3.4.5.6.7.8.9.10.Steps MAY continue for as many pages as necessary.

ATTACHMENT 3 Authentication Code Log (Page 1 of 1)MONTH MONTH 1 16 1 16 2 17 2 17 3 18 3 18 4 19 4 19 5 20 5 20 6 21 6 21 7 22 7 22 8 23 8 23 9 24 9 24 10 25 10 25 11 26 11 26 12 27 12 27 13 28 13 28 14 29 14 29 15 30 15 30 31 31 No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 42 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions (Page 1 of 19)IP2 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Determine the cause 15 minutes Chemical and CN-TA-03-90, Rev. 2-AOP-CVCS-Not required Uncomplicated of dilution, isolate following Volume 1: Indian Point Unit 1 Actions in the reactor water initiating event Control 2 (IPP) Boron Mode 1 Auto response to makeup source, and (startup & System Dilution Analysis for 2-ARP-SAF alarms Approaching Rod initiate boration power Malfunction the 4.7% Uprate Insertion Umit 12.5" before available operation). (FSAR Program. Rod Insertion Limit 0" Not expected shutdown margin is 30 minutes -14.1.5). Mode I Manual to exceed 50%l t 2-ARP-FDF lost, du~ring refueling Over Temp Delta-T of time limit NIS Power Range (Mode 6). High Range 108%Mode 2 2-ARP-FDF NIS Source Range Flux Level HI NIS Power Range Low Range 25%Mode 6 2-ARP-FCF Source Range High Flux Level At Shutdown If only 1 MD AFW 10 minutes Loss of CN-TA-03-126, 2-E-0, Step 7 Simulator NA pump is available, after reactor Normal Rev. 1: Loss of RNO No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 43 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable provide AFW flow trip. Feedwater Normal Feedwater/

from the TD AFP to and Loss of All Loss of Non-the steam AC Power to Emergency AC generators.

the Station Power Analysis for Auxiliaries 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 NA after VCT Failure after VCT Release -Rev. 0: Indian Point 1, Step 4.4 failure. Waste Gas 2 -Failure of a (FSAR 14.2.3) Tank Containing Gaseous Activity (Stretch Power Uprate Program).During a SGTR, 60 minutes after Steam CN-CRA-03-48, 2-E-3, Step 21 Simulator NA terminate primary to SGTR. Generator Rev 1: Indian Point secondary break Tube Rupture Unit 2 flow and prevent SG FSAR 14.2.4 Supplemental overfill.

Steam Generator Tube Rupture Analysis for 4.7%

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 44 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Uprate.CN-CRA-03-37, Rev 0: Indian Point Unit 2 (IPP) Steam Generator Tube Rupture T&H Analysis for Uprate Program.CN-CRA-03-63, Rev. 1: Indian Point 2 -SGTR Doses for Power Uprate.(a) Terminate (a) 15 minutes Rupture of a CN-CRA-05-58, Prudent Simulator NA auxiliary feedwater after SI signal. Steam Pipe Rev. 0: Indian Point Operator flow to the faulted (FSAR 14.2.5) 2 Steamline Break Action List steam generator with open OAP-012 following receipt of Feedwater Bypass the SI signal for Lines.main steamline CN-CRA-03-20, 2-E-2, Step 4 break (MSLB); and Rev. 0: Indian Point manually isolate No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 45 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable faulted SG for those 2 Steamline Break Outside Inside Containment Containment breaks Analysis for Stretch where steamline Power Uprate.isolation does not CN-CRA-03-19, occur automatically.

Rev. 0: Indian Point Unit 2 Steamline Break Outside Containment Analysis for 4.7%Stretch Uprate.Complete Transfer Prior to RWST During IP2 FSAR 6.2.2.1.4 2-ES-1.3 Simulator to Cold Leg Level <3' for Transfer to Calculations:

Recirculation prior to SI, RHR and Cold Leg GSX-00036-00 stopping all pumps charging Recirculation taking suction from Pumps, <2' for FMX-00089-00 the RWST containment spray pumps No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 46 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Open Central Within 30 Station IP-RPT-04-0081 1, 2-ECA-0.0, Not Required Uncomplicated Control Room minutes Blackout Rev. 0: Station Step 5 Actions cabinet doors following the (SBO) Event Blackout Final onset of an Report. Not expected SBO event. to exceed 50%of time limit.Open AFW Pump Within 30 Station IPP-RPT-04-0081 1, 2-ECA-0.0, Not Required Uncomplicated Room Roll-up Door minutes Blackout Rev. 0: Station Step 5 Actions to maintain room following the (SBO) Event Blackout Final temperatures less onset of an Report. Not expected than the 130OF limit. SBO event. IP-CALC-07-00143, to exceed 50%Rev. 1: Auxiliary of time limit.Feedwater Pump Room Temperature Rise 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 IP-RPT-04-0081 1, 2-ECA-0.0, Walkthrough NA (Appendix R diesel) following the Blackout Rev. 0: Station Step 5 RNO to be available, onset of an (SBO) Event Blackout Final SBO event. Report.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 47 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Isolate high energy 110 seconds High Energy RPT-196-1, Rev. 2: 2-ARP-FCF, Walkthrough lines in PAB piping after receipt of Line Break EQ Program Window 2-11 OR penetration area alarm -Based (HELB) Environmental Simulator upon receipt of pipe on SGBD Analyses Parameters Report.pen. high break IP2-DBD-225, temperature alarm. presenting the Rev.1: High Energy limiting time. Line Break.(Isolation valves to be closed 3 min after break based on: 40 sec to temp alarm; 110 sec operator response; 30 sec for valve closure]

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 48 of 79 C A'TACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Trip Circulating 10 minutes Internal Plant Con Edison Letter 2-AOP- Walkthrough Water Pump or open from event Flooding to AEC, 12/18/72.

FLOOD-i, OR Turbine Building roll- initiation

-Analyses Con Edison Letter Step 4.100 Simulator up door to prevent (Assumes 3 (FSAR 1.11.8) to NRC, 7/14/80. 1-ARP-002 flooding of 480V min for Switchgear Room. condenser pit alarm and 7 min operator action].(a) Locally close (a) 30 minutes Seismic Event FMX-001 30-00, 2-ARP-SCF, Walkthrough LCV-1 158 (if to close LCV- Rev. 1: Indian Point Window 2-3 automatic closure on 1158 following Unit 2 Impact of CST level fails failure to auto- Pipe Break following seismic close. Downstream of 0-AOP-event) -to isolate (b) 4hrs to LCV-1 158. SEISMIC-1 break flow to non- RHR cut-in IP-CALC-04-00648, seismic portion of after 1158 Rev. 0: IP2 Impact CST supply line to closure, of Pipe Break AFW. Downstream of (b) After 1158 LCV-1 158 at Power closure, cooldown to Uprate Conditions.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 49 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable RHR cut-in prior to CST emptying.Take operator action 10 minutes Overpressure FMX-00270-00, 2-ARP-SGF, Not Required Uncomplicated to terminate cause after initiation Protection Rev. 0: NET-i177-Window 2-6, Actions in of RCS low of event. System (OPS) 01- Overpressure 1-6, 1-7 response to temperature

-(FSAR Protection System alarms overpressurization 4.3.4.1) Thermal Hydraulic event. Analysis, Setpoint Not expected Development 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 Uncomplicated operator to control loss of N2 required.

FIX-00030 2-ECA-0.0 Actions Not Aux Feed Flow. Backup, in 30 expected to minutes on loss 2-E-0 exceed 50% of of Instrument time limit.Air.During Mode 4 10 minutes During Mode 4 WCAP-12476 2-AOI-4.2.2 Simulator LOCA, initiate after initiation LOCA event Step 5 makeup to RCS with of event.SI Pump No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 50 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Start of fire event 0 minutes Appendix R 2-AOP-SSD-1 Not Required NA -not an Fire operator action Reactor trip 5 minutes Appendix R 2-ONOP-FP-1 2-AOP-SSD-1 Walkthrough NA Fire identifies significant fire that requires entry into 2-AOP-SSD-1. Reference IP-CALC-05-01034 for reactor trip time.Trip RCPs from 5 minutes Appendix R Preserve RCP seal 2-AOP-SSD-1 Walkthrough NA CCR Fire integrity, assuming that both seal injection and thermal barrier cooling may be lost due to fire.Reference Westinghouse Tech No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 51 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Bulletin 04-22, Rev.1, and calculation IP-CALC-05-01034.

Defeat power to 5 minutes Appendix R Promptly 2-AOP-SSD-1 Walkthrough NA pressurizer PORVs Fire secure/prevent and letdown path inventory loss via (LCV-459) from letdown path, and if CCR 125V PORVs and block distribution panels valves are spuriously opened due to cable faults.Action time is not based explicitly on a calculation, but is expected to be performed promptly following manual reactor trip and prior to CCR exit into 2-AOP-SSD-1.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 52 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Locally confirm/trip 10 minutes Appendix R Same as "Trip 2-AOP-SSD-1 Walkthrough NA RCPs at 6.9kV swgr Fire RCPs." Local confirmation of trip at 6.9kV switchgear is needed in event that cable faults cause the CCR breaker trip switches to fail to trip the breakers remotely.Reference calculation NEA-00031 for 10-minute RCP trip assumption.

Isolate instrument air -15 minutes Appendix R Fails most AOVs in 2-AOP-SSD-1 Walkthrough NA to VC at IA-501 in Fire VC to desired/safe pipe pen area or IA- position (e.g., fails 739 in 480V swgr letdown path room closed, fails normal No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 53 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable charging path open, etc.). Calculation I P-CALC-05-01034 credits isolating letdown within 15 minutes, although this is already accomplished by CCR distribution panel breaker trips listed above. Also, prevent loss of nitrogen inventory for ASSS instruments, if valve HCV-943 has been spuriously opened due to cable faults.Securing air to VC header will ensure HCV-943 is failed closed.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 54 of 79 A'TACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Locally confirm -15 minutes Appendix R In the event that 2-AOP-SSD-1 Walkthrough NA MSIV closure at Fire cable faults have control racks in caused CCR ABFP Bldg controls to fail to secure MSIVs.If BOTH RCP CVCS 22 minutes, Appendix R IP-RPT-06-00022 2-AOP-SSD-1 Walkthrough NA seal injection AND assuming initial Fire (Applies to both IP2 CCW thermal barrier seal leakoff and IP3); also cooling have been rate is 3 gpm Westinghouse TB lost for the time 04-22, Rev. 1 duration listed at right, do NOT restore either cooling function to the seal packages Isolate S/G 30 minutes Appendix R Maintain S/G 2-AOP-SSD-1 Walkthrough NA blowdown locally Fire inventory above dryout conditions, pending restoration of AFW flow.Reference No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 55 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable calculation NEA-00031 for 30-minute SGBD isolation requirement.

Note that NEA-00031 includes a 30-minute SGBD isolation case, but calculation IP-CALC-05-01034 only references a 20-minute SGBD isolation time. The limiting time is taken to be 30 minutes, and calculation IP-CALC-05-01034 should be updated to reflect the 30-minute SGBD No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 56 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable isolation assumption.

Start TDAFW pump 30 minutes Appendix R Prevent S/G dryout. 2-AOP-SSD-1 Walkthrough NA and align flow to Fire Per Calculation S/Gs. Alternatively, NEA-00031, dryout if power is available, will occur in start one MDAFWP approximately 38 minutes without makeup.Assumption of AFW initiation at 30 minutes is used in calculation IP-CALC-05-01034.

Open ASSS -30 minutes Appendix R Provide ASSS 2-AOP-SSD-1 Walkthrough NA pneumatic line Fire monitoring isolation valves in instrumentation as pipe pen soon as possible.Take -30 minutes Appendix R As above. 2-AOP-SSD-1 Walkthrough NA control/monitoring at Fire Fan House 90'_el. I III No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 57 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable ASSS instrument panel Start Appendix R 60 minutes Appendix R Support recovery of 2-AOP-SSD-1 Walkthrough NA DG Fire charging, CCW, SW, and ASSS instruments as soon as possible.Limiting time is that required for starting a charging pump (to preserve RCS inventory to within the indicating range of the pressurizer wide-range channel), by 75 minutes. See below.Line up 13kV swgr 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NA Fire No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 58 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Transfer 23 CHP to 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NA ASSS feed Fire Close 23 CHP 60 minutes Appendix R 2-AOP-SSD-1 Walkthrough NA breaker on 12FD3 Fire Start 23 CHP 60 minutes Appendix R Maximum allowable 2-AOP-SSD-1 Walkthrough NA Fire analyzed time is 75 minutes for restoration of RCS makeup, per Calculation IP-CALC-05-01034.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 59 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Transfer 23 CCW <90 minutes Appendix R CHP can be 2-AOP-SSD-1 Walkthrough NA Pump to ASSS feed Fire operated at full speed for approximately 60 minutes before restoring CCW cooling. The time shown assumes that one CHP has been started at -60 minutes, and thus may be running without cooling for-30 minutes before CCW is restored.Per 2-AOP-SSD-1, the alternative is to align City Water to the running CHP until CCW is restored.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 60 of 79 ATTACHMENT 4 Unit 2 Time Critical Operator Actions IP2 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Start CCW pump <90 minutes Appendix R Initially, to provide 2-AOP-SSD-1 Walkthrough NA Fire cooling to charging pump, which can be operated for up to 60 min at high speed without cooling from CCW or City Water.Transfer 23 or 24 <90 minutes Appendix R Support restart of 2-AOP-SSD-1 Walkthrough NA SWP to ASSS feed Fire SW as heat sink for CCW.Start one SWP <90 minutes Appendix R 2-AOP-SSD-1 Walkthrough NA Fire No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 61 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions (Page 1 of 18)IP3 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Determine the cause 15 minutes Chemical and CN-TA-03-140, 3-ARP-009 Not required Uncomplicated of dilution, isolate following Volume Rev. 1: Indian Point 3-AOP-CVCS-Actions in the reactor water initiating event Control Unit 3 (INT) Boron 1 Step 4.102 response to makeup source, and (startup & System Dilution Analysis for '1 Ste alarms initiate boration power Malfunction the Power Uprate 3Mo before available operation). (FSAR 14.1.5) Program. Rod Insertion Low Not expected shutdown mriisLimittoecd50 30 minutes -Rod Insertion Low- toexceed50%

lost. during refueling Low Umit of time limit (Mode 6)Mode I Manual (Mode 6) 13-ARP-n02 OverTemp AT NIS Power Range High Range Mode 2 3-ARP-002 NIS Source Range High Flux Level NIS Power Range Low Range Mode 6 3-ARP-004 Source Range High Flux Level At Shutdown No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 62 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable If only 1 MD AFW 10 minutes Loss of CN-TA-03-143, Rev 3-E-0, Step 4 Simulator NA pump is available, after reactor Normal 0: Loss of Normal RNO provide AFW flow trip. Feedwater Feedwater/

Loss of from the TD AFP to and Loss of All Non-Emergency the steam AC Power to AC Power Analysis generators.

the Station for Indian Point Unit Auxiliaries 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 NA after VCT Failure. after VCT Release -Rev. 1: Indian Point 1, Step 4.3 failure. 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 NA terminate primary to after SGTR. Generator Rev. 1: Indian Point secondary break Tube Rupture 3 Stretch Power flow and prevent SG FSAR 14.2.4 Uprate overfill.

Supplemental Steam Generator Tube Rupture No: QAP-li1 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 63 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions 1P3 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Analysis.CN-CRA-03-69, Rev. 1: Indian Point 3 Stretch Power Uprate Steam Generator Tube Rupture (SGTR)Thermal Hydraulic Analysis.CN-CRA-03-25, Rev. 1: Indian Point Unit 3 -Steam Generator Tube Rupture Doses for Stretch Power Uprate.(a) Terminate (a) 30 minutes Rupture of a CN-CRA-03-1 00, EOP Prudent Simulator NA auxiliary feedwater after SI signal Steam Pipe Rev. 1: Indian Point Operator flow to the faulted (Inside VC (FSAR 3 Steamline Break Action List per steam generator MSLB). 14.2.5); and Inside Containment OAP-012 following receipt of Steamline Analysis for Stretch No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 64 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Operator Action Times Assumed in FSAR Analysis Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable the SI signal for Break Power Uprate. 3-RO-1 main steamline Containment CN-CRA-03-67, 3-E-2 Steps 1 break (MSLB). Integrity Rev. 1: Indian Point and 4.b.(b) Manually (FSAR Unit 3 Steamline terminate AFW to (b) 10 minutes 14.3.6). Break Outside faulted SG and close (Limiting Containment faulted SG MSIV for Outside VC Analysis for Stretch those Outside MSLB). Uprate.Containment breaks CN-CRA-02-51, where steamline Rev. 1: Indian Point isolation does not 3 -Steam Release occur automatically.

for Dose.CN-CRA-03-22, Rev. 1: Indian Point 3 Main Steam Line Break Doses for Stretch Power Uprate.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 65 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Open Central Within 30 Station UFSAR Section EOP Setpoint:

Not Uncomplicated Control Room minutes Blackout 8.2.3; and NRC Time .14 Required Actions cabinet doors following the (SBO) Event safety evaluation 3-ECA-0.0, onset of an report dated Step 7 Not expected SBO event 12/23/91, "Safety to exceed 50%Evaluation of the of time limit.Indian Point 3 Response to the Station Blackout Rule" Open AFW Pump Within 30 Station IP3-CALC-AFW-EOP Setpoint:

Not Uncomplicated Room doors to minutes Blackout 00418 and IP- Time .14 Required Actions maintain following the (SBO) Event CALC-07-00179.

3-ECA-0.0, temperatures less onset of an Calculations were Step 7 Not expected than the 130 OF limit SBO event required as a result to exceed 50%of NRC safety of time limit.evaluations to re-analyze AFW pump room temperatures during SBO events.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 66 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable See 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 RNO to be available, of a SBO event (SBO) Event "480V AC Electrical Distribution System"; IP3-DBD-324, "Appendix R Diesel Generator";

and NRC safety evaluation report dated 12/31/91 No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 67 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Battery 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 NA one division to be of the initiation Blackout "1 25V DC Electrical Step 31 available, of a SBO event (SBO) Event Distribution System"; and NRC 3-AOP-safety evaluation 138KV-1, report dated Steps 4.26/47 12/31/91 3-AOP-480V-1, Steps 4.32/51/70 Open 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 Uncomplicated Doors of losing 1 A/C CCR A/C unit 25.d Required Actions Not unit is operable.

expected to Applies only exceed 50% of during EOPs. time limit.Dispatch dedicated Immediately on When AFW is IP3-CALC-MULT-3-AOP-AIR-1 Not required Uncomplicated operator to control loss of N2 required 382 3-ECA-0.0 Actions Not Aux Feed Flow. Backup, in 30 expected to minutes on loss 3-E-0 exceed 50% of of Instrument time limit.Air No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 68 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable During Mode 4 Within 10 During Mode 4 WCAP-12456 3-ONOP- Simulator LOCA, initiate minutes of LOCA event RCS-8 makeup to RCS with Event Step 4 SI Pump Perform 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 Walkthrough Makeup to IP3 SFP of decision to event NL-07-075 Table A.2-2 using External use External Strategy Makeup Perform 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 Walkthrough to IP3 SFP using of decision to event NL-07-075 Table A.2-3 External Strategy use External Spray Complete Transfer Prior to RWST During IP3 FSAR 6.2.2 3-ES-1.3 Simulator to Cold Leg Level <1.5' Transfer to IP3-CALC-CS-Recirculation prior to Cold Leg 02590 stopping all pumps Recirculation taking suction from IP3-CALC-SI-the RWST 00725 No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 69 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Selected Miscellaneous Events Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Isolate RWST Unmanned 46 Seismic NSE-99-3-035-3-RO-1 Walkthrough NA Purification Loop minutes after Events; SFPC, Rev. 1, 3-SOP-SI-003 initiation of Accidents RWST Purification event requiring Without Continuous Manned 15 RWST Manning While minutes after injection.

Above Cold initiation of Shutdown event Take operator action 10 minutes Overpressure UFSAR 4.2.3, 3-ARP-010 Not Uncomplicated to terminate cause after initiation Protection 4.3.4, and 7.3.2. Required Actions in of RCS low of event. System (OPS) response to temperature Event. (FSAR alarms overpressurization 4.3.4)event. Not expected to exceed 50%of time limit No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 70 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Start of fire event 0 minutes Appendix R 3-AOP-SSD-1 Not NA -not an Fire Required operator action Reactor trip 5 minutes Appendix R 3-ONOP-FP-1 3-AOP-SSD-1 Walkthrough NA Fire identifies significant fire that requires entry into 3-AOP-SSD-1. Reference IP-CALC-06-00029 for reactor trip time.Trip RCPs from 5 minutes Appendix R Preserve RCP seal 3-AOP-SSD-1 Walkthrough NA CCR Fire integrity, assuming that both seal injection and thermal barrier cooling may be lost due to fire.Reference Westinghouse Tech Bulletin 04-22, Rev.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 71 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable 1, and calculation IP-CALC-06-00029.

Defeat power to 5 minutes Appendix R Promptly 3-AOP-SSD-1 Walkthrough NA pressurizer PORVs Fire secure/prevent and letdown path inventory loss via from CCR 125V letdown path, and if distribution panels PORVs and block valves are spuriously opened due to cable faults.Action time is not based explicitly on a calculation, but is expected to be performed promptly following manual reactor trip and prior to CCR exit into 3-AOP-SSD-1.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 72 of 79 A'TACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Locally confirm/trip 10 minutes Appendix R Same as 'Trip 3-AOP-SSD-1 Walkthrough NA RCPs at 6.9kV swgr Fire RCPs." Local confirmation of trip at 6.9kV switchgear is needed in event that cable faults cause the CCR breaker trip switches to fail to trip the breakers remotely.Reference calculation IP-CALC-04-000766 for 10-minute RCP trip assumption.

Locally confirm -15 minutes Appendix R In the event that 3-AOP-SSD-1 Walkthrough NA MSIV closure at Fire cable faults have control racks in caused CCR ABFP Bldg controls to fail to secure MSIVs.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 73 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable If BOTH RCP CVCS 22 minutes, Appendix R IP-RPT-06-00022 3-AOP-SSD-1 Walkthrough NA seal injection AND assuming initial Fire (Applies to both IP2 CCW thermal barrier seal leakoff and IP3); also cooling have been rate is 3 gpm Westinghouse TB lost for the time 04-22, Rev. 1 duration listed at right, do NOT restore either cooling function to the seal packages Isolate S/G 30 minutes Appendix R Maintain S/G 3-AOP-SSD-1 Walkthrough NA blowdown locally Fire inventory above dryout conditions, pending restoration of AFW flow.Reference calculation IP-CALC-04-000766 for 30-minute SGBD isolation requirement.

Note No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 74 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable that IP-CALC 00766 includes a 30-minute SGBD isolation case, but calculation IP-CALC-06-00029 only references a 20-minute SGBD isolation time. The limiting time is taken to be 30 minutes, and calculation IP-CALC-06-00029 should be updated to reflect the 30-minute SGBD isolation assumption.

Start TDAFW pump 30 minutes Appendix R Prevent S/G dryout. 3-AOP-SSD-1 Walkthrough NA and align flow to Fire Per Calculation IP-S/Gs. Alternatively, CALC-04-000766, No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 75 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable if power is available, dryout will occur in start one MDAFWP approximately 37 minutes without makeup.Assumption of AFW initiation at 30 minutes is used in calculation IP-CALC-06-00029.

Start Appendix R 60 minutes Appendix R Support recovery of 3-AOP-SSD-1 Walkthrough NA Diesel Generator Fire charging, CCW, SW, and ASSS instruments as soon as possible.Limiting time is that required for starting a charging pump (to preserve RCS inventory to within the indicating range of the pressurizer wide-range No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 76 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable channel), by 75 minutes. See below.Energize MCC 312A 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NA from Appendix R Fire Diesel Generator Transfer 31 or 32 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NA CHP to ASSS feed Fire Close selected CHP 60 minutes Appendix R 3-AOP-SSD-1 Walkthrough NA breaker on MCC Fire 31 2A Start selected 60 minutes Appendix R Maximum allowable 3-AOP-SSD-1 Walkthrough NA charging pump Fire analyzed time is 75 minutes for restoration of RCS makeup, per Calculation IP-CALC-06-00029.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 77 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions IP3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Transfer 32 CCW <90 minutes Appendix R CHP can be 3-AOP-SSD-1 Walkthrough NA Pump to ASSS Fire operated at full speed for approximately 60 minutes before restoring CCW cooling. The time shown assumes that one CHP has been started at -60 minutes, and thus may be running without cooling for-30 minutes before CCW is restored.Per 3-AOP-SSD-1, the alternative is to align City Water to the running CHP until CCW is restored.

No: OAP-115 Rev: 15 OPERATIONS COMMITMENTS AND POLICY DETAILS Page 78 of 79 ATTACHMENT 5 Unit 3 Time Critical Operator Actions 1P3 Target Completion Times for Appendix R Fire Required Action Required Time When TCOA Source Procedure Validation Basis for Limits Document that performs Method waiving the required validation, if TCOA applicable Start 32 CCW Pump <90 minutes Appendix R Initially, to provide 3-AOP-SSD-1 Walkthrough NA Fire cooling to charging pump, which can be operated for up to 60 min at high speed without cooling from CCW or City Water.Start 38SWP from <90 minutes Appendix R Support restart of 3-AOP-SSD-1 Walkthrough NA MCC 312A feed Fire SW as heat sink for CCW.Stop any running <120 minutes Appendix R EC-25886 3-AOP-SSD-1 Walkthrough N/A RHR Pumps Fire IP-CALC-10-00221, Avoid excessive heat up of pump/seal ATTACHMENT 6 Time 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 Department Records Custodian.

Team Leader Signature Date Entey Nuclear Northeast Procedure Use Is: RI Continuous O Reference 13 Information Control Copy:_Effective Date: '31 f/2o3/i..Page 1 of 28)N AND/OR Pt NG WATER S" XTION OF THE Approved By: TANK RPO or Designee: Prii Team 3C Procedure Owner EDITORIAL REVISION RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 2 of 28 REVISION

SUMMARY

(Page 1 of 1)1.0 REASON FOR REVISION 1.1 Procedure Upgrade Project.1.2 Incorporate feedback IP3-11398.

2.0

SUMMARY

OF CHANGES 2.1 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 a temporary 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 situations which 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 why RWST purification may have been temporarily secured (IP3-11398) and added valve 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: 24 THE REFUELING WATER STORAGE TANK Page 3 of 28 TABLE OF CONTENTS Section Title Page 1.0 P U R P O S E .........................................................................................................................

4 2.0 PRECAUTIONS AND LIMITATIONS

............................................................................

4 3.0 PR ER EQ U IS ITES .......................................................................................................

6 4 .0 P R O C E D U R E ...................................................................................................................

7 4.1 System Startup ...............................................................................................

7 4.2 N orm al O peration ...........................................................................................

10 4.3 Lowering RW ST Level ..................................................................................

12 4.4 System Shutdow n .........................................................................................

15 4.5 Pumping RWST to CVCS HUT Using the Refueling Water Purification Pump.. 17 5 .0 R E F E R E N C E S ................................................................................................................

19 6.0 RECORDS AND DOCUMENTATION

..........................................................................

19 Attachments:

ATTACHMENT 1, RWST PURIFICATION LINEUP ...........................................................

20 ATTACHMENT 2, TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGE IN S TA LLE D ...........................................................................................

22 ATTACHMENT 3, TEMPORARY RWST HEISE GAUGE SPECIAL LOG ...........................

25 ATTACHMENT 4, VALVE ALIGNMENT FOR PUMPING THE RWST TO A CVCS HUT ........ 26 RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 4 of 28 1.0 PURPOSE 1.1 This procedure establishes the requirements for recirculation and/or purification of RWST.1.2 This procedure applies to recirculation and/or purification of RWST.2.0 PRECAUTIONS AND LIMITATIONS

2.1 UNTIL

LER-2012-002-00 is resolved, this procedure can NOT be performed in MODES 1, 2, 3 or 4. LER-2012-002-00 states the RWST is inoperable whenever it is connected to the purification system due to non-qualified seismic piping.2.2 Precautions And Limitations 2.2.1 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 approximately 100 gpm).2.2.3 WHEN recirculating RWST, THEN an operating order should be written per EN-OP-102, "Protective and Caution Tagging, to close spent fuel pit purification isolation valves AC-719A and AC-629 to prevent inadvertent draining of RWST into Spent Fuel Pit.2.2.4 It is noted, RWST level should be maintained greater than 36 ft in the event of a DBE/SI to ensure required RWST inventory is maintained following a seismic event.2.2.5 In Modes 1, 2, 3 and 4, either of the following steps SHALL be implemented depending on whether dedicated operator manning for RWST recirculation/purification operations is desired OR NOT: 2.2.5.1 IF unmanned operation desired, THEN Operations staff must have a heightened awareness to isolate the Purification Loop upon indications of a Design Basis Event (DBE). The time should be less than 46 minutes, from the time of the alarm to the isolation of the loop. {Reference 5.2.1).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 5 of 28 2.2.5.2 IF manned operation is desired, THEN a dedicated person SHALL be briefed on the NSE 99-3-035 SFPC. The dedicated person is required to be stationed on the 41 foot elevation in the PAB. (near the Refueling Water Purification Pump) The dedicated person is to isolate non-siesmic portions of the system (by securing the pump, closing AC-727A AND AC-727B), after occurrence of a Design Basis Event and/or IF a Safety Injection (DBE/Sl) occurs. This manual isolation is required to be completed within 15 minutes after receipt of computer alarm.2.2.6 In Modes 1, 2, 3, and 4 other activities (excluding sampling), that may effect flow in or out of the RWST, will not be permitted simultaneously with 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 the following:

• Control Room direction* SI signal Actuation (loss of normal PAB lighting and Purification Pump)* LT-920 instrument loop, PICS becomes inoperable

• Seismic motion is suspected* Unidentified area flooding 2.2.8 A test requirement for 3-PT-V055, Exercise Close of Valve AC-726B RWST Purification Return Check Valve, has been established prior to placing RWST on Recirculation and/or Purification by Work Request (WR) test.2.2.9 WHEN in Modes 1, 2, 3, and 4, THEN RWST purification/recirculation SHALL 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 instrumentation limitations for RWST purification/recirculation

{Reference 5.2.1).2.3 General Information 2.3.1 IF any activity (i.e. Maintenance, 3-PT-SA43, RWST Instrument Check and Calibration Loop 920A/B), is performed after the PICS Lo Level alarm is set in this procedure (Step 4.1.1), THEN Step 4.1.1 must be re-performed to reset the PICS Low Level alarm setpoint.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 6 of 28 2.3.2 IF purification of RWST is unnecessary, THEN demineralizer and/or filter may be bypassed in accordance with Attachment 1, RWST Recirculation Lineup.2.3.3 WHEN topping off the RWST per 3-SOP-SI-002, Filling the Refueling Water Storage Tank, THEN the following are essential to minimize overflow:* Communications and coordination with individual stationed at the overflow stanchion pipe at lower WHUT pump room.* Flow should be limited to approximately 25 gpm or less 2.3.4 Operator should walkdown to locate the purification loop isolation valves and switch location to stop the pump.2.3.5 Operations Personnel SHALL possess the following in order to isolate the purification 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 PREREQUISITES

3.1 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 Return Check Valve, has been completed satisfactorily prior to system startup.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 7 of 28 4.0 PROCEDURE 4.1 System Startup NOTE* Recirculation and/or purification requires a RWST Low Level alarm supplementary to the existing level indication, since the existing level indicators (LT-920/LI-920) are not as accurate." Computer alarm (L0933A) provides timely warning in case of RWST/piping rupture.0 PICS monitor with RWST level on trend SHOULD have the alarm function ENABLED* 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 is expected.

Reaching the point of overflow provides a method to use a Temporary Alarm for RWST low level (L0933A) in PICS." Care should be taken as the point of overflow is approached.

The flow rate should be reduced to minimize the amount of water that will eventually enter WHUT sump which will 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 by toggling 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 the overflow into the WHUT Pump Room Sump who will notify Control Room (CCR) at first indication of RWST overflow.* WHEN sump level rises faster than the normal fill rate, THEN the RWST is topped off AND NOTIFY CCR to secure the RWST fill 4.1.1.4 SLOWLY FILL RWST to overflow (this should occur at approximately 36.8') as per 3-SOP-SI-002, Filling The Refueling Water 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: 24 THE REFUELING WATER STORAGE TANK Page 8 of 28 4.1.1.5 WHEN filling is complete (overflow is indicated at WHUT Pump Room), THEN SET a Temporary Alarm on PICS System Page for RWST low level alarm (L0933A) at .3 ft. less than the indicated overflow 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 LEVEL ALARMS 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 Isolation 4.1.3 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 Isolation 4.1.4 VERIFY AC-628, Refueling Cavity Draindown Filtration System Outlet Isolation, is CLOSED (41' FSB, SFP Pump Room).4.1.5 NOTIFY Health Physics to conduct a survey on the spent resin transfer line #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 on MCC-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: 24 THE REFUELING WATER STORAGE TANK Page 9 of 28 CAUTION If NOT continuously manned, the recirculation or purification of RWST must be secured per P&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 controller mounted on wall by pump.NOTE Step 4.1.9.1 is N/A if RWST recirculation/

purification operations is manned by a dedicated operator.4.1.9.1 IF a PICS alarm is generated during the purification process, THEN: STOP operation AND verify system lineup integrity for any leaks. NOTIFY System Engineer for further direction OR IF Temporary Alteration TA-05-3-022 is installed, THEN GO TO Attachment 2, TRACKING RWST LEVEL ALARMS WITH TEMPORARY HEISE GAUGE INSTALLED, Step 3.0 CAUTION Do NOT exceed 100 gpm as indicated on FI-656.4.1.10 ADJUST the following to establish a maximum flow of 100 gpm as indicated 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: 24 THE REFUELING WATER STORAGE TANK Page 10 of 28 4.2 Normal Operation NOTE The following are symptoms for a Design Basis Event (DBE) which indicate RWST purification SHALL be isolated:* CRS direction" Loss of normal lighting (lights & purification pump strip off bus on SI)* Site Page announcement SI has occurred s 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 occurring 4.2.1 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 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' 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 been isolated.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 be still intact/undamaged

• Dose Rates for the area are normal RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 11 of 28 NOTE It 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 that purification is no longer needed.4.2.4 IF it is desired to temporarily secure RWST recirculation (for example, for filling 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 Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSED Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED and Pump Suction Isolation Purif. Pump LOCKED SI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSED RWST Isolation I I P AC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED and To RWST Isolation LOCKED 4.2.4.3 PERFORM Independent Verification for the following valves per OAP-019, Component Verification and System Status Control: Independent Verification Valve Position Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSED Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED and Pump Suction Isolation Purif. Pump LOCKED SI-841, Spent Fuel Pit Demineralizer To 34*SI Pump Room CLOSED RWST Isolation AC-727B, Spent Fuel Pit Purification Loop 34'Sl Pump Room CLOSED and To RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 12 of 28 4.2.5 IF it is desired to restore RWST recirculation after being temporarily secured in Step 4.2.4, THEN: 4.2.5.1 OPEN the valves in the following table: Valve Position Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water OPEN Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water OPEN Pump Suction Isolation Purif. Pump SI-841, Spent Fuel Pit Demineralizer To 34 SI Pump Room OPEN RWST Isolation AC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room OPEN To RWST Isolation 4.2.5.2 RESTART Refueling Water Purification Pump using local controller.

4.3 Lowering

RWST Level 4.3.1 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 PAB until relieved or draindown completion.

Dedicated individual must be briefed on this task and provided with the following equipment:

o Flashlight o Radio tuned to a frequency monitored by the Control Room o 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 path when required.4.3.2 DECLARE 32 CS Train inoperable.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 13 of 28 4.3.3 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 is occurring* Site announcement that a Safety Injection has occurred* Local area flooding (potential pipe break)* Starting of 1 or more containment spray pumps* CRS direction 4.3.8.1 IF SI-4 fails to close, THEN PERFORM either of the following to isolate RWST drain path: a) ISOLATE drain line at SI-4 as follows: 1) REMOVE hose from SI-4.2) INSTALL cap on SI-4.OR b) ISOLATE 32 CS Pump suction as follows: 1) REQUEST the Control Room place 32 CS Pump control switch in PULLOUT.2) UNLOCK and CLOSE SI-865B, 32 Spray Pump Suction 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: 24 THE REFUELING WATER STORAGE TANK Page 14 of 28 NOTE If dedicated individual is stationed near 32 Containment Spray Pump on 41' el. in PAB, then dedicated individual may be released following completion of Step 4.3.9.1.4.3.9.1 PERFORM Independent Verification of SI-4, Pressure Test Connection Isolation per OAP-01 9, Component Verification and System 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 PAB until relieved or draindown completion.

Dedicated individual must be briefed on this task and provided with the following equipment:

o Flashlight o Radio tuned to a frequency monitored by the Control Room o 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 isolate RWST drain path when required.b) THROTTLE OPEN SI-4, Pressure Test Connection Isolation, 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 Test Connection 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 in Step 4.3.8.1 b)2), THEN PERFORM Independent Verification of SI-865B, 32 Spray Pump Suction Line Isolation (Locked Open) per OAP-019 Component Verification and System Status Control.

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 15 of 28 4.3.12 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

Shutdown 4.4.1 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 Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSED Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED and Pump Suction Isolation Purif. Pump LOCKED SI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSED RWST Isolation AC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED and To RWST Isolation LOCKED 4.4.1.3 PERFORM Independent Verification for the following valves per OAP-019, Component Verification and System Status Control: Independent Verification Valve Position Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSED Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED and Pump Suction Isolation Purif. Pump LOCKED SI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSED RWST Isolation AC-727B, Spent Fuel Pit Purification Loop 34' SI Pump Room CLOSED and To RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 16 of 28 4.4.1.4 WHEN recirculation flow is no longer needed AND as directed by the CRS/SM or designee, THEN: a) REMOVE PTO tags from AC-719A and AC-629 and OPEN AC-719A and AC-629.b) INITIATE flow through the Spent Fuel Pit Purification System as follows: 1) VERIFY AC-710, Spent Fuel Pit Demineralizer Bypass is closed (34' Ion Exchanger Valve gallery, upper level).2) OPEN AC-709, Spent Fuel Pit Demineralizer Outlet Isolation (34' Ion Exchanger Valve gallery, lower level).3) CLOSE AC-716, Spent Fuel Pit Filter Bypass (15' PAB SFP Filter).4) OPEN AC-705, Spent Fuel Pit Demineralizer Inlet Isolation (34' Ion Exchanger Valve gallery, upper level).5) OPEN AC-719B, Spent Fuel Pit Purification Loop Return Isolation (SFP Heat Exchanger Room, 55'FSB).6) INITIATE flow through SFP demin and filter by throttling AC-715, Spent Fuel Pit Filter Outlet Isolation (15' PAB SFP Filter).6 Flow is NOT to exceed 100 gpm c) PERFORM Independent Verification of valves in steps 4.4.1.4.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 for RWST Lo level alarm (L0933A).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 17 of 28 4.5 Pumping RWST to CVCS HUT Using the Refueling Water Purification Pump 4.5.1 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 per 3-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 Feed Ion Exchangers Isolation.

4.5.5.4 CLOSE CH-1298, 31 CVCS Holdup Tank Recirculation Inlet Isolation.

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 Feed Ion Exchangers Isolation.

4.5.6.4 CLOSE CH-1297, 32 CVCS Holdup Tank Recirculation Inlet Isolation.

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 Feed Ion Exchangers Isolation.

4.5.7.4 CLOSE CH-1296, 33 CVCS Holdup Tank Recirculation Inlet Isolation.

4.5.8 VERIFY

disconnect switch for Refueling Water Purification Pump is CLOSED (on MCC-37).

RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 18 of 28 4.5.9 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 Refueling Water Purification Pump.CAUTION Do NOT exceed 100 gpm as indicated on FI-656.4.5.11 ADJUST AC-727B, Spent fuel Pit Purification Loop to RWST isolation, to establish 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 Purification Pump.4.5.12.1 POSITION valves per the following table or as directed by the CRS: Valve Position Table Valve Location Position Initial AC-725, Refueling Water Purification Pump 41' PAB, Refueling Water CLOSED Discharge Isolation Purif. Pump AC-727A, Refueling Water Purification 41' PAB, Refueling Water CLOSED AND Pump Suction Isolation Purif. Pump LOCKED SI-841, Spent Fuel Pit Demineralizer To 34'SI Pump Room CLOSED RWST Isolation AC-727B, Spent Fuel Pit Purification Loop 34'SI Pump Room CLOSED AND To RWST Isolation LOCKED RECIRCULATION AND/OR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 19 of 28

5.0 REFERENCES

5.1 Commitment

Documents None 5.2 Development Documents 5.2.1 NSE 99-3-035 SFPC-Rev 1, RWST Purification Without Continuous Manning While Above Cold Shutdown.5.2.2 IP3-CALC-SI-03333-Rev 0, Engineering Evaluation of Postulated RWST Inventory Loss (ACTS 99-44077)5.3 Interface Documents 5.3.1 EN-OP-102, Protective and Caution Tagging 5.3.2 3-PT-SA43, RWST Instrument Check and Calibration Loop 920NB 5.3.3 Drawing 9321 -F-27503, Flow Diagram Safety Injection System Sheet 2 5.3.4 Drawing 9321-F-27513, Flow Diagram Auxiliary Coolant System Sheet 2 5.3.5 OAP-019, Component Verification and System Status Control 5.3.6 3-SOP-SFP-001, Spent Fuel Pit Cooling and Purification System Operation 5.3.7 3-SOP-SI-002, Filling the Refueling Water Storage Tank 5.3.8 3-ARP-012, Panel SJF, Cooling Water and Air 6.0 RECORDS AND DOCUMENTATION NONE RECIRCULATION ANDIOR PURIFICATION OF No: 3-SOP-SI-003 Rev: 24 THE REFUELING WATER STORAGE TANK Page 20 of 28 ATTACHMENT 1 RWST PURIFICATION LINEUP Page 1 of 2 VALVE11 NUMBE VALVE DESCRIPTION LOCATION REQUIRED POSITION NUMBE RI AC-704 PI-653 Isolation 34' PAB, Ion Exchr Vlv Gallery Upper CLOSED Level AC-710 Spent Fuel Pit Demineralizer Bypass 34' PAB, Ion Exchr VIv Gallery Upper Level (1)AC-706 Spent Fuel Pit Demineralizer Vent 34' PAB, Ion Exchr Vlv Gallery Upper CLOSED Level AC-708A Spent Fuel Pit Demineralizer Resin Fill Isolation 34'LPAB, Ion Exchr Vv Gallery Upper CLOSED Level AC-708B Spent Fuel Pit Demineralizer To SRST Isolation 34'LPAB Ion Exchr Vlv Gallery Lower CLOSED Level AC-707A Spent Fuel Pit Demineralizer Outlet Drain 34' PAB, Ion Exchr Vlv Gallery Lower CLOSED Level AC-707B Spent Fuel Pit Demineralizer Primary Water Backwash 34' PAB, Ion Exchr VIv Gallery Lower CLOSED Isolation Level AC-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: 24 THE REFUELING WATER STORAGE TANK Page 21 of 28 ATTACHMENT 1 RWST PURIFICATION LINEUP Page 2 of 2 VALVE VALVE DESCRIPTION LOCATION REQUIRED NUMBER POSITION SI-841 Spent Fuel Pit Demineralizer To RWST Isolation 34' PAB, SI Pump Room OPEN AC-720 Spent Fuel Pit Filter Outlet Sample Isolation 15' PAB, SFP Filter CLOSED AC-716 Spent Fuel Pit Filter Bypass 15' PAB, SFP Filter (3)AC-713A Spent Fuel Pit Filter Drain 15' PAB, SFP Filter CLOSED AC-713B Spent Fuel Pit Filter Vent 15' PAB, SFP Filter (Behind Shield on CLOSED Top of Filter) CLOSED AC-711 Spent Fuel Pit Filter Inlet Isolation 15' PAB, SFP Filter OPEN AC-712 PI-655 Isolation 15' PAB, SFP Filter OPEN AC-714 PI-654 Isolation 15' PAB, SFP Filter OPEN AC-715 Spent Fuel Pit Filter Outlet Isolation 15' PAB, SFP Filter (4)AC-717 FI-656 HI Side Root Isolation 15' PAB, SFP Filter OPEN AC-718 FI-656 LO Side Root Isolation 15' PAB, SFP Filter OPEN AC-66 Refueling Water Purification Pump Discharge Sample 41' PAB, Refueling Water Purif. Pump CLOSED Isolation AC-727A Refueling Water Purification Pump Suction Isolation 41' PAB, Refueling Water Purif. Pump OPEN AC-725 Refueling Water Purification Pump Discharge 41'PAB, Refueling Water Purif. Pump OPEN Isolation 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: 24 THE REFUELING WATER STORAGE TANK Page 22 of 28 ATTACHMENT 2 TRACKING 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 is established, 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 symptoms 3.1.1 IF symptoms of a DBE are present, THEN SECURE the RWST Purification system 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: 24 THE REFUELING WATER STORAGE TANK Page 23 of 28 ATTACHMENT 2 TRACKING 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 the initial overflow level reading, THEN: 3.2.6.1 SECURE the RWST Purification system per Section 4.2, Normal Operation.

3.2.6.2 DETERMINE if symptoms of a DBE are present: 0 REFER to NOTE prior to Step 4.2.1 for symptoms 3.2.7 IF there is a Temporary Heise Gauge reading change (greater than plus or minus 1" change) from the initial overflow reading, THEN: 3.2.7.1 NOTIFY the Control Room of an anomalous condition requiring investigation.

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: 24 THE REFUELING WATER STORAGE TANK Page 24 of 28 ATTACHMENT 2 TRACKING 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 symptoms c) 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 symptoms 3.2.8 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 than 1 inch lower than initial overflow reading, THEN PLACE the system 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: 24 THE REFUELING WATER STORAGE TANK Page 25 of 28 ATTACHMENT 3 TEMPORARY RWST HEISE GAUGE SPECIAL LOG (Page 1 of 1)DATE TIME RWST LEVEL INITIALS 4 4 4 4 + 4 4 4 4 4 + 4 1- I I I 4 I I 4.I I 4.

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

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

• Refueling Cavity Drain Pump To WHUT 41' PAB, WHU Access CLOSED Tank Isolation CH-1 108 CVCS Waste Transfer Pumps Recirc to CVCS HUTs 33' PAB, WHUT Pump Room CLOSED CH-1 109 CVCS Recirc Pump #31 Discharge 33' PAB, WHUT Pump Room CLOSED CH-1104 CVCS HUT #31 Inlet 31 CVCS HUT, on catwalk CLOSED CH-1 119 CVCS HUT #32 Inlet 32 CVCS HUT, on catwalk CLOSED CH-1 120 CVCS HUT #33 Inlet 33 CVCS HUT, on catwalk CLOSED I Entergy CONDITION REPORT CR-IP3-2002-05092 Originator:

Petrosi,Samuel Originator Group: Design Eng Mgmt Supervisor Name: Smith, Mark A Discovered Date: 12/20/2002 14:00 Originator Phone: 2879 Operability Required:

N Reportability Required:

N Initiated Date: 12/20/2002 14:41 Condition

==

Description:==

Engineering Area For Improvement identified by the WANO team: The timeliness and quality of design changes has affected plant performance.

Examples include: Elimination of Turbine Runback circuitry, BUSFPCS, Essential SW aligned to 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 independent S/A of Design Changes.REFERENCE ITEMS: Type Code LTCR Description TRENDING (For Reference Purposes Only): Trend Type KEYWORDS KEYWORDS KEYWORDS Trend Code KW-SELF-ID KW-MANAGEMENT EMPLOYEE INITIATED KW-PLANT MODIFICATIONS Entergy ADMIN CR-IP3-2002-05092 Initiated Date: 12/20/2002 14:41 Owner Group :Design Eng Mgmt Current Contact: Joe Reynolds Current Significance:

C -NO CARB Closed by: Reynolds,Joseph A 11/10/2003 16:59 Summary

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 CR closed.

Entergy I ASSIGNMENTS I CR-IP3-2002-05092 Version: 1 Significance Code: C -NO CARB Classification Code: NON-SIGNIFICANT Owner Group: Design Eng Mgmt Performed By: Sorrell,William Assignment

==

Description:==

CRR Apparent Cause Evaluation required 12/23/2002 10:58 Entergy I CORRECTIVE ACTION I CR-IP3-2002-05092 CA Number: I Group I orl, ila Name I Assigned By: Assigned To: Subassigned To : PLT-CARB-PORC Design Eng Mgmt Sorrell,William Petrosi,Samnuel Originated By: Sorrell,William 12/23/2002 11:00:2(Performed By: Varas,Kelley A 1/17/2003 13:49:17 Subperformed By: Approved By: Closed By: Varas,Kelley A 1/17/2003 13:49:17 Current Due Date: 01/17/2003 CA Type: DISP-APP CAUSE Plant Constraint:

1. NONE CA

Description:

CRR Apparent Cause Evaluation required Response: See Attached.

Per SAM PETROSI Subresponse

Closure Comments: Attachments:

Response Description CRR Response Initial Due Date: 01/13/2003 CA Priority:

Attachment Header Document Name: ICR-IP3-2002-05092 CA-00001 Document Location lResponse Description Attach Title: ICRR Response (REV 2) CONDITION REPORT RESPONSE (CRR) Page 1 of 2 la. CR NO. lb.CA No. 2. Date CRR Assigned:

3. Assigned Department:

CR 02-5092 CA #1 1/13/03 Design Engineering Evaluation Type: Z Progran/Process

[-D Equipment Problem 4a. STATE THE PROBLEM (precisely identify the core issue)Engineering Area For Inprovement identified by the WANO tean: The timeliness and quality of design changes has affected plant performance.

Examnples include: Elimination of Turbine Runback circuitry, BUSFPCS, Essential SW aligned 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 Issue D Procedural Problem El Equipment Problem E] Supervision Problem E] Design Problem 5. 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 Essential Ser-vce Water Supply to the Circulating Water Purmps (CR 01-03116, Level A) -4). 50.59 Evaluation for Temporary Alteration 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, CR 01-03177 (Level B) was issued to investigate any potential weaknesses that may exist in the 50.59 process as a result of events 2 mad 3, above. The response to CR 02-03177 was prepared by an independent assessment team from the corporate office. With respect to the overall question of a weakness in the 50.59 process, the assessment tean concluded 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 of design change.B. Quality -Events 2 through 4 represent exanmples of poor quality of 50.59 evaluations due to individual technical errors caused by non-critical thought processes.

Contributing to the deficiencies identified in events 2 and 3 was lack of recognition and/or failure to properly categorize activities that constitute a design change. Contributing to the deficiency identified in event 4 was overconfidence since the Temporary Alteration had previously been used with similar recominendated actions and justifications.

6. Is there an Extent of Condition?

-If NONE, So State: -provide rationale Extent of conditions of the individual events are contained ill dteir associated Condition Report responses.

A recent 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 exist to improve their quality.Is there a Safety Impact (Industrial or Nuclear)?

-If "yes" provide rationale The safety significance of the individual events is contained in their associated CR response.

The conclusions in the recent 2002, 4' Qtr. Assessment of "Modification Quality and Schedule Adherence" support the assertion that 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 Problem sheet to this document.In addition to the corrective actions already identified in the aforementioned CR's (2002-03514, 01-03116, 02-03013 and 01-03177) as well as the learning organization corrective actions identified in LOCR 2002-00079, the following corrective actions 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 APPROVAL 8.CARB Presentation Required?

[see PLT notes] [F- YES H NO Investigator (Print Name) Sam Petrosi Date 1/17/03 Ext 2879 Sam Petrosi / 1/17/03 Dept Mangr Date Safety Prog Adm (For Safety Issues)

Entergy CA DUE DATE EXTENSION CR-iP3-20o2-05092 Corrective Action : CR-IP3-2002-05092 CA-00001 Version: 1 Approved:Y Requested Duedate: 01/17/2003 Previous Duedate: 01/13/2003 Requested By: Varas,Kelley A 01/13/2003 Approved By: Sorrell,William 01/13/2003 Request

Description:

Extension is requested due to holiday vacations and integration activities which limited available resources.

Extension is acceptable since corrective actions have been identified, and in the majority of cases implemented, for the specific examples cited in the CR. Per SAM PETROSI.Approved

Description:

acceptable for extension Entergy CORRECTIVE ACTION I CR-IP3-2002-05092 CA Number: 2 I Grout VaaeIe Name Assigned By: Design Eng Mgmt Assigned To: Design Eng Mgmt Subassigned To : Design Eng I&C Staff Varas,Kelley A Petrosi,Samuel Originated By: Varas,Kelley A 1/17/2003 13:44:16 Performed By: Petrosi,Samuel 10/29/2003 12:04:3S Subperformed By: Hill,John 10/20/2003 11:33:3(Approved By: Closed By: Petrosi,Samuel 10/29/2003 12:08:5: Current Due Date: 10/30/2003 CA Type: LONG TERM CA Initial Due Date: 05/31/2003 CA Priority: Plant Constraint:

LTCA OTHER CA

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 Code LTCA-PROCESS/PROGRAM Description Response: The Design Review Committee, which is established per ENN-DC-1 15, will review a variety of engineering documents in addition to the modifications required by the procedure.

The DRC will grade each engineering document reviewed and issue 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. jhill No new procedures are required.

The existing IP2 EQRT process has been reactivated and will be utilized.

Review of modification 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-iP3-2002-05092 Corrective Action : CR-IP3-2002-05092 CA-00002 Version: I Approved:F Requested Duedate: 08/31/2003 Previous Duedate: 05/31/2003 Requested By: Hill,John 05/29/2003 Approved By: Petrosi,Samuel 05/29/2003 Request

Description:

A quality review team/process has been developed but has not yet been proceduralized.

Additional time needed to allow consolidation of team for both IP2 and IP3 as well as put procedure in new site procedure format. There is no impact to the plant 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 developed based on these. The new procedure will also include performance indicators.

SWP 05/29/03 Entergy I CA DUE DATE EXTENSION 1CR-IP3-2002-05092 Corrective Action : CR-IP3-2002-05092 CA-00002 Version: 2 Approved: Requested Duedate: 10/30/2003 Previous Duedate: 08/31/2003 Requested By: Hill,John 08/29/2003 Approved By: Varas,Kelley A 08/29/2003 Request

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 existing processes 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, this item was also approved by the Director as a long term CA item. Therefore the new due date in excess of 150 days is acceptable.

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-IP3-2002-05092 CA Number: 3 Grouo I Name I Assigned By: Design Eng Mgmt Assigned To: Design Eng Mgmt Subassigned To : Design Eng Civil/Str Staff Varas,Kelley A Petrosi,Samuel Drake,Richard S Originated By: Varas,Kelley A Performed By: Varas,Kelley A Subperformed By: Approved By: Closed By: Petrosi,Samuel 1/17/2003 13:45:32 7/18/2003 14:18:33 7/23/2003 12:31:04 Current Due Date: 07/29/2003 Initial Due Date: 05/31/2003 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

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 due date 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-IP3-2002-05092 Corrective Action: CR-IP3-2002-05092 CA-00003 Version: 1 Requested Duedate: 07/29/2003 Requested By: Drake,Richard S Approved By: Petrosi,Samuel Approved:

F Previous Duedate: 05/31/2003 05/29/2003 05/29/2003 Request

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-1P3-2002-05092 CA Number: 4 Group VaaeleI Name I Assigned By: Design Eng Mgmt Assigned To: Design Eng Mgmt Subassigned To : Design Eng Mgmt Varas,Kelley A Petrosi,Samuel Varas,Kelley A Originated By: Varas,Kelley A 1/17/2003 13:47:19 Performed By: Petrosi,Samuel 5/29/2003 14:41:59 Subperformed By: Varas,Kelley A 5/29/2003 14:14:59 Approved By: Closed By: Varas,Kelley A 5/29/2003 14:49:33 Current Due Date: 05/31/2003 Initial Due Date: 05/31/2003 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

Description:

Develop Design Change / 50.59 Evaluation quality performance indicators.

Response: Accept sub-response.

SWP 05/29/03 Subresponse

Close this CA to CR 5092 / CA # 2 which will develop a procedure for an "Engineering Quality Review Team" which will also include performance indicators with respect to the quality of engineering documents reviewed.Closure Comments: Accept for closure Entergy I CORRECTIVE ACTION I CR-IP3-2002-05092 CA Number: 5 Group I Name I Assigned By: CA&A Staff Assigned To: Design Eng Mgmt Subassigned To : Schmidt,George P Petrosi,Samuel Originated By: Schmidt,George P Performed By: Petrosi,Samuel 10/30/2003 07:14:2(11/10/2003 16:09:0(Subperformed By: Approved By: Closed By: Reynolds,Joseph A 11/10/2003 16:58:3'Current Due Date: 11/14/2003 CA Type: CR CLOSURE REVIEW Initial Due Date: 11/14/2003 CA Priority: Plant Constraint:

1. NONE CA

Description:

CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION 5.8.Response: All corrective actions are completed.

However, som clarification will be provided.

The Engineering Quality review Team is actually the Design Review Board, whose responsibilities are as outlined in ENN-DC-l 15. In addition, the ENN procedure allows for the DRC to review other documents other than MODS as deemed necessary.

The quality review checklists that are being used, have not been proceduralized.

However, they will provide the performance Indicators needed. This CR may be closed. SWP 11/10/03 Subresponse

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-IP3-2003-01166 Originator:

Cramer,Thomas A Originator Phone: 8213 Originator Group: Operations Shift Manager Staff Operability Required:

N Supervisor Name: Seaboldt,Jack J Reportability Required:

N Discovered Date: 03/12/2003 02:33 Initiated Date: 03/12/2003 04:07 Condition

==

Description:==

When the RWST purification lineup was secured per SOP SI-003, flow through the Spent fuel pit demineralizer from the spent fuel pit cooling loop was not initially established as expected.

Two valves were shut that were not addressed in SOP SI-003. These valves, AC-705, Spent fuel pit demineralizer inlet, and AC-719B, purification loop return, were apparently shut when securing spent fuel purification per SOP SFP-001. There is a disconnect in the procedure flowpath from SOP SFP-001 and SOP SI-003 in that the restoration section of SOP SI-003 assumes that purification was taken out per SOP SI-003 and not SOP SFP-001. These valves were then opened per SOP SFP-001 and the COL SFP 1 Immediate 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-719B open 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 of purification flow.EQUIPMENT:

Tag Name Tag Suffix Name Component Code Process System Code AC-705 VALVE 5 0012 AC-719B VALVE 5 0012 REFERENCE ITEMS: Type Code Description DOC SOP SI-003 DOC SOP SFP-00 1 DOC Procedure FDBK # IP3-6473 DOC COL SFP-1 DOC Procedure FDBK # IP3-6474 KEYWORD Procedure KEYWORD Spent fuel pit purification TEAM 3B TRENDING (For Reference Purposes Only): Trend Type Trend Code KEYWORDS KW-SELF-ID KEYWORDS KW-CONFIGURATION CONTROL KEYWORDS KW-PROCEDURE ADEQUACY Entergy I ADMIN P3-2003-01166 Initiated Date: 3/12/2003 4:07 Owner Group :Operations Proc Staff Current Contact: Current Significance:

C -REVIEW & CORRECT Closed by: Jowitt,Roseann 3/14/2003 7:58 Summary

Description:

Remarks

Description:

Closure

Description:

CLOSED TO ACTIONS TAKEN

---

7 Entergy ASSIGNMENTS CR-IP3-2003-01166 Version: 1 Significance Code: C -REVIEW & CORRECT Classification Code: NON-SIGNIFICANT Owner Group: Operations Proc Staff Performed By: Sorrell,William Assignment

==

Description:==

Close to actions taken Historical Human Performance Precursor 03/13/2003 12:58 Entergy I CONDITION REPORT I CR-IP3-2003-03264 Originator:

Tagliamonte,Reid J Originator Phone: 7157392 Originator Group: Tech Support Mgmt Operability Required:

N Supervisor Name: LePere,John C Reportability Required:

N Discovered Date: 05/23/2003 14:52 Initiated Date: 05/23/2003 15:07 Condition

==

Description:==

During P.M. dissassembly of the spent fuel pit filter the upper and lower devider plate gaskets were found to be installed wrong. The bottom divider plate gasket was installed on the top of the devider plate. The hardware assembly was pre-assembled by the vendor PAL trinity with the gaskets and was installed as a retrofit unit to convert to a single filter element. New divider plate gaskets were installed in the proper configuration during re-assembly.

All other filter assemblies retrofitted with this hardware have been inspected during P.M. filter replacements and have not had this problem. Reactor coolant 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:

None EQUIPMENT:

Ta2 Name Ta2 Suffix Name Component Code Process System Code 0012 Entergy ADMIN I CR-IP3-2003-03264 Initiated Date: 5/23/2003 15:07 Owner Group :Tech Radiation Protection Mgmt Current Contact: Current Significance:

C -REVIEW & CORRECT Closed by: Schmidt,George P 6/18/2003 7:44 Summary

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 is via the referenced lower tier process identifier, therefore this CR closed.

Entergy A S S I G N M E N T S I CR-IP3-2003-03264 Version: 1 Significance Code: C -REVIEW & CORRECT Classification Code: NON-SIGNIFICANT Owner Group: Tech Radiation Protection Mgmt Performed By: Sorrell,William Assignment

==

Description:==

Please evaluate and assign further corrective actions as required.Historical Human Performance Precursor 05/27/2003 11:22 Entergy I CORRECTIVE ACTION I CR-IP3-2003-03264 CA Number: I Group.I Name.I Assigned By: CRG/CARB/OSRC Assigned To: Tech Radiation Protection Mgmt Subassigned To : Tech Radiation Protection Staff Sorrell,William LePere,John C Lavera,Ronald Originated By: Sorrell,William 5/27/2003 11:24:38 Performed By: Lavera,Ronald 6/17/2003 15:21:48 Subperformed By: Approved By: Closed By: Lavera,Ronald 6/17/2003 15:21:48 Current Due Date: 06/17/2003 Initial Due Date: 06/17/2003 CA Type: DISP -CORR ACTION CA Priority: Plant Constraint:

1. NONE CA

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 a notification 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 Z Originator:

Post,Richard E Originator Group: Operations Shift Manager Staff Supervisor Name: Smyers,Carl Discovered Date: 08/15/2003 06:43 Originator Phone: 8221 Operability Required:

N Reportability Required:

N Initiated Date: 08/15/2003 06:46 Condition

==

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 temperature went from 100 F to a max of 114 F.Immediate Action

Description:

Suggested Action

Description:

REFERENCE ITEMS: Type Code CR KEYWORD RX EVT REVIEWED TEAM 3C Description IP3-2003-04719 Reactivity Non-event TRENDING (For Reference Purposes Only): Trend Type KEYWORDS RX MANANGEMENT MAINT RULE Trend Code KW-REACTIVITY RXM-NON-EVENT MR-FF Entergy I ADMIN I CR-IP3-2003-04700 Initiated Date: 8/15/2003 6:46 Owner Group :Operations Shift Manager Current Contact: R Perra Current Significance:

D -ADMIN CLOSURE Closed by: Perra,Ralph T 10/8/2003 5:30 Summary

Description:

Remarks

Description:

Closure

Description:

CR closed issue resolved.

Entergy A S S I G N M E N T S CR-IP3-2003-04700 Version: 1 Significance Code: D -ADMIN CLOSURE Classification Code: NON-SIGNIFICANT Owner Group: Operations Shift Manager Performed By: Harrison,Christine B 08/16/2003 13:39 Assignment

==

Description:==

8/16/03: Per CRG the evaluation of this CR will be included in the apparent cause evaluation assigned to Operations under CR-IP3-2003-04719.

Entergy CORRECTIVE ACTION CR-IP3-2003-04700 CA Number: 1.... ... G ro u p ] :~~~ ........ ...... .... ... .. N e ..... ... ..Group IName Assigned By: P&S Outage Mgmt Sullivan,Brian A Assigned To: Operations Staff LibbyEarl R Subassigned To: Operations Shift Manager O'Donnell,Eugene E Originated By: Sullivan,Brian A 8/15/2003 22:54:39 Performed By: Haynes,James S 10/2/2003 13:19:30 Subperformed By: Haynes,James S 10/2/2003 13:18:53 Approved By: Closed By: Sullivan,Brian A 10/2/2003 17:21:22 Current Due Date: 10/03/2003 Initial Due Date: 10/03/2003 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

Description:

This CA results from the post transient evaluation effort following the 8/14/03 U3 reactor trip. Reference is item 3 on page 30 of the post trip eval."Operations to evaluate whether training or labeling of the spent fuel building exit pushbutton is necessary to inform personnel 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 order entry describing this issued issued 10/3/03. No further action required.Closure Comments: Closue is acceptable Entergy CORRECTIVE ACTION I CR-IP3-2003-04700 CA Number: 2 Group.. ... ... I Name I Assigned By: CA&A Staff Assigned To: Operations Shift Manager Subassigned To : Schmidt,George P Libby,Earl R Originated By: Schmidt,George P 10/6/2003 10:59:35 Performed By: Haynes,James S 10/7/2003 16:08:05 Subperformed By: Approved By: Closed By: Perra,Ralph T 10/8/2003 05:29:53 Current Due Date: 10/21/2003 Initial Due Date: 10/21/2003 CA Type: CR CLOSURE REVIEW CA Priority: Plant Constraint:

1. NONE CA

Description:

CAT-D, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION 5.8.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-IP3-2003-04719 Originator:

Sicard,Michael D Originator Phone: 6151 Originator Group: Operations Mgmt Operability Required:

N Supervisor Name: Ventosa,John A Reportability Required:

N Discovered Date: 08/15/2003 22:06 Initiated Date: 08/15/2003 22:09 Condition

==

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 from about 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) as previously surmised, caused the SFP bldg door seals to engage and prevent operator entry until some time during the post transient activities.

When this lighting panel was restored and circuit was reset upon offsite power recovery, this caused the door 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 is apparent that the system is functioning per design.Suggested Action

Description:

REFERENCE ITEMS: Type Code Description CR IP3-2003-04698 CR IP3-2003-04700 DOC Operations Procedure Feedback IP3-7067 DOC Operations Procedure Feedback IP3-7067 DWG 9321-LL-31313 Sheet 28 DWG 9321-F-32043 TRENDING (For Reference Purposes Only): Trend Type Trend Code KEYWORDS KW-SELF-REVEALING Entergy ADMIN I CR-IP3-2003-04719 Initiated Date: 8/15/2003 22:09 Owner Group :Operations Shift Manager Current Contact: Joe REynolds Current Significance:

B -ACE & NO CARB Closed by: Reynolds,Joseph A 4/12/2004 17:25 Summary

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-IP3-2003-04719 Version: 1 Significance Code: B -ACE & NO CARB Classification Code: NON-SIGNIFICANT Owner Group: Operations Shift Manager Performed By: Harrison,Christine B Assignment

==

Description:==

08/16/2003 13:29 Entergy I CORRECTIVE ACTION I CR-IP3-2003-04719 CA Number: I Group I Name I Assigned By: CRG/CARB/OSRC Assigned To: Operations Shift Manager Subassigned To: Harrison,Christine B O'Donnell,Eugene E Originated By: Harrison,Christine B 8/16/2003 13:31:28 Performed By: Haynes,James S 9/12/2003 15:38:18 Subperformed By: Approved By: Closed By: Perra,Ralph T 9/15/2003 03:16:30 Current Due Date: 09/12/2003 CA Type: DISP -ACE Initial Due Date: 09/08/2003 CA Priority: Plant Constraint:

1. NONE CA

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 temperature went 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 component failed, 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 any design/tech spec issues/safety issues. CA 4 issued for resolution to these issues.Attachments:

Response Description PRS Response Description ACE Attachment Header Document Name: ICR-IP3-2003-04719 CA-OOOO1 Document Location JResponse Description,, Attach Title: FPRS Issue/Problem Resolution Sheet INSTRUCTIONS:

Complete this form for all investigations (Apparent Cause, Root Cause). This form may be used for broke/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/Fix CR-IP2-2003-04719 (optional) note whether the corrective action is "Preventive" or "Corrective".

Identify any corrective actions that were classified as CAPRs or Long Term CAs (Long Term CAs cannot be completed in less than 150 days due to an identified process/program restriction).

Reference any other tracking processes (e.g. duplicate CR, Work Order, MOD, ER, procedure feedback number, etc.) by their unique identifier to ensure tracking capability from this CR to the lower tier process. Document the date the CRG approved the closure to the other tracking process.TNTTr]D T1%/F[Nr1%

U A T1' C DD TICTT1'7 A 'TT(Th.rfn C-rDI Urr T1J DD"AWDUQI1 ITEM ISSUE / PROBELM SOLUTION / RESOLUTION TYPE Assigned Due CA ## [Note any WRs, MODs, other] CA Department date I Loss of Spent Fuel cooling due Restore Spent Fuel cooling pump N/A Operations Comp N/A to station blackout.PROPOSED/ASSIGNED CORRECTIVE ACTIONS ISSUE / PROEM .. SOLUTION , RESOLUTION

-- TYPE Assigned- e Date ITEM # [Note any WRs, MODs, other] CA Department SFB doors sealed on loss of Write ER for engineering to 2 power preventing access to evaluate bypassing seal feature on a Perform Operations 10/08/03 2 building, loss of power. CA Attachment Header Document Name: ICR-1P3-2003-04719 CA-0o0o1 Document Location IResponse Description Attach Title: FCEE IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~E terg( MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 1 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE Condition Report Number: Category Level: Assigned Department:

CR-IP3-2003-04719 B Operations CR-IP3-2003-04700 Evaluation Type: Program/Process X Equipment Problem STATE 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. Power was 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 operator entry. When power to this panel was restored following offsite power recovery, the door seals deflated 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-5 was in a normal state with no alarms up. I&C was contacted to assist in researching why the door seals had inflated.

It was not understood at the time that a lighting bus was the power source for the solenoids that supplied air to the seals. Due to the complexity of the trip that included a loss of all air in the station and the EDG's the only power supply to the plant, it took some time before all panels and busses were energized.

Adding to this was the report that even though offsite power had been restored to the plant, it was not initially considered to be reliable and 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 No GENERIC IMPLICATIONS:

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~~Enterg( MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 2 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE SAFETY SIGNIFICANCE:

During the event, there was never a challenge to Nuclear or Radiological safety. During refueling outages when the core is offloaded, we routinely maintain temperatures in excess of 130 degrees in the pool. Also, the "Spent Fuel Pit High Temp." alarm in the Control Room remained clear during the event. This alarm requires operator action at 135 degrees. Also, if temperature reaches 150 degrees, System Engineering must provide further guidance and resolution (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 were found. At IP-3 on 5/8/0 1, SFP cooling was lost for twenty minutes due to a GFCI tripping causing the BUSFPCS to shutdown (normal cooling OOS for MTC) during a refueling outage with the core fully offloaded to the pool. At that time, temperature was being maintained at 151 degrees and reached a high of 155 degrees in twenty minutes. This event was noted as NOT SIGNIFICANT 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 AC power 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 a complete loss of offsite power on 8/14/03. Temperature in the SFP increased from about 100 deg F to a maximum of 114 deg F. SFP power was lost as well as to 120VAC distribution panel 32 (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 SFP building door seals to inflate and prevent operator entry until some time during the post transient activities.

When this lighting panel was restored and circuit was reset upon offsite power recovery, the door seals deflated allowing entry into the building to manually restore SFP cooling.Was the event caused by, or identify, an equipment or component

__failure? I Yes I X NO IF Yes, THEN, coordinate with the appropriate Engineering Department organizations to complete 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 review results in the narrative section of this report.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0~ntergy MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 3 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE CARB Presentation Required? (See CRG notes on YES X NO assigned CA in PCRS)INVESTIGATOR Date report completed Phone Extension of Investigator Print Name E. Gurina December 13 2012 736-8281 Entergy I CA DUE DATE EXTENSION

[CR-IP3-2003-04719 Corrective Action : CR-IP3-2003-04719 CA-00001 Version: 1 Approved: Requested Duedate: 09/12/2003 Previous Duedate: 09/08/2003 Requested By: Haynes,James S 09/08/2003 Approved By: Lewandowski,Paul R 09/08/2003 Request

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 is complete, 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 has been obtained, and the extension does not exceed the 30-day limit. Therefore, the extension is approved.

Entergy I CORRECTIVE ACTION ICR-IP3-2003-04719 CA Number: 2 Group HansJaeI Name I Assigned By: Operations Staff Assigned To: Operations Staff Subassigned To: Haynes,James S Etzweiler,Joan F Originated By: Haynes,James S 9/12/2003 14:35:17 Performed By: Etzweiler,Joan F 10/8/2003 17:05:33 Subperformed By: Approved By: Closed By: Etzweiler,Joan F 10/8/2003 17:05:33 Current Due Date: 10/08/2003 CA Type: PERFORM CA Initial Due Date: 10/08/2003 CA Priority: Plant Constraint:

1. NONE CA

Description:

Write ER for engineering to evaluate allowing the ability to bypass Spent Fuel Building door seals under conditions similar to 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 this Condition 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 building is a life safety code issue. Safety accepts a Corrective Action (CA #5) with a two month due date to provide short and long term recommendations.

2 -- Re-entry to restore forced cooling of the Spent Fuel Pit (SFP). More urgent when fuel has recently been discharged from the Reactor.3 -- Long-term resolution of both above issues would include consideration of a design change. Possibilities include de-pressurization on loss of power, automatic back-up power, or unpowered manual override of seal pressurization.

Licensing advised that IP3 Tech. Spec. Amendment

1. 215 removed the requirement for FSB air filtration following a postulated Fuel Handling Accident.

The basis for the Amendment was the new IP3 source term. The pressurized door seals were intended to ensure that negative pressure was maintained in the FSB, so that all exiting air would be forced through the filters. Because the licensing basis was changed to remove the requirement for FSB air filtration, it is expected that the design can be changed to facilitate personnel exit. A follow-up Corrective Action (CA #6) is assigned for Operations Support to work with Safety, Engineering and Licensing to determine whether a design change is warranted, and if so, to develop a specific design change recommendation in an Engineering Request.Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2003-04719 CA Number: 3 Group HansJaeI Name I Assigned By: Operations Staff Assigned To: Operations Staff Subassigned To: Haynes,James S Haynes,James S Originated By: Haynes,James S 9/12/2003 15:40:47 Performed By: Haynes,James S 9/18/2003 13:36:03 Subperformed By: Approved By: Closed By: Haynes,James S 9/18/2003 13:36:03 Current Due Date: 09/18/2003 Initial Due Date: CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

Description:

Review ACE report for generic implications and attach revised report.09/18/2003 Response: The automatic door sealing feature is not installed at Unit 2 Fuel Storage building.

ACE report updated and attached.Subresponse

Closure Comments: Attachments:

Response Description ACE rev 1 Attachment Header Document Name: ICR-IP33-2003-04719 CA-00003 Document Location IResponse Descdption Attach Title: lACE rev 1 IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0 Entergy MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 1 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE Condition Report Number: CaBegory Level: Assigned Department:

CR-IP3-2003-04719 B Operations CR-IP3-2003-04700 Evaluation Type: Program/Process X Equipment Problem STATE 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. Power was 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 operator entry. When power to this panel was restored following offsite power recovery, the door seals deflated 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-5 was in a normal state with no alarms up. I&C was contacted to assist in researching why the door seals had inflated.

It was not understood at the time that a lighting bus was the power source for the solenoids that supplied air to the seals. Due to the complexity of the trip that included a loss of all air in the station and the EDG's the only power supply to the plant, it took some time before all panels and busses were energized.

Adding to this was the report that even though offsite power had been restored to the plant, it was not initially considered to be reliable and had to be loaded cautiously.

CORRECTIVE ACTIONS: See Problem Resolution Sheet.EWas the Event Classified as a Human Error or Station Reset? Yes IX No GENERIC IMPLICATIONS:

The automatic door sealing feature is not installed at Unit 2 Fuel Storage building.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0 fEnh ) MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 2 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE SAFETY SIGNIFICANCE:

During the event, there was never a challenge to Nuclear or Radiological safety. During refueling outages when the core is offloaded, we routinely maintain temperatures in excess of 130 degrees in the pool. Also, the "Spent Fuel Pit High Temp." alarm in the Control Room remained clear during the event. This alarm requires operator action at 135 degrees. Also, if temperature reaches 150 degrees, System Engineering must provide further guidance and resolution (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 were found. At IP-3 on 5/8/01, SFP cooling was lost for twenty minutes due to a GFCI tripping causing the BUSFPCS to shutdown (normal cooling OOS for MTC) during a refueling outage with the core fully offloaded to the pool. At that time, temperature was being maintained at 151 degrees and reached a high of 155 degrees in twenty minutes. This event was noted as NOT SIGNIFICANT 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 AC power 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 a complete loss of offsite power on 8/14/03. Temperature in the SFP increased from about 100 deg F to a maximum of 114 deg F. SFP power was lost as well as to 120VAC distribution panel 32 (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 SFP building door seals to inflate and prevent operator entry until some time during the post transient activities.

When this lighting panel was restored and circuit was reset upon offsite power recovery, the door seals deflated allowing entry into the building to manually restore SFP cooling.Was the event caused by, or identify, an equipment or component

__failure?Yes X NO IF Yes, THEN, coordinate with the appropriate Engineering Department organizations to complete 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 review results in the narrative section of this report.

IPEC SITE QUALITY RELATED IP-SMM-LI-102 Revision 0 MANAGEMENT ADMINISTRATIVE PROCEDURE MANUAL INFORMATIONAL USE ATTACHMENT 9.12 PAGE 3 OF 3 APPARENT CAUSE EVALUATION RESPONSE TEMPLATE CARB Presentation Required? (See CRG notes on YES X NO assigned CA in PCRS)INVESTIGATOR Date report completed Phone Extension of Investigator Print Name E. Gurina December 13. 2012 736-8281 Entergy CORRECTIVE ACTION CR-IP3-2003-04719 CA Number: 4 Group .Name Assigned By: CA&A Mgmt Perra,Ralph T Assigned To: Operations Shift Manager O'Donnell,Eugene E Subassigned To : Originated By: Perra,Ralph T 9/15/2003 03:22:36 Performed By: Main,Dennis E 9/22/2003 14:43:57 Subperformed By: Approved By: Closed By: Perra,Ralph T 9/23/2003 03:45:54 Current Due Date: 09/22/2003 Initial Due Date: 09/22/2003 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

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 component failed, 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 any design/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 available to 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 the blackout.

Power was restored when off-site power was available and stable and time permitted.

Since the SFP did not have any 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 the normal mod process will capture their comments on whether this modification would violate any design, Tech Spec, or safety issue.Subresponse

Closure Comments: CA can be closed based on the provided response.

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719 CA Number: 5 Group I Name I Assigned By: Operations Staff Assigned To: Safety Staff Subassigned To : Etzweiler,Joan F Stockwell,Lisa L Originated By: Etzweiler,Joan F Performed By: Bianco,Scott Subperformed By: Approved By: CIn~ted Rv" F.10/8/2003 16:45:54 12/10/2003 13:42:M~12/10/2003 14:10:21....... B Main.. De ni E....Current Due Date: 12/10/2003 CA Type: PERFORM CA Initial Due Date: 12/10/2003 CA Priority: Plant Constraint:

1. NONE CA

Description:

See CR IP3-2003-04698, Post Transient Review Report for the 8/14/03 plant trip. If someone is inside the IP3 Fuel Storage Building (FSB) when loss of 120 Vac power occurs, the building will be dark and the doors will be pressuized closed. The emergency 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 to Operations 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 the Unit 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 for some reason the exhaust fan is not lost there should only be about ?" of water negative pressure on the door and someone should be able to operate it.? Telephones will also be operable so personnel could call the CCR and Operations could secure the exhaust fan if necessary.

Subresponse:

Closure Comments: Close CA Entergy CORRECTIVE ACTION CR-IP3-2003-04719 CA Number: 6 Group I Name Assigned By: Operations Staff Etzweiler,Joan F Assigned To: Operations Staff Etzweiler,Joan F Subassigned To: Originated By: Etzweiler,Joan F 10/8/2003 17:03:37 Performed By: Etzweiler,Joan F 1/6/2004 13:17:24 Subperformed By: Approved By: Closed By: Etzweiler,Joan F 1/6/2004 13:17:24 Current Due Date: 01/06/2004 Initial Due Date: 01/06/2004 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

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 building is a life safety code issue. Safety accepts a Corrective Action with a two month due date to provide short and long term recommendations.

2 -- Re-entry to restore forced cooling of the Spent Fuel Pit (SFP). More urgent when fuel has recently been discharged from the Reactor.Long-term resolution of both above issues would include consideration of a design change. Possibilities include de-pressurization on loss of power, automatic back-up power, or unpowered manual override of seal pressurization.

Licensing advised that IP3 Tech. Spec. Amendment

1. 215 removed the requirement for FSB air filtration following a postulated Fuel Handling Accident.

The basis for the Amendment was the new IP3 source term. The pressurized door seals were intended to ensure that negative pressure was maintained in the FSB, so that all exiting air would be forced through the filters. Because the licensing basis was changed to remove the requirement for FSB air filtration, it is expected that the design 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-IP3-2003-04719 Response: 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 Operation ONOP-SFP-l, rev 12, Loss of Spent Fuel Pit Cooling ARP-0 11, rev 29, page 60, LIGHTING FEEDER AUTO-TRIP ONOP-EL-4, rev 12, Loss of Offsite Power ONOP-EL-7, rev 6, Loss of a 480V Bus -Above Cold Shutdown SOP-EL-015, rev 15, Operation of Non-Safeguards Equipment During Use of EOPs Discussed potential design change to eliminate the pressuized door seals with Systems Engineering and Engineering Programs, with results captured in Attachment of e-mail. The conclusion was that the engineers did not feel that the door pressurization 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 Fuel Pool Cooling pumps' cell 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.Based on the document review and input from Engineering and Safety as described above, the action taken was to issue the following Operations Procedure Feedbacks:

IP3-7067 -- Revise ARP-0 I1 to identify as Automatic Actions the FSB door seal pressurization and FSB elev. 95' door emergency 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 Description E-Mails About FSB Door Seals Attachment Header Document Name:[CR-IP3-2003-04719 CA-00006 Document Location IResponse Description Attach Title: IE-Mails About FSB Door Seals, From: Tesoriero, Michael Sent: Thursday, December 18, 2003 7:28 AM To: Catano, John; Eisenberg, Zvi; Sinert, Ivan; Etzweiler, loan Cc: Lee, Uz

Subject:

RE: IP3 FSB Pressurized Door Seals I believe the SOV's are powered from a lighting bus that is not powered by the EDG's until certain panels are reset.However, MCC-37 gets reset early to start the SFP pumps, only you can't get in the building to start the pumps locally due to the door seals. John is probably right. Maybe move the reset of the panel that powers the sov's up in the procedure before starting SFP pumps. A test and/or modification 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 PM To: Eisenberg, Zvi; Sinert, Ivan; Etzweiler, Joan Cc: Lee, Liz; Tesoriero, Michael

Subject:

RE: IP3 FSB Pressurized Door Seals ALL, NO, THERE IS NO REASON TO TEST AND/OR MODIFY ANYTHING.

THE DOOR SEALS INFLATE TO KEEP BAD THINGS IN, AND IF THEY ARE INFLATED, AREN'T THEY TO KEEP PEOPLE OUT WHILE THERE IS A FUEL HANDLING TYPE ACCIDENT, WHY WOULD YOU WANT TO GO IN THERE THEN? IF WE HAD TO GET IN THERE WITH R-5 ACTUATED AND A BLACKOUT TAKING PLACE WOULDN'T ALL IT TAKE TO DEFLATE THE DOOR SEALS IS PULLING THE FUSES ON R-5? IF NOT PUT A BOX CUTTER BY EACH DOOR AND CUT THE SEALS FROM THE INSIDE IF NEEDED. DON'T THE D/G'S START ON A BLACKOUT AND WOULDN'T THEY PROVIDE POWER TO THE SOV'S? JUST BECAUSE SOMEONE ASKS A "QUESTION" IT DOESN'T AUTOMATICALLY BECOME A MONUMENTAL PROBLEM John L. Catano Jr.Entergy Nuclear Northeast-IPEC Programs and Component Engineering 914-736-8348 914-736-8350 FAX 888-451-8562 PAGER JCATANO@ENTERGY.COM

---

Original Message-----

From: Eisenberg, Zvi Sent: Wednesday, December 17, 2003 1:33 PM To: Sinert, Ivan; Etzweiler, Joan Cc: Lee, Uz; Catano, John

Subject:

RE: IP3 FSB Pressurized Door Seals I recommend to performed some kind of test to review the operation of the FSB ventilation and the ability to open the personal door under the loss of power.----- Original Message-----

From: Sinert, Ivan Sent: Wednesday, December 17, 2003 1:14 PM To: Etzweiler, Joan Cc: Eisenberg, Zvi; Lee, Uz

Subject:

RE: IP3 FSB Pressurized Door Seals The door seals inflate with air and are backed up. So when power is lost the Vent System is down but the door seals are maintained.

The pressure from the seal on the latch makes the door hard to open, if opened, the seals would keep the door from closing. A modification to deflate the seal and allow for re-inflation would need to be studied by Engineering if Operations requests.

I'm not sure we should do this because we would be loosing reserve air/nitrogen each time we use it and at some point we would loose the building seal. Licensing as well as Engineering should look at licensing basis to be sure we are not in a bad place if we mod. this system.Ivan----- Original Message-----

From: Etzweiler, Joan Sent: Monday, December 15, 2003 1:12 PM To: Sinert, Ivan Cc: Eisenberg, Zvi; Lee, uz

Subject:

IP3 FSB Pressurized Door Seals Ivan, Per discussions with LL and youself, you agreed to look into the design details of the door pressurization system and personnel door latch for the FSB, to understand why operators could not 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, Zvi Sent: Monday, December 15, 2003 11:39 AM To: Etzweiler, loan

Subject:

RE: Possible Elimination of IP3 FSB Door Seals Please discuss this with Liz Lee.Thanks, Zvi----- Original Message-----

From: Etzweiler, Joan Sent: Monday, December 15, 2003 11:38 AM To: Eisenberg, Zvi

Subject:

RE: Possible Elimination of IP3 FSB Door Seals Okay, 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, Zvi Sent: Monday, December 15, 2003 11:13 AM To: Etzweiler, Joan; Canavan, Gerald Cc: Head, Jerald; Prussman, Stephen; Ubby, Earl; Sicard, Michael; Lee, Liz; Sinert, Ivan; Putnam, Charles; Digenova, Mario; Orlando, Tom

Subject:

RE: Possible Elimination of IP3 FSB Door Seals Joan, I believe we need to determine and understand the cause before we decide to change plant configuration.

Zvi----- Original Message-----

From: Etzweiler, Joan Sent: Friday, December 12, 2003 9:25 PM To: Canavan, Gerald Cc: Head, Jerald; Prussman, Stephen; Libby, Earl; Sicard, Michael; Lee, Liz; Sinert, Ivan; Putnam, Charles; Digenova, Mario; Eisenberg, Zvi

Subject:

Possible Elimination of IP3 FSB Door Seals Gerry, IPEC Operations is evaluating whether to submit an Engineering Request for a design change to eliminate 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 that the WPO Nuclear Eng. Analysis group would need to perform the technical evaluation to support 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 on 1/6/04.BACKGROUND As a result of the loss of northeast power grid event on 8/14/30, Indian Point Unit 3 lost the ability to open the Fuel Storage Building (FSB) doors.This was a problem because the Spent Fuel Pool Cooling (SFPC) Pumps are located inside the FSB. The SPFC Pumps lost power due to the black-out.

Pump motor start is local only. Loss of power to a 120 VAC distribution panel caused the FSB door seals to engage. The sealed doors prevented operator entry to manually restore SFPC. This problem would have been more urgent if fuel had recently been discharged from the Reactor. Without the FSB Exhaust Fan running, the door should not have been hard to open; yet it was. The automatic door-sealing feature is not installed at the IP2 FSB.An IPEC Licensing Engineer has advised that the need for pressurized seals was eliminated because IP3 Tech. Spec. Amendment

1. 215 removed the requirement for FSB air filtration following a postulated Fuel Handling Accident.

The pressurized door seals were intended to ensure that negative pressure was maintained in the FSB, so that all exiting air would be forced through the filters. Because the licensing basis was changed to remove the requirement for FSB air 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 cooling during 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 area radiation monitor.Thanks for your input, Gerry.Joan Efzweiler, 914-736-8207, Operations Department, Technical Support Entergy CORRECTIVE ACTION CR-IP3-2003-04719 CA Number: 7 Group I Name Assigned By: CA&A Staff ReynoldsJoseph A Assigned To: Operations Shift Manager O'Donnell,Eugene E Subassigned To : Originated By: Schmidt,George P 1/6/2004 15:08:43 Performed By: Haynes,James S 1/13/2004 10:43:58 Subperformed By: Approved By: Closed By: ReynoldsJoseph A 1/13/2004 10:57:10 Current Due Date: 01/15/2004 Initial Due Date: 01/15/2004 CA Type: CR CLOSURE REVIEW CA Priority: Plant Constraint:

1. NONE CA

Description:

CAT-B, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION 5.8.Response: CR has been reviewed for closure per ENN-LI-102 section 5.8. Additional corrective actions have been assigned.

DO NOT 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 resolution of the remaining issues, therefore this CR removed from the closure review process pending completion of the new CAs and this CA closed.

Entergy CORRECTIVE ACTION I CR-IP3-2003-04719 CA Number: 8 Group HansJaeI Name I Assigned By: Operations Support Staff Assigned To: Operations Procedure Mgmt Subassigned To: Haynes,James S Janicki.john W Originated By: Haynes,James S 1/13/2004 09:41:16 Performed By: Janicki,John W 4/7/2004 08:49:53 Subperformed By: Approved By: Closed By: Janicki,John W 4/7/2004 08:49:53 Current Due Date: 04/12/2004 Initial Due Date: 04/12/2004 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

Description:

IP3-7067 -- Revise ARP-01 1 to identify as Automatic Actions the FSB door seal pressurization and FSB elev. 95' door emergency 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-IP3-2003-04719 CA Number: 9 Group I Name I Assigned By: Operations Support Staff Assigned To: Operations Procedure Mgmt Subassigned To : Haynes,James S Janicki,John W Originated By: Haynes,James S 1/13/2004 09:43:17 Performed By: Janicki,John W 4/7/2004 08:51:46 Subperformed By: Approved By: Closed By: Janicki,John W 4/7/2004 08:51:46 Current Due Date: 04/12/2004 Initial Due Date: 04/12/2004 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

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-IP3-2003-04719 CA Number: 10 Group HansJaeI Name I Assigned By: Operations Staff Assigned To: Operations Staff Subassigned To : Haynesjames S Etzweilerjoan F Originated By: Haynes,James S 1/13/2004 10:41:49 Performed By: Etzweiler,Joan F 1/19/2004 18:10:05 Subperformed By: Approved By: Closed By: Etzweiler,Joan F 1/19/2004 18:10:05 Current Due Date: 02/17/2004 Initial Due Date: 02/17/2004 CA Type: PERFORM CA CA Priority: Plant Constraint:

1. NONE CA

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 Spent Fuel 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-IP3-2003-04719 Response: 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 Spent Fuel 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." BACKGROUND There were no safety enhancements recommended.

The listed items were merely noted by Safety as possible optional enhancements.

[Per resonses to CA #5 and CA # 6, the Safety representive considered personnel safety already adequately assured based on 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 procedure changes requested in Operations Procedure Feedbacks IP3-7067 (CA #8) and IP3-7068 (CA # 9). An expedited operator response 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 readily available 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 standard telephone jack with a very long cord, and can be easily removed or re-located.

It is used primarily for the convenience of fuel movement activities.

There are already numerous signs in the area. The addition of a permanently affixed sign would therefore be confusing or misleading.

Therefore, adding a sign to indicate a telephone is not justified.

CONCLUSION The ideas for optional safety enhancements have been reviewed and are not considered to be worth pursuing.

No further corrective action or ER is initiated.

ME 1/19/04 Subresponse

Closure Comments:

Entergy I CORRECTIVE ACTION I CR-IP3-2003-04719 CA Number: 11 Group I Name I Assigned By: CA&A Staff Assigned To: Operations Watch Mgmt Subassigned To: Reynolds,Joseph A Vitale,Anthony J Originated By: Schmidt,George P 4/7/2004 09:35:03 Performed By: Main,Dennis E 4/9/2004 08:53:36 Subperformed By: Approved By: Closed By: Reynolds,Joseph A 4/12/2004 17:24:14 Current Due Date: 04/14/2004 Initial Due Date: 04/14/2004 CA Type: CR CLOSURE REVIEW CA Priority: Plant Constraint:

1. NONE CA

Description:

CAT-B, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH ENN-LI-102, SECTION 5.8.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-IP3-2005-00239 Originator:

Goerres,Andrew P Originator Group: Operations Watch Staff Supervisor Name: PitsleyDavid K Discovered Date: 01/21/2005 19:21 Originator Phone: 8214 Operability Required:

Y Reportability Required:

N Initiated Date: 01/21/2005 19:26 Condition

==

Description:==

During restoration following performance of 3PT-V055 (Exercise Close of Valve AC-726B, RWST Purification Return Check Valve), Valve AC-719A (Spent Fuel Pit Purification Loop Supply Isolation) failed while opening. The valve failed in such a way that the handwheel is unable to be used to close the valve. There was no leakage from the valve evidenced after this failure and the affected system was left in a stable condition.

Immediate Action

Description:

Suggested Action

Description:

EQUIPMENT:

Tag Name AC-719A Ta2 Suffix Name Component Code Process System Code VD SFPC REFERENCE ITEMS: Type Code#LEVEL OF DEFENSE KEYWORDS KEYWORDS KEYWORDS TEAM 3B WON TRENDING (For Reference Purposes C Trend Type KEYWORDS Description Union operator initiated

-surveillance testing Valve Spent Fuel Cooling 3PT-V055 IP3-05-10939)nly): Trend Code KW-SELF-REVEALING Entergy I ADMIN I CR-iP3-2005-00239 Initiated Date: 1/21/2005 19:26 Owner Group :System Eng Primary System Mgmt Current Contact: Current Significance:

D -ADMTN CLOSURE Closed by: Harrison,Christine B 1/26/2005 10:38 Summary

Description:

During restoration following performance of 3PT-V055 (Exercise Close of Valve AC-726B, RWST Purification Return Check Valve), Valve AC-719A (Spent Fuel Pit Purification Loop Supply Isolation) failed while opening. The valve failed in such a way that the handwheel is unable to be used to close the valve. There was no leakage from the valve evidenced after this 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-iP3-2005-00239 OperabilityVersion:

1 Operability Code: ADMIN -NA Immediate Report Code: NOT REPORTABLE Performed By: Lyon,Daniel R 01/22/2005 05:34 Approved By: Faughnan,Philip J 01/22/2005 06:23 Operability

==

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 any DBA and does not affect the operation or function any safety related systems. There is no external leakage and no compensatory actions are required.Approval Comments: Approved Entergy A S S I G N M E N T S CR-IP3-2005-00239 Version: 1 Significance Code: D -ADMIN CLOSURE Classification Code: NON-SIGNIFICANT Owner Group: System Eng Primary System Mgmt Performed By: Harrison,Christine B Assignment

==

Description:==

1/25/05: Per CRG, close to work order IP3-05-10939 (Y).01/26/2005 10:37 Entergy CONDITION REPORT I CR-IP3-2007-00859 Originator:

Stubble,Mark D Originator Group: Operations Watch Staff Supervisor Name: Baker 1I,John C Discovered Date: 03/05/2007 22:50 Originator Phone: 5431 Operability Required:

N Reportability Required:

N Initiated Date: 03/05/2007 22:52 Condition

==

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 Code CR DITG TEAM 2D Description IP2-2007-01138 IP2-07-00058 TRENDING (For Reference Purposes Only): Trend Type AW HEP FACTOR INPO BINNING KEYWORDS REPORT WEIGHT Trend Code OPMG H OP1 KW-DUPLICATE CR I Entergy ADMIN CR-IP3-2007-00859 Initiated Date: 3/5/2007 22:52 Owner Group :Operations Watch Mgmt Current Contact: Current Significance:

D -ADMIN CLOSURE Closed by: Harrison,Christine B 3/6/2007 10:27 Summary

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-IP3-2007-00859 Version: 1 Significance Code: D -ADMIN CLOSURE Classification Code: NON-SIGNIFICANT Owner Group: Operations Watch Mgmt Performed By: Harrison,Christine B Assignment

==

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-IP3-2009-02219 Originator:

Roberts,Laurence R Originator Group: Operations Support Staff IP3 Supervisor Name: Jordan II,John B Discovered Date: 05/05/2009 07:53 Originator Phone: 5995 Operability Required:

N Reportability Required:

N Initiated Date: 05/05/2009 08:00 Condition

==

Description:==

RWST Purification Pump motor has two separate component IDs in PASSPORT.

SI-P-B (M) is one component ID in the SI system. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of every PM for this same component.

Immediate Action

Description:

Suggested Action

Description:

EQUIPMENT:

Ta2 Name SI-P-B (M)RWST PURIFICATI ON PMP REFERENCE ITEMS: Type Code KEYWORDS Ta2 Suffix Name Component Code Process System Code LCLS/NS LCLM/NS MOTOR MOTOR SI SFPC Description component ID TRENDING (For Reference Purposes Only): Trend Type KEYWORDS KEYWORDS KEYWORDS REPORT WEIGHT KEYWORDS KEYWORDS HEP FACTOR KEYWORDS INPO BINNING Trend Code KW-PASSPORT KW-CONFIGURATION OTHER KW-PUMP 1 KW-COMPUTER PROGRAM KW-PREVENTATIVE MAINTENANCE P KW-SOFTWARE ER4 ESDE KW-DOCUMENT CONTROL KW-PROCEDURE NOT UPDATED KW-CHANGE MANAGEMENT KW-MODIFICATION CLOSE OUT AJ KEYWORDS KEYWORDS KEYWORDS KEYWORDS Entergy I ADMIN I CR-iP3-2009-02219 Initiated Date: 5/5/2009 8:00 Owner Group :Eng DE Config Mgmt IP3 Current Contact: Joe Reynolds Current Significance:

C Closed by: Reynolds,Joseph A 9/11/2009 16:26 Summary

Description:

RWST Purification Pump motor has two separate component IDs in PASSPORT.

SI-P-B (M) is one component ID in the SI system. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of every PM 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 SI system. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of every PM for 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-IP3-2009-02219 Version: 1 Significance Code: C Classification Code: CORRECT/ADDRESS Owner Group: Eng DE Config Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

05/07/2009 11:26 Entergy CORRECTIVE ACTION CR-IP3-2009-02219 CA Number: 1 Group .Name Assigned By: Eng DE Config Mgmt IP3 McCaffirey,Thomas S Assigned To: Eng DE Config Mgmt IP3 Lee,Lizabeth Ann Subassigned To: Eng DE Config Staff IP3 RadvanskyMichael S Originated By: zzip2crg 5/7/2009 11:45:06 Performed By: Thoms,Rudolf 5/26/2009 14:10:48 Subperformed By: Radvansky,Michael S 5/26/2009 14:06:03 Approved By: Closed By: Thoms,Rudolf 5/26/2009 14:10:48 Current Due Date: 05/28/2009 Initial Due Date: 05/28/2009 CA Type: DISP -CA CA Priority: Plant Constraint:

1. NONE CA

Description:

Please review and assign further corrective actions as required.Response: Sub Responce Approved Subresponse

Condition

==

Description:==

RWST Purification Pump motor has two separate component IDs in PASSPORT.

SI-P-B (M) is one component ID in the St system. RWST Purification Pmp (M) is the other ID in the SFPC system. The consequence of this to generate two of every PM 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 a single component.

There are two separate and distinct pumps (and motors) involved.

One pump is the RWST Purification pump (ID # RWST PURIFICATI) 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 used later as a source of power for the CVCS Hold-up Tank Recirculation pump under modification MMP-93-3-242.

The electrical 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 of documentation mainly in the mechanical area were not addressed to reflect this change. As an example, the Flow Diagram still shows the pump as active with no note that it has been electrically disconnected.

The Safety Injection System Design Basis 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 the source 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 disconnected and to ensure any other mod closeout actions have been satisfactorily completed.

Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2009-02219 CA Number: 2 Group Name Assigned By: Eng DE Config Mgmt IP3 RadvanskyMichael S Assigned To: Eng DE Config Mgmt IP3 Lee,Lizabeth Ann Subassigned To: Eng DE Config Staff IP3 RadvanskyMichael S Originated By: Radvansky,Michael S 5/26/2009 13:57:46 Performed By: Lee,Lizabeth Ann 8/5/2009 19:18:21 Subperformed By: Radvansky,Michael S 8/5/2009 13:14:52 Approved By: Closed By: Lee,Lizabeth Ann 8/5/2009 19:18:21 Current Due Date: 08/07/2009 Initial Due Date: 08/07/2009 CA Type: ACTION CA Priority: Plant Constraint:

1. NONE CA

Description:

This is a tracking CA for completion of EC for resolving status of equipment records for RWST Recirculation pump and motor since the motor has been electrically disconnected.

Note: Due to Passport being down at the time of writing no number 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 to drawing 9321-F-27503.

Closure Comments:

Entergy I CORRECTIVE ACTION I CR-IP3-2009-02219 CA Number: 3 Group I Name I Assigned By: Eng DE Config Mgmt IP3 Assigned To: Eng DE Mech Mgmt IP3 Subassigned To: Eng DE Mech Staff IP3 Radvansky,Michael S Myers,Valerie E Uwechue,Godwin 0 Originated By: Radvansky,Michael S 5/26/2009 14:02:23 Performed By: Myers,Valerie E 9/9/2009 10:13:56 Subperformed By: Uwechue,Godwin 0 9/9/2009 07:21:48 Approved By: Closed By: Myers,Valerie E 9/9/2009 10:13:56 Current Due Date: 09/17/2009 CA Type: ACTION Initial Due Date: 09/17/2009 CA Priority: Plant Constraint:

1. NONE CA

Description:

Update the Safety Injection System DBD to reflect the current status of the RWST Recirculation pump i.e. that it has been electrically disconnected and ensure any other mod closeout actions associated with this electrical disconnection have been satisfactorily 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 RWST Recirculation 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-IP3-2009-02219 Corrective Action : CR-IP3-2009-02219 CA-00003 Version: I Requested Duedate: 09/17/2009 Requested By: Uwechue,Godwin 0 Approved By: Myers,Valerie E Approved:

I-V Previous Duedate: 08/14/2009 08/11/2009 08/11/2009 Request

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-IP3-2009-02219 CA Number: 4 Group I Name I Assigned By: CAA Staff IP3 Assigned To: Eng DE Config Mgmt IP3 Subassigned To: Reynolds,Joseph A Lee,Lizabeth Ann Originated By: Jowitt,Roseann 9/9/2009 10:29:49 Performed By: Lee,Lizabeth Ann 9/10/2009 05:40:31 Subperformed By: Approved By: Closed By: Reynolds,Joseph A 9/11/2009 16:25:36 Current Due Date: 09/24/2009 Initial Due Date: 09/24/2009 CA Type: CR CLOSURE REVIEW CA Priority: Plant Constraint:

1. NONE CA

Description:

CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW CR AND APPROVE / DISAPPROVE CLOSURE IN ACCORDANCE WITH EN-LI-102, SECTION 5.9.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-IP3-2011-03729 Originator:

PetersonJoseph F Originator Phone: 6899 Originator Group: P&C Eng Codes Staff IP3 Operability Required:

Y Supervisor Name: Azevedo,Nelson F Reportability Required:

Y Discovered Date: 07/26/2011 06:06 Initiated Date: 07/26/2011 06:37 Condition

==

Description:==

The following conditions were noted during a Boric Acid 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- 1 852A 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.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 Code AC-739A EX/SR/MR VALVE RHR AC-739B EX/SR/MR VALVE RHR AC-740A EX/SR/MR VALVE RHR AC-727B EX/SR/MR VALVE SFPC SI-MOV-1852A HCLS/SR/MR VALVE SI REFERENCE ITEMS: Type Code Description KEYWORDS Boric Acid WON 00285361 Y WON 00285362 Y WON 00285360 Y WON 00285364 Y WON 00285363 Y WRN 00244044 WRN 00244045 WRN 00244046 WRN 00244048 WRN 00244049 TRENDING (For Reference Purposes Only): Trend Type Trend Code INPO BINNING ER3 HEP FACTOR E EL ESSE EL ESSE Entergy CONDITION REPORT CR-iP3-2011-03729 TRENDING (For- Rafren, Pro~o niv): Trend Type KEYWORDS KEYWORDS REPORT WEIGHT Trend Code KW-VALVE PACKING KW-LEAKS-BORON I

Entergy ADMIN CR-IP3-2011-03729 Initiated Date: 7/26/2011 6:37 Owner Group :P&C Eng Codes Mgmt IP3 Current Contact: Joe Reynolds Current Significance:

D Closed by: Reynolds,Joseph A 8/3/2011 5:25 Summary

Description:

The following conditions were noted during a Boric Acid 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- 1 852A 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.Remarks

Description:

Closure

Description:

Per CAA review, noted the CRG approved the closure of this CR issue "The following conditions were noted during a Boric Acid 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 the referenced work orders noted to have the PCRS control field Y attribute applied. Therefore with the BACC program review action 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 in BACC Program.

Entergy OPERABILITY CR-IP3-2011-03729 OperabilityVersion:

1 Operability Code: OPERABLE Immediate Report Code: NOT REPORTABLE Performed By: ZastrowAndrew 07/26/2011 17:30 Approved By: Faughnan,Philip J 07/26/2011 17:33 Operability

==

Description:==

Valves AC-739A, 739B, 740A, and SI-MOV- 1 852A are part of the ECCS system. Valve AC-727B is part of SFP Purification.

The boron accumulations described are minor with no active leakage. The brown tint on SI-MOV- 1852A appears to be grease that has mixed in with the boron and not any valve corrosion products.

The small amount of boron present 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-COI leakage quantificaiton.

Additionally, since the leakage is too small to quantify, the leakage amount does not challenge IVSWS leakage specifications.

RCS Leakage is within T.S. limits. Valves AC-739A, -739B, -740A, SI-MOV-1852A and AC-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-IP3-2011-03729 Version: 1 Significance Code: D Classification Code: CLOSE TO WMS Owner Group: P&C Eng Codes Mgmt IP3 Performed By: Harrison,Christine B 07/28/2011 12:21 Assignment

==

Description:==

7/28/11: Per CRG, close to referenced work orders. A corrective action is being assigned to Code Programs to include in BACC Program.

Entergy I REPORTABILITY I CR-IP3-2011-03729 Reportability Version: 1 Report Number: Report Code: NOT REPORTABLE Boilerplate Code: Performed By : BurneyMichael W Reportability

==

Description:==

This condition does not meet the reporting criteria of SMM -LI-108.07/27/2011 14:47 Entergy CORRECTIVE ACTION I CR-IP3-2011-03729 CA Number: I Group..... ... ... I Name.... I Assigned By: P&C Eng Codes Mgmt IP3 Assigned To: P&C Eng Codes Mgmt IP3 Subassigned To : P&C Eng Codes Staff IP3 AzevedoNelson F Azevedo,Nelson F Herrmann,Robert D Originated By: Zzip2crg 7/28/2011 12:25:19 Performed By: Azevedo,Nelson F 8/2/2011 10:21:26 Subperformed By: Herrmann,Robert D 8/2/2011 07:58:04 Approved By: Closed By: Azevedo,Nelson F 8/2/2011 10:21:26 Current Due Date: 08/11/2011 Initial Due Date: 08/11/2011 CA Type: ACTION CA Priority: Plant Constraint:

1. NONE CA

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 light brown 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-I1P3-2009-04483 Originator:

Weglinski,Michael P Originator Group: Rad Protection Staff 1P3 Supervisor Name: Burns,Thomas F Discovered Date: 11/13/2009 08:15 Originator Phone: 8440 Operability Required:

N Reportability Required:

N Initiated Date: 11/13/2009 08:20 Condition

==

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 to Dosimetry to be issued a replacement DLR.Suggested Action

Description:

Actions as taken.REFERENCE ITEMS: Type Code PRC Description EN-RP-203 TRENDING (For Reference Purposes Only): Trend Type INPO BINNING HEP FACTOR WR KEYWORDS RAD PROTECTION FOCUS RAD PROTECTION FOCUS KEYWORDS KEYWORDS REPORT WEIGHT Trend Code RPI H RPMG KW-RAD PROTECTION MANAGMENT RP-DOSIMETRY, LOST RP-EXPOSURE CONTROL KW-MANAGEMENT EXPECTATIONS KW-DOSE ASSESSMENT I

Entergy ADMIN I CR-IP3-2009-04483 Initiated Date: 11/13/2009 8:20 Owner Group :Rad Protection Mgmt IP3 Current Contact: Current Significance:

D Closed by: Harrison,Christine B 11/17/2009 13:15 Summary

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-IP3-2009-04483 Version: 1 Significance Code: D Classification Code: ACTIONS TAKEN Owner Group: Rad Protection Mgmt IP3 Performed By: Harrison,Christine B 11/17/2009 12:34 Assignment

==

Description:==

11/17/09:

Per CRG, close to actions taken as described in Immediate Action Description.

I Entergy CONDITION REPORT I CR-IP3-2011-04515 Originator:

Carballo,Edgardo N Originator Group: Maint FIN Staff IP2 Supervisor Name: Downes,Oliver P Discovered Date: 09/29/2011 06:10 Originator Phone: 7551 Operability Required:

N Reportability Required:

N Initiated Date: 09/30/2011 06:33 Condition

==

Description:==

While replacing the filter in the SFP under WO# 291282, discovered that the filter vessel cover bolts were of different size (Head of bolt). This job, potentially having high dose, should be looked at, because we can't have two mechanics waiting on a high dose area until someone gets the right tool.Immediate Action

Description:

Informed supervisor, and wrote CR Suggested Action

Description:

Recommend that on the next filter change, replace all the bolts to the same size EQUIPMENT:

Tag Name ACFLSF1 Tag Suffix Name Component Code Process System Code NC/NS FILTER SFPC REFERENCE ITEMS: Type Code CR WON WON Description IP3-2011-04521 00291282 292955 Y TRENDING (For Reference Purposes Only): Trend Type CB INPO BINNING REP FACTOR KEYWORDS KEYWORDS KEYWORDS KEYWORDS KEYWORDS REPORT WEIGHT Trend Code ESSE CM2 P KW-SPENT FUEL STORAGE KW-CONFIGURATION OTHER KW-WORK PACKAGE PLANNING KW-ALARA CEC 1 Entergy ADMIN CR-IP3-2011-04515 Initiated Date: 9/30/2011 6:33 Owner Group :Maintenance Mgmt IP3 Current Contact: Current Significance:

C Closed by: Ferretti,Michael D 10/11/2011 13:51 Summary

Description:

While replacing the filter in the SFP under WO# 291282, discovered that the filter vessel cover bolts were of different size (Head of bolt). This job, potentially having high dose, should be looked at, because we can't have two mechanics waiting 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 have been satisfactorily completed and no additional Corrective Actions are required.

Entergy AS SIGN ME NT S I CR-IP3-2011-04515 Version: 1 Significance Code: C Classification Code: CORRECT/ADDRESS Owner Group: Maintenance Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

10/4/11: Level 2 HPER for Maintenance-FIN.

10/05/2011 06:19 Entergy CORRECTIVE ACTION CR-IP3-2011-04515 CA Number: 1 GroupP- Name Assigned By: Industrial Safety-HU Mgmt IP3 Eisenstadt,Charles Assigned To: Maint FIN Mgmt IP3 Bailey,Timothy H Subassigned To : Originated By: Eisenstadt,Charles 10/4/2011 11:03:39 Performed By: Ferretti,Michael D 10/6/2011 09:05:56 Subperformed By: Approved By: Closed By: Eisenstadt,Charles 10/6/2011 17:22:41 Current Due Date: 10/11/2011 Initial Due Date: 10/11/2011 CA Type: HUMAN PERF CA Priority: Plant Constraint:

1. NONE CA

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 concurrence NO 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 initiator identified an existing condition that was intended to improve this specific job. A work request will be initiated and documented 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 be determined who was involved in making all of the filter cover bolts different head sizes. Most likely this is an historic issue that has happened over the years.Subresponse

Closure Comments: Close to actions taken .See response Entergy CORRECTIVE ACTION I CR-IP3-2011-04515 CA Number: 2 Group I Name I Assigned By: Maintenance Mgmt IP3 Assigned To: Maintenance Mgmt IP3 Subassigned To : Maint FIN Mgmt IP3 Kirkpatrick,John Kirkpatrick,John Bailey,Timothy H Originated By: Zzip2crg 10/5/2011 06:37:16 Performed 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: 10/26/2011 CA Type: DISP -CA Initial Due Date: 10/26/2011 CA Priority: Plant Constraint:

NONE CA

Description:

You have been assigned as the Responsible Manager for this Category "C", Non-Significant Condition Report by the CRG Address/correct the identified condition per EN-LI-102.

Perform disposition review, investigate as needed, and ensure actions 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-IP3-2012-01710 Originator:

Stuart,Christopher Originator Group: Operations Watch Staff IP3 Supervisor Name: Dignam,John M Discovered Date: 06/05/2012 09:58 Originator Phone: 8214 Operability Required:

Y Reportability Required:

Y Initiated Date: 06/05/2012 10:00 Condition

==

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 delta p is roughly reading 12-13 psid and trending up slowly. This filter should be changed out soon. WRT# 00274556 Immediate Action

Description:

Contacted FSS of slowly increasing trend.Suggested Action

Description:

Change the filter out.EQUIPMENT:

Tae Name ACFLSF1 Tag Suffix Name Component Code Process System Code NC/NS FILTER SFPC REFERENCE ITEMS: Type Code CR KEYWORDS KEYWORDS KEYWORDS KEYWORDS TEAM 3E WON WRN Description IP3-2012-01741 SPF Filter high delta P filter Spent fuel pit filter 00317376 Y 00274556 TRENDING (For Reference Purposes Only): Trend Type EM INPO BINNING HEP FACTOR REPORT WEIGHT KEYWORDS KEYWORDS KEYWORDS KEYWORDS Trend Code ESSE ER3 E I KW-LOGS KW-FUEL POOL COOLING KW-STRAINER KW-PRESSURE TRANSMITTER Entergy ADMIN I CR-IP3-2012-01710 Initiated Date: 6/5/2012 10:00 Owner Group :System Eng Primary System Mgmt IP3 Current Contact: Current Significance:

D Closed by: Harrison,Christine B 6/23/2012 5:52 Summary

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 delta p is roughly reading 12-13 psid and trending up slowly. This filter should be changed out soon. WRT# 00274556 Remarks

Description:

Closure

Description:

6/7/12: Per CRG, close to work order 00317376 (Y).

Entergy OPERABILITY CR-IP3-2012-01710 OperabilityVersion:

1 Operability Code: EQUIPMENT FUNCTIONAL Immediate Report Code: NOT REPORTABLE Performed By: ZastrowAndrew 06/05/2012 11:17 Approved By: Faughnan,Philip J 06/05/2012 15:09 Operability

==

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 to be replaced shortly. SFP filter remains in service and is FUNCTIONAL.

Approval Comments: Approved Entergy I ASSIGNMENTS I CR-IP3-2012-01710 Version: 1 Significance Code: D Classification Code: CLOSE TO WMS Owner Group: System Eng Primary System Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

6/7/12: Per CRG, close to work order 00317376 (Y).06/07/2012 11:39 Entergy REPORTABILITY I CR-IP3-2012-01710 Reportability Version: 1 Report Number: Report Code: NOT REPORTABLE Boilerplate Code: Performed By : BurneyMichael W Reportability

==

Description:==

This Non-TS equipment is functional, not reportable.

06/11/2012 14:51 Entergy I CONDITION REPORT CR-IP3-2012-01741 Originator:

Leenig,Scott R Originator Group: Operations Watch Staff IP3 Supervisor Name: Lizzo,Nicholas Discovered Date: 06/07/2012 10:03 Originator Phone: 8214 Operability Required:

Y Reportability Required:

Y Initiated Date: 06/07/2012 10:08 Condition

==

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 the filter was bypassed per 3-sop-sfp-00

1. An existing WRT was written for this when the filter was approaching its upper limit at 14 lbs the wrt number is 00274556 and the CR # is CR-IP3-2012-01710.

Immediate Action

Description:

Suggested Action

Description:

EQUIPMENT:

Taa Name ACFLSFI REFERENCE ITEMS: Type Code CR PRC WON WRN Tag Suffix Name Component Code Process System Code NC/NS FILTER SFPC Description 01710 3-SOP-SFP-001 00317376 00274556 TRENDING (For Reference Purposes Only): Trend Type HEP FACTOR INPO BINNING EM KEYWORDS KEYWORDS KEYWORDS KEYWORDS REPORT WEIGHT Trend Code E ER3 ESSE KW-LOGS KW-PRESSURE TRANSMITTER KW-FUEL POOL COOLING KW-STRAINER I

Entergy ADMIN I CR-IP3-2012-01741 Initiated Date: 6/7/2012 10:08 Owner Group :System Eng Primary System Mgmt IP3 Current Contact: Current Significance:

D Closed by: Harrison,Christine B 6/23/2012 7:00 Summary

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 the filter was bypassed per 3-sop-sfp-00

1. An existing WRT was written for this when the filter was approaching its upper limit at 14 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-IP3-2012-01741 OperabilityVersion:

1 Operability Code: NOT REQUIRED Immediate Report Code: NOT REPORTABLE Performed By: Andersen,Robert Jon 06/07/2012 10:33 Approved By: Lewis,Matthew W 06/07/2012 11:11 Operability

==

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 a minimum water level to provide sufficient iodine scrubbing and shielding in the event of a fuel handling accident.

Further operability review is therefore not required.

This condition is not reportable per IP-SMM-LI-108 Approval Comments: Approve.

Entergy I ASSIGNMENTS I CR-IP3-2012-01741 Version: 1 Significance Code: D Classification Code: CLOSE TO WMS Owner Group: System Eng Primary System Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

6/11/12: Per CRG, close to work order 00317376 (Y).06/11/2012 11:22 Entergy REPORTABILITY I CR-IP3-2012-01741 Reportability Version: 1 Report Number: Report Code: NOT REPORTABLE Boilerplate Code: Performed By : Rokes,Charles B 06/08/2012 08:32 Reportability

==

Description:==

Recorded condition does not meet reporting criteria of SMM-LI- 108 based on operations concllusion the spent fuel pit filter does not affect the ability of the spent fuel pool to perform its design function which is to maintain a minimum water level to provide sufficient iodine scrubbing and shielding in the event of a fuel handling accident.

Entergy CONDITION REPORT CR-IP3-2012-01768 Originator:

Conroy,Patric W Originator Group: NSA Director IP3 Supervisor Name: VentosaJohn A Discovered Date: 06/08/2012 14:05 Originator Phone: 9142546668 Operability Required:

Y Reportability Required:

Y Initiated Date: 06/08/2012 14:20 Condition

==

Description:==

Based on questions raised by NRC resident regarding mode restrictions on use of RWST Purification system associated with CR-IP3-2012-00485 (IP3 LER 2012-002-00), it appears that additional procedural restrictions for use of this system and operation of its associated valves are required to prevent the RWST being connected to non-seismic systems or portions thereof 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 (Recirculation and/or Purification of the Refueling Water Storage Tank) to place mode restrictions on use of this procedure which were completed under CA#3 to this CR. However, a review of 3-SOP-SFP-001 (Spent Fuel Pit Cooling and Purification System Operation), Section 4. 1.1 (Filling SFP Transfer Canal form RWST) identifed that RWST Purification system boundary valves may not be adequatley controlled to prevent connection of the RWST to non-seismic piping while in Modes 1,2,3 and 4.Immediate Action

Description:

Spoke with Shift Manager to verify SFP Transfer Canal not currently being filled from RWST Suggested Action

Description:

Revise 3-SOP-SFP-001 to include mode restriction for filling SFP transfer canal from RWST; perform additional extent of condition review for other procedures.

EQUIPMENT:

Tag Name RWST-31 Tag Suffix Name Component Code Process System Code HCLS/SR/MR VESSEL SI REFERENCE ITEMS: Type Code CR LER PRC PRC Description IP3-2012-00485 2012-002-00 3-SOP-SI-003 3-SOP-SFP-00 1 TRENDING (For Reference Purposes Only): Trend Type REPORT WEIGHT CU INPO BINNING HEP FACTOR KEYWORDS KEYWORDS KEYWORDS Trend Code 3 OPMG CM]1 P KW-PROCEDURAL DEFICIENCY KW-TANK KW-NRC Entergy ADMIN I CR-IP3-2012-01768 Initiated Date: 6/8/2012 14:20 Owner Group :Operations Support Mgmt IP3 Current Contact: Current Significance:

C Closed by: Main,Dennis E 10/15/2012 8:49 Summary

Description:

Based on questions raised by NRC resident regarding mode restrictions on use of RWST Purification system associated with CR-IP3-2012-00485 (IP3 LER 2012-002-00), it appears that additional procedural restrictions for use of this system and operation of its associated valves are required to prevent the RWST being connected to non-seismic systems or portions thereof 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 (Recirculation and/or Purification of the Refueling Water Storage Tank) to place mode restrictions on use of this procedure which were completed under CA#3 to this CR. However, a review of 3-SOP-SFP-001 (Spent Fuel Pit Cooling and Purification System Operation), Section 4.1.1 (Filling SFP Transfer Canal form RWST) identifed that RWST Purification system boundary valves may not be adequatley controlled to prevent connection of the RWST to non-seismic piping while in Modes 1,2,3 and 4.Remarks

Description:

Closure

Description:

Per Operations Department review, this CAT C CR issue was approved for closure by the Operations department.

The issue resolution was captured, therefore the DPIC verified/performed the quality closure review, noted the trend codes applied and then closed the CR.

Entergy OPERABILITY CR-IP3-2012-01768 OperabilityVersion:

1 Operability Code: ADMIN -NA Immediate Report Code: NOT REPORTABLE Performed By: Andersen,Robert Jon 06/08/2012 14:27 Approved By: Ras,Thomas 06/08/2012 15:28 Operability

==

Description:==

The condition described in the body of the CR describes a procedural issue and is adminstrative in nature and therefore Admin-N/A.

Note that the RWST purification loop is currently not in service. This condition is not reportable per IP-SMM-LI-108.Approval Comments: approved Entergy I ASSIGNMENTS I CR-IP3-2012-01768 Version: 1 Significance Code: C Classification Code: CORRECT/ADDRESS Owner Group: Operations Support Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

06/12/2012 11:06 Entergy REPORTABILITY I CR-IP3-2012-01768 Reportability Version: 1 Report Number: Report Code: NOT REPORTABLE Boilerplate Code: Performed By : BurneyMichael W Reportability

==

Description:==

This condition is administrative related not reportable.

06/12/2012 12:47 Entergy I CORRECTIVE ACTION ICR-IP3-2012-01768 CA Number: I Grouo I Name I Assigned By: Operations Support Mgmt 1P3 Assigned To: Operations Support Mgmt 1P3 Subassigned To : Operations Procedure Staff IP3 Dinelli,John Smyers Jr,Carl Dennis Gander,Thomas E Originated By: Zzip2crg Performed By: Balletta,John F Subperformed By: Balletta,John F Approved By: Closed By: Balletta,John F 6/13/2012 07:40:55 7/3/2012 12:37:40 7/3/2012 12:36:39 7/3/2012 12:37:40 Current Due Date: 07/06/2012 Initial Due Date: 07/06/2012 CA Type: DISP -CA CA Priority:

3 Plant Constraint:

NONE CA

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-IP3-2012-01768 Subresponse

Revised 3-SOP-SFP-001, Rev. 25, to include new P&L 2.1 and CAUTIONS indicating The RWST is inoperable whenever it is connected to the purification system due to connection to non-qualified seismic piping. Sections 4.1.1 and 4.3.7 SHALL 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 the purification loop in service to demonstrate isolation capability and take credit for this passive, Safety Related, Class I isolation boundry. This is accomplished by scheduleing and implementing WR 00-05301-00.

This implies if WR 00-05301-00 is NOT implemented prior to placing the purification loop in service, procedures need to prohibit opening AC-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 whenever it is connected to the purification system due to connection to non-qualified seismic piping. Section 4.7.1 SHALL NOT be performed 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 currently active. This test references SP-LIC-03-02, Reissue SP-LIC-03-01 with Supplemental Guidance on Dedicated Operator for CR-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 for CR-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 as necessary to meet the requirements of NSE 99-3-035 SFPC, Rev. 1 Issue CA to determine if 3-PT-V055, EXERCISE CLOSE OF AC-726B, RWST PURIFICATION RETURN CHECK VALVE 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-IP3-2012-01768 CA Number: 2Name Assigned By: Operations Procedure Mgmt IP3 Balletta,John F Assigned To: Licensing Mgmt IP3 Walpole,Robert W Subassigned To: Licensing Staff lP3 Prussman,Stephen G Originated By: Balletta,John F 7/3/2012 12:31:23 Performed By: Walpole,Robert W 9/24/2012 16:39:56 Subperformed By: Prussman,Stephen G 9/24/2012 11:42:47 Approved By: Closed By: Walpole,Robert W 9/24/2012 16:39:56 Current Due Date: 09/27/2012 Initial Due Date: 09/27/2012 CA Type: ACTION CA Priority:

4 Plant Constraint:

1. NONE CA

Description:

Determine if SP-LIC-03-02, Reissue SP-LIC-03-01 with Supplemental Guidance on Dedicated Operator for CR-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 documents providing guidance on manual action. ?The need for manual action can arise in a number of contexts (e.g. to support a surveillance test, to support a temporary system configuration during maintenance or to address a degraded or non-conforming condition).

The NRC guidance was written primarily for use of manual action when degraded/non-conforming conditions are not accepted as is (e.g., manual testing of boron versus N32 shutdown indication for TRM) but are also applicable to other cases such as temporary operation 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, RWST purification).?

The NRC identified other examples in which licensees failed to recognize that aligning nonseismic piping to the RWST would require TS LCO action statement entry, system modifications, or license amendments in Information Notice 2012-01. ?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 boundary valve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expressly permit operation under such measures or the licensee can demonstrate that the RWST still meets the TS definition of operability without reliance on compensatory measures.?

?Applying compensatory measures for TS required equipment in lieu of meeting the requirements of the LCO could constitute a change to the TS, which is prohibited by 10 CFR 50.59(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,? does allow 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 manual action is taken. However, planned maintenance cannot rely on manual action for a longer period of time than the allowed outage time for the affected LCO absent NRC approval.Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768 Attachments:

Subresponse Description IN-2012-01 Subresponse Description SP-LIC-03-02 Attachment Header Document Name: luntitled Document Location PSubresponse Description Attach Title:

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION OFFICE OF NEW REACTORS WASHINGTON, DC 20555-0001 January 26, 2012 NRC INFORMATION NOTICE 2012-01: SEISMIC CONSIDERATIONS-PRINCIPALLY ISSUES INVOLVING TANKS ADDRESSEES All holders of an operating license or construction permit for a nuclear power reactor under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," except those who have permanently ceased operations and 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." PURPOSE The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform addressees of recent operating experience related to seismic concerns.

The NRC expects recipients to review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

Suggestions contained in this IN are not NRC requirements; therefore, no specific action or written response is required.DESCRIPTION OF CIRCUMSTANCES LaSalle County Station In October 2010, NRC inspectors raised concerns about the adequacy of the seismic analysis for the standby liquid control (SLC) test tanks at LaSalle County Station. The test tanks are nonsafety related but are located near safety-related components in the SLC system. The inspectors determined that the seismic analysis had several errors and omissions.

The analysis did 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 the SLC test tanks contain water they could potentially fall over or collapse during a seismic event and impact safety-related equipment located nearby. By procedure, the water levels in the test tanks 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 be drained after testing. The revised analysis also determined that the test tanks would not collapse during a seismic event if they are empty.ML11292A175 IN 2012-01 Page 2 of 5 The licensee stated that the original design for LaSalle County Station did not consider the possibility of nonsafety-related, nonseismically-qualified items falling over during a seismic event. 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 test tanks was determined to be inadequate.

Besides the corrective actions mentioned above, the licensee revised its procedure for the SLC system testing to state that the SLC system must be declared inoperable when the test tanks contain water. The licensee is considering additional corrective actions.The following documents contain additional information on these issues at LaSalle County Station: 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) Accession No. ML110460708 Exelon Generation Company, "Licensee Event Report 2010-003-00," LaSalle County Station, dated December 21, 2010, ADAMS Accession No. ML103560658 River Bend Station On January 14, 2009, a licensee investigation of operational practices related to the SLC system concluded that, from March 14, 2003, to October 28, 2008, a seismic event could have rendered the SLC system incapable of performing its design safety function as credited in the station accident analysis.

Although the safety significance of this event was low, the licensee reported it in accordance with 10 CFR 50.73, "Licensee Event Report System," as an operation prohibited 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 test procedure that allowed water to remain in the SLC test tank following testing. The test tank is classified as a seismic Class 2 component, which means that it is designed and installed so that its 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 this condition was not analyzed.

Therefore, a seismic event could potentially render both trains of SLC inoperable if it occurred when water was left in the test tank. As a corrective action, the licensee put administrative controls in place to ensure that the tank is drained after testing and revised its surveillance test procedures.

On August 27, 2009, following maintenance on SLC pump B, operators filled the SLC test tank to perform a test. The test was aborted when the pump failed to start. The test tank was drained and normal system lineup was restored.

On August 28, 2009, NRC inspectors observed 3 to 5 inches of water in the test tank and informed the licensee.

The licensee declared both trains of SLC inoperable and entered an 8-hour action statement for the associated limiting condition for operation (LCO). The licensee determined that the two valves used to fill the test tank for the SLC pump operability test were not tightly closed, allowing slow leakage into the test tank. The licensee closed the two valves and drained the test tank to exit the action statement for the LCO. The as-found condition was evaluated and it was determined IN 2012-01 Page 3 of 5 that the amount of water present would not have caused a failure of the tank with a design basis seismic 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 Bend Station, dated March 11, 2009, ADAMS Accession No. ML090760981 NRC, "River Bend Station-NRC Integrated Inspection Report 05000458/2009002," dated May 8, 2009, ADAMS Accession No. ML091280577 NRC, "River Bend Station-NRC Integrated Inspection Report 05000458/2009004," dated November 12, 2009, ADAMS Accession No. ML093160691 Shearon Harris Nuclear Power Plant On May 24, 2010, the refueling water storage tank (RWST) at Shearon Harris Nuclear Power Plant was aligned to the nonseismic fuel pool purification system (FPPS), causing the RWST to be made inoperable.

The RWST is a safety-related system that is seismically qualified and described in TS. The FPPS is a nonsafety-related, nonseismic system that can be cross-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 the RWST 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 to manually close the open boundary valve and incorrectly concluded that this compensatory measure would maintain the RWST operable.

NRC inspectors determined that opening the boundary valve while the plant was operating in Modes 1 through 4 would make the RWST inoperable 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 for its 10 CFR 50.59 evaluations.

It determined that the FPPS procedure change resulted in a deviation from General Design Criterion 2, "Design Bases for Protection against Natural Phenomena," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, which requires prior NRC approval to perform the activity.

The licensee's corrective actions include changing the FPPS procedure to remove the capability to purify the RWST in Modes 1 through 4 and clarifying its procedural guidance for 10 CFR 50.59 evaluations regarding the impact of proposed activities on the design and licensing basis.The following documents contain additional information on these issues at Shearon Harris Nuclear Power Plant: Progress Energy, "Licensee Event Report 50-400/2010-003-00," Shearon Harris Nuclear Power Plant, dated November 15, 2010, ADAMS Accession No. ML1 03270052 NRC, "Shearon Harris Nuclear Power Plant-NRC Integrated Inspection Report 05000400/2010005," dated January 28, 2011, ADAMS Accession No. ML110280469 IN 2012-01 Page 4 of 5 A description of other plants that have also had seismic-related issues involving the SLC or RWST is available at ADAMS Accession No. ML1 1292A190.BACKGROUND Recent events have increased industry focus on the potential impact of seismic events. These include the earthquake and tsunami in Japan on March 11, 2011, that affected the Fukushima Dai-ichi nuclear plant and the U.S. earthquake near the North Anna Power Station site on August 23, 2011 (Event Notice 47201). On September 1, 2011, the NRC issued, in the Federal Register, "Draft Generic Letter 2011-XX: Seismic Risk Evaluations for Operating Reactors" (ADAMS Accession No. ML1 11710783), to solicit public comment on the potential NRC request that licensees reevaluate their vulnerability to seismic events.Lists of recent NRC generic communications, inspection findings, and licensee event reports related to seismic issues are available at ADAMS Accession Nos. ML1 1292A191, ML1 1292A1 92, and ML1 1292A1 97, respectively.

DISCUSSION This IN provides examples and references to events in which licensees failed to recognize various seismic considerations and system alignment issues that could impact safety. The NRC staff has identified recent concerns about SLC test tanks that were not seismically qualified when they contained water. This operating experience may apply to other tanks found on site at nuclear plants. The NRC identified other examples in which licensees failed to recognize that aligning nonseismic piping to the RWST would require TS LCO action statement entry, system modifications, or license amendments.

The SLC test tanks described in this IN were not safety-related but those at River Bend Station were required to be seismically qualified because they could potentially impact nearby safety-related equipment during a seismic event. Incorrect seismic structural analyses or inadequately reviewed procedure changes led to licensees using tanks, such as the SLC test tanks, in a manner that left them vulnerable to seismic hazards. Operating experience indicates that it is important to verify that the SLC system test tanks and similar tanks have adequate seismic analysis and are procedurally controlled to ensure that seismic vulnerabilities are appropriately 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 licensing basis. 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 the technical specifications until the condition can be met." Intentionally aligning the seismically qualified RWST piping to the nonseismic FPPS piping by opening a boundary valve, immediately calls into question the full seismic qualification and, subsequently, the operability of the RWST system. LCO 3.0.2 requires that upon discovery of a failure to meet an LCO, the required actions of the associated conditions must be met. If a boundary valve is discovered to be open when it must be closed to support RWST operability, then the RWST is inoperable; TS for 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 not limited to, performance of surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

However, TS would not allow applying compensatory IN 2012-01 Page 5 of 5 measures, such as manual actions in place of the closed boundary valve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expressly permit operation under such measures or the licensee can demonstrate that the RWST still meets the TS definition of operability without reliance on compensatory measures.

In the case of the RWST alignment to the FPPS, the TS for the RWST specified no such allowance, and the licensee had not demonstrated RWST operability with the FPPS boundary valve open.Licensees should exercise caution when considering the use of compensatory measures for planned maintenance activities.

Applying compensatory measures for TS required equipment in lieu of meeting the requirements of the LCO could constitute a change to the TS, which is prohibited by 10 CFR 50.59(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," does allow 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.

The NRC expects recipients to review the information in this notice for applicability to their facilities and consider actions, as appropriate, to avoid similar seismic concerns at their sites.CONTACT This IN requires no specific action or written response.

Please direct any questions about this matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.RA/ by JLuehman for RA/ by SBahadur for Laura A. Dudes, Director Timothy J. McGinty, Director Division of Construction Inspection Division of Policy and Rulemaking and Operational Programs Office of Nuclear Reactor Regulation Office of New Reactors Technical Contact: Mark King, NRR 301-415-1150 E-mail: Mark.Kinqa-nrc..ov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.qov, under NRC Library/Document Collections/Generic Communications.

IN 2012-01 Page 5 of 5 measures, such as manual actions in place of the closed boundary valve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expressly permit operation under such measures or the licensee can demonstrate that the RWST still meets the TS definition of operability without reliance on compensatory measures.

In the case of the RWST alignment to the FPPS, the TS for the RWST specified no such allowance, and the licensee had not demonstrated RWST operability with the FPPS boundary valve open.Licensees should exercise caution when considering the use of compensatory measures for planned maintenance activities.

Applying compensatory measures for TS required equipment in lieu of meeting the requirements of the LCO could constitute a change to the TS, which is prohibited by 10 CFR 50.59(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," does allow 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.

The NRC expects recipients to review the information in this notice for applicability to their facilities and consider actions, as appropriate, to avoid similar seismic concerns at their sites.CONTACT This IN requires no specific action or written response.

Please direct any questions about this matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.IRA/ by JLuehman for Laura A. Dudes, Director Division of Construction Inspection and Operational Programs Office of New Reactors IRA/ by SBahadur for Timothy J. McGinty, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Technical Contact: Mark King, NRR 301-415-1150 E-mail: Mark.Kinqp(nrc..ov Note: 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 email OFFICE NRR/DIRS/IOEB Tech Editor BC:NRR/DIRS/IOEB BC:RIII/DRP/BR2 NAME MKing* JDougherty*

JThorp NShah for KRiemer*DATE 12/19/11 12/21/11 12/21/11 12/19/11 OFFICE D:NRR/DIRS BC: NRO/DSRA/SBPA BC:NRR/DSS/STSB BC:NRR/DE/EMCB NAME FBrown EMcKenna*

REIliott*

MMurphy*DATE 12/22/11 1/6/12 1/20/12 116/12 OFFICE LA:NRR/DPR/PGCB PM:NRRPDPR/PGCB BC:NRR/DPR/PGCB LA:NRR/DPR/PGCB NAME CHawes BPurnell KMorganButler CHawes DATE 1/9/12 1/9/12 1/20/12 1/23/12 OFFICE D:NRO/DCIP D:NRR/DPR NAME LDudes (JLuehman for) TMcGinty (SBahadur for)DATE 1/25/12 1/26/12 OFFICIAL RECORD COPY Attachment Header Document Name: luntitled Document Location FSubresponse Descrption Attach Title: ISP-LIC-03-02 Entergy Interoffice Correspondence March 4, 2003 SP-LIC-03-02 MEMORANDUM TO: G. O'Donnell FROM: S. Prussman

SUBJECT:

Reissue SP-LIC-03-01 With Supplemental Guidance On Dedicated Operator for CR-IP3-2003-308, CA-3: NRC Guidance on Use of Operator Action

References:

1. NRC Generic Letter NO. 91-18, Revision 1: Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and 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 Technical Specifications," May 6, 1991.4. NRC Information Notice 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response 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 a containment isolation valve. This memo is a reissuance of SP-LIC-03-01 issued to provide Operations with a summary of NRC guidance on the use of operator action and to apply that guidance to the current SOP controls.

This memo revises the prior memo to provide guidance on"dedicated operator." NRC GUIDANCE References I to 4 provide an overview of NRC guidance for manual action. The need for manual action can arise in a number of contexts (e.g. to support a surveillance test, to support a temporary system configuration during maintenance or to address a degraded or non-conforming condition).

The NRC guidance was written primarily for use of manual action when degraded/non-conforming conditions are not accepted as is (e.g., manual testing of boron versus N32 shutdown indication for TRM) but are also applicable to other cases such as temporary operation 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, RWST purification).

Degraded / Non-conforming Conditions The NRC guidance (Reference

1) for degraded/non-conforming conditions references the Manual Chapter (Reference

2) guidance for determining operability.

In that document is guidance on manual actions for determining operability as follows:

SP-LIC-03-01 Page 2 of 4 The first step in assessing the use of manual action is to define the significance of that action considering:

1. It is not appropriate to take credit for manual action in place of automatic action for protection of safety limits to consider equipment operable.2. It is not expected that many determinations of operability for safety related equipment will be successful for manual action in place of automatic action since credit for manual initiation to mitigate the consequences of design basis accidents should have been established as part of the licensing review of a plant.3. Manual action by a dedicated operator has been credited in the TS to close normally isolated containment isolation valves that are opened (Reference 3).This was considered acceptable under administrative controls when the capability of the operator to perform had to be assessed under guidelines similar to those identified below. The operator action is credited for rendering a 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 a full consideration of all pertinent differences." Written procedures could include actions that are part of a maintenance package that qualify as administrative controls.

The pertinent differences must focus on the physical differences between manual and operator action and must include, but not be limited to (adds guidance of Reference 3): 1. The scope of the activity (specific actions required) and the licensed conditions (e.g., after an earthquake, after a LOCA, etc) with their consequences under which it must be performed, 2. the ability to recognize input signals for action (includes operator recognition and control room recognition), 3. ready access to or recognition, of setpoints, design nuances that may complicate subsequent manual operation such as auto-reset, repositioning on temperature or pressure, 4. timing required for automatic action (include the ability and timing in getting to the area if not stationed and the ingress /egress paths, use ANS 58.1 for operator 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 manual action 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 dedicated operator but credible errors for non-dedicated operator) and effects, and 10. identification of support personnel and/or equipment required.The guidelines used for operability can also be used for inoperable equipment where credit is to be taken for compensating action. Equipment not in TS that is inoperable does not require plant shutdown 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 has failed. Manual action is acceptable in these situations.

The guidelines used above should be SP-LIC-03-01 Page 3 of 4 followed except that requirements for dedicated operators and single failure are not required where adequately justified.

This justification must be approved using the 50.59 process and recognize that the TS bases say dedicated operator.

For purposes of the TS bases, dedicated operator is an operator who has been set aside for the purpose of the sole purpose of performing the manual action. A non-dedicated operator is one who has other functions.

Analysis can show that there is sufficient time for the operator to perform the manual action based on procedural requirements or CR direction but the single failure must be taken as noted above. A recent example is the Unit 3 loss of N32 source range used for Appendix R. The use of manual action to assess shutdown by taking boron samples was contemplated as a compensating action until the N32 was fixed. This would have been justified as not requiring a dedicated operator but the availability of trained personnel in a timely manner and a procedure would be necessary.

A 50.59 is required for compensating actions but the purpose is to verify that the compensating action did not impact other aspects of the facility as described in the FSAR.Temporary Operation of a System in a Condition it was Designed For As we have discovered during the course of operation, systems that were designed for operations in 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 is acceptable for this case for evaluation the change. One such case was the purification loop used for cleaning the RWST. That loop was non-seismic and did not have redundant and automatic isolation valves. Safety Evaluation 99-3-035 SFPC was written to allow operation of the purification loop using manual action to meet design criteria and the evaluation was based upon the criteria for the degraded /non-conforming conditions.

The change is a design change since a 50.59 was used for the action.Design Change Using Manual Action Design changes using manual action are generally considered unacceptable to the NRC staff unless they have reviewed and approved them. This does not mean all such changes are unacceptable as described previously.

Reference 4 presents a number of instances where the NRC has found such modifications unacceptable.

For example, operator action was credited to isolate nonessential SWS loads and to give the operator time to complete the action the evaluators assumed that the non-seismic intake canal would not fail for an hour. There are other examples that should be considered when taking this action.APPLICABILITY TO SOP-CVCS-002 The guidance above for the preparation of a change to SOP-CVCS-002 would indicate that the procedural 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 is not an auto closure valve since charging may be in use so the timing of the CR directive must be assessed based on system need and operator ability to perform the function)Input signal for action -CR notification Affects 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 the operator to complete it (e.g., most CIV require immediate closure so the operator is dedicated and nearby whereas the charging closure is required when system will not be used). In this case SP-LIC-03-01 Page 4 of 4 a non-dedicated operator may be practical.

To use a non-dedicated operator, it must be shown that the procedure would direct the CR to have the operator close the valve, that here is sufficient time to close the valve (e.g., operator closes consistent with design function and before environment precludes operation), and that single failure would be acceptable.

Note that here the need 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 automatic actuation 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 operator can perform the action (e.g., our design criteria is GDC 19 dose limits for operation of manual containment isolation valves and this should have been assessed).

The flashlight requirement indicates some consideration of this.Single failure -Historically we have said no single failure of a dedicated operator (presumption is that this is the only task and therefore error likelihood much lower) while a single failure could occur if there were a non-dedicated operator (standard design practice).

Apply based on dedicated or non-dedicated.

Support equipment

/ personnel

-here that is flashlight, radio and CR direction.

cc: J. McCann P. Rubin J. Janecky A. Williams S. Petrosi J. Ventosa J. Bubniak R. Long A. Small Entergy CORRECTIVE ACTION I CR-IP3-2012-01768 CA Number: 3 Group I Name I Assigned By: Operations Procedure Mgmt IP3 Assigned To: Operations Procedure Mgmt IP3 Subassigned To: Ballettajohn F Gander,Thomas E Originated By: Balletta,John F Performed By: Gander,Thomas E 7/3/2012 12:33:59 9/20/2012 10:14:42 Subperformed By: Approved By: Closed By: Gander,Thomas E 9/20/2012 10:14:42 Current Due Date: 09/27/2012 CA Type: ACTION Initial Due Date: 09/27/2012 CA Priority:

4 Plant Constraint:

1. NONE CA

Description:

Identify other procedures that may open valves AC-727B or SI-841 in modes 1 through 4. Revise procedures as necessary to meet the requirements of NSE 99-3-035 SFPC, Rev. I Response: 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 active procedure.

3-ONOP-SFP-1, Rev. 12 moved from the Operations G:\ drive to the History directory.

Action Complete 2. 3-PT-V055, Rev. 2 -Currently contains P&L 2.1.2 which indicates a dedicated operator is required in Modes 1 through 4 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 used during refueling.

A mode restriction was added to 3-SOP-RP-020 in revision 38 as an additional barrier to prevent performing this procedure in Modes 1 through 4. Action Complete 4. 3-SOP-SI-003, Rev. 23 -Currently contains P&L 2.1 which indicates this procedure cannot be performed in modes I through 4 until LER-2012-002-00 is resolved.

No action required Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768 CA Number: 4 Group Name Assigned By: Operations Procedure Mgmt IP3 Balletta,John F Assigned To: Operations Procedure Mgmt IP3 Gander,Thomas E Subassigned To: Originated By: Balletta,John F 7/3/2012 12:36:12 Performed By: Gander,Thomas E 7/25/2012 11:47:35 Subperformed By: Approved By: Closed By: Gander,Thomas E 7/25/2012 11:47:35 Current Due Date: 09/25/2012 Initial Due Date: 09/25/2012 CA Type: CAT C-CORRECT CA Priority:

3 Plant Constraint:

1. NONE CA

Description:

Revise 3-SOP-SFP-001, Rev. 25, to include new P&L 2.1 and CAUTIONS indicating The RWST is inoperable whenever it is connected to the purification system due to connection to non-qualified seismic piping. Sections 4.1.1 and 4.3.7 SHALL NOT 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 to the purification system due to connection to non-qualified seismic piping. Sections 4.1.1, 4.7. 1, and 4.3.7 SHALL NOT be performed in Modes 1 through 4 per LCO 3.5.4. (CR-IP3-2012-01768, CA-I)Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-IP3-2012-01768 CA Number: 5 Group, Name Assigned By: Operations Support Staff lP3 Main,Dennis E Assigned To: Operations Support Mgmt IP3 Cramer,Thomas A Subassigned To : Originated By: Zzip2crg 9/25/2012 08:25:20 Performed By: Main,Dennis E 9/28/2012 07:58:03 Subperformed By: Approved By: Closed By: Main,Dennis E 9/28/2012 07:58:03 Current Due Date: 10/04/2012 Initial Due Date: 10/04/2012 CA Type: CR CLOSURE REVIEW CA Priority:

4 Plant Constraint:

1. NONE CA

Description:

CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW THE CR IN ACCORDANCE WITH EN-LI-102, SECTION 5.10. AND THE EN-LI-102-02 CLOSURE 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 UmleUEi U Group I Name I Assigned By: Assigned To: Subassigned To: Operations Support Staff IP3 Operations Procedure Staff IP3 Main,Dennis E Balletta,John F Originated By: Main,Dennis E 9/28/2012 07:57:46 Performed By: Balletta,John F 10/12/2012 07:00: 1I Subperformed 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:

1. NONE CA

Description:

Revise 3-PT-V55 based on Licensing response to CA-2.10/17/2012 3 Response: 3-PT-V055 has been revised and approved.

It is available in MERLIN on 10/15/12.Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-1P3-2012-01768 CA Number: 7 Group I Name I Assigned By: Operations Support Staff IP3 Assigned To: Operations Support Mgmt IP3 Subassigned To: Main,Dennis E Cramer,Thomas A Originated 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: 10/24/2012 CA Type: CR CLOSURE REVIEW CA Priority:

4 Plant Constraint:

1. NONE CA

Description:

CAT-C, ALL CORRECTIVE ACTIONS ARE CLOSED FOR THIS CR, THEREFORE THIS CR MAY BE READY TO CLOSE. REVIEW THE CR IN ACCORDANCE WITH EN-LI-102, SECTION 5.10. AND THE EN-LI-102-02 CLOSURE 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-IP3-2012-03339 Originator:

De Donato,Anthony J Originator Group: P&C Eng Codes Staff IP3 Supervisor Name: Azevedo,Nelson F Discovered Date: 10/23/2012 10:04 Originator Phone: 6683 Operability Required:

N Reportability Required:

N Initiated Date: 10/23/2012 10:10 Condition

==

Description:==

During response to Incoming Letter RA-12-128 RAI Regarding Proposal to Align RWST and SFP Purification System for Unit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last IST Program (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, it has been determined that they should be added to the U3 IST Program. There are no operability issues, since the operability of these four manual valves and the one check valve has been demonstrated every two years during system usage, and the check valve is closure tested every two years.Immediate Action

Description:

Suggested Action

Description:

Assign to Codes Programs.TRENDING (For Reference Purposes Only): Trend Type HEP FACTOR AU KEYWORDS KEYWORDS INPO BINNING REPORT WEIGHT KEYWORDS Trend Code P ESPC KW-VALVE KW-IST ER4 W KW-PROGRAMMATIC DEFICIENCY Entergy ADMIN CR-IP3-2012-03339 Initiated Date: 10/23/2012 10:10 Owner Group :P&C Eng Codes Mgmt IP3 Current Contact: Current Significance:

C Closed by: Summary

Description:

During response to Incoming Letter RA-12-128 RAI Regarding Proposal to Align RWST and SFP Purification System for Unit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last IST Program (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, it has been determined that they should be added to the U3 IST Program. There are no operability issues, since the operability of these four manual valves and the one check valve has been demonstrated every two years during system usage, and the check valve is closure tested every two years.Remarks

Description:

Closure

Description:

Entergy I ASSIGNMENTS I CR-IP3-2012-03339 Version: 1 Significance Code: C Classification Code: CORRECT/ADDRESS Owner Group: P&C Eng Codes Mgmt IP3 Performed By: Harrison,Christine B Assignment

==

Description:==

10/25/2012 10:36 Entergy CORRECTIVE ACTION CR-IP3-2012-03339 CA Number: 1 Group .Name I Assigned By: P&C Eng Codes Mgmt IP3 Tesoriero,Michael V Assigned To: P&C Eng Codes Mgmt IP3 Zarrella,Joseph Subassigned To : P&C Eng Codes Staff IP3 De Donato,Anthony J Originated By: Zzip2crg 10/25/2012 13:26:21 Performed By: De Donato,Anthony J 11/9/2012 09:31:18 Subperformed By: Approved By: Closed By: De Donato,Anthony J 11/9/2012 09:31:18 Current Due Date: 11/15/2012 Initial Due Date: 11/15/2012 CA Type: DISP -CA CA Priority:

3 Plant Constraint:

NONE CA

Description:

You have been assigned as the Responsible Manager for this Category "C", Non-Significant Condition Report by the CRG Address/correct the identified condition per EN-LI- 102. Perform disposition review, investigate as needed, and ensure actions 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 for Unit 3, it was discovered that valves AC-725, AC-727A, AC-726B, AC-727B, and SI-841 were not included in the last IST Program (4th Interval) update most likely due to their limited use. However, after reviewing the function of these valves, it has been determined that they should be added to the U3 IST Program. There are no operability issues, since the operability of these four manual valves and the one check valve has been demonstrated every two years during system usage, and the check 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 satisfied and 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 been demonstrated every two years during system usage, and the check valve is closure tested every two years.Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION I CR-IP3-2012-03339 CA Number: 2 GrouD I Name I Assigned By: P&C Eng Codes Staff IP3 Assigned To: P&C Eng Codes Staff lP3 Subassigned To : De Donato,Anthony J De Donato,Anthony J I Originated By: De Donato,Anthony J Performed By: Subperformed By: Approved By: Closed By: 11/9/2012 09:29:27 Current Due Date: 01/10/2013 Initial Due Date: 01/11/2013 CA Type:. ACTION CA Priority:

4 Plant Constraint:

1. NONE CA

Description:

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 satisfied and document these requirements in the IST database.Response: Subresponse

Closure Comments: