L-2018-201, Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b

Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b

ML18316A030
Person / Time
Site:	Saint Lucie
Issue date:	11/09/2018
From:	Deboer D Florida Power & Light Co, Document Control Desk
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-201
Download: ML18316A030 (47)

Text

November 15,2018 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 St. Lucie Nuclear Plant, Units 1 and 2 Docket Nos. 50-335 and 50-389 NOV 0 9 2018 L-2018-201 CFR 50.90

Subject:

Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b"

References:

1. Florida Power & Light Company letter L-2014-242, "Application to Adopt TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B,"

December 5, 2014 (ML14353A016)

2. NRC E-mail "Request for Additional Information - St. Lucie TSTF-505 EICB - MF5372 &

MF 5373," March 28,2016 (ML16089A006)

3. NRC E-mail "Request for Additional Information - St. Lucie TSTF-505 APLA - MF5372 &

MF5373," April13, 2016 (ML16105A456)

4. NRC E-mail "Request for Additional Information-St. Lucie TSTF 505 APLA-MF5372 &

MF5373," May 27, 2016 (ML16152A187)

5. Florida Power & Light Company letter L-2016-114, "Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, 'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B,' "July 8, 2016 (ML16193A659)

6. Florida Power & Light Company letter L-2016-135, "Second Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505,

'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B,' "July 22, 2016 (ML16208A061)

7. Florida Power & Light Company letter L-2017 -007 "Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-

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.In-fr-o-c-rm~e~d-.E.,_x--,-te--n---c'ldea Completion Tunes - RITSTFTn.itiatlve 46,'" February 25, 201_,----------

(ML17058A181)

8. NRC E-mail "Request for Additional Information-St. Lucie RICT LAR-MF5372/5363,"

October 4, 2017 (ML17277A369)

9. NRC E-mail "Request for Additional Information-St. Lucie RICT LAR I&C- (CACs MF5372/MF5375 EPID L-2014-LLA-0001)," February 1, 2018 (ML18033A014)

L-2018-201 Page 2 of3

10. Florida Power & Light Company letter 2018-006, "Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,'" February 1, 2018 (ML18032A614)

11. Florida Power & Light Company letter L-2018-058, "Fourth Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,'" March 15,2018 (ML18074A116)

12. Florida Power & Light Company letter L-2018-111, "Second Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1,

'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,' "June 7, 2018 (ML18158A228)

13. Florida Power & Light Company letter L-2018-150, "Third Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1,

'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,'" September 18, 2018 (ML18261A354)

In Reference 1, as supplemented by References 5, 6, 7, 10, 11, 12, and 13, Florida Power & Light Company (FPL) submitted a license amendment request (LAR) for St. Lucie Units 1 and 2. The proposed amendment would revise the Technical Specifications (TS) to implement TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times RITSTF [Risk Informed TSTF]

Initiative 4b."

This letter supplements the LAR by identifying two additional items related to PRA open facts and observations (F&Os) that must complete to support implementation of the Risk Informed Completion Time Program. Attachment 1 in Reference 13 provided a table of open finding level F&Os and identified four PRA model changes that must occur to support implementation of the Risk Informed Completion Time Program. Attachment 1 to this supplement provides a revised table of open F&Os that includes the two additional implementation items and supersedes in Reference 13. Similarly, Attachments 2 and 3 provide a revised license condition for Unit 1 and Unit 2, respectively, that incorporates these implementation items and supersedes the license condition previously proposed in Reference 13. contains a revised markup ofTS 3.6.1.3, "Containment Air Locks," for Unit 2, which contains an editorial correction to change the second occurrence of air lock in Action b to its plural form, air lock( s). This markup supersedes the corresponding markup in Reference 7.

This supplement does not alter the conclusions in Reference 1 that the changes do not involve a

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environmental impacts associated with the changes.

No new or revised commitments are included in this letter Should you have any questions regarding this submittal, please contact Mr. Michael Snyder, Licensing Manager, at (772) 467-7036.

I declare under penalty of perjury that the foregoing is tme and correct.

Sincerely, Daniel DeBoer Site Director Florida Power & Light Company Attachments cc:

NRC Regional Administrator, Region II NRC Senior Resident Inspector NRC Project Manager Ms. Cindy Becker, Florida Department of Health L-2018-201 Page 3 of3

L-2018-201 Page 1 of36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments Internal Events PRA Model Findings AS-04 AS-A5 RWTirupture is assumed to fail This finding was reviewed and This F&O is confusing and needs The current model does not support shutdown cooling. This seems closed with no further action.

to be interpreted. The F&O talks the finding that RWT is required to overlj conservative. Without This scenario was reviewed to be about SOC when it is implied that establish SOC. Charging pumps take makdup the level in the RCS contrary to current plant practices cooldown is being reviewed.

suction from BAMTs and not VCT waul drop, but there is more Since this is a C-E designed which is isolated on SIAS (CVCS than ~nough fluid in the Boric and EOPs. Use of RWT and plant, there is a separate pump letdown and VCT are only required Acid t anks and the VCT to BAMTs are required when RCS for HPSI and charging. The during operation). If the RCS level re'tl thl' level. The level do"'

needs makeup due to shrinkage source for the charging pump at drops, for any reason, eves has not n ed to be fully restored to following Rx trip. The reviewer PSL is the VCT which can be fed enough inventory to makeup at a allow shutdown cooling. The assumes that Ops will continue to from either the boric acid makeup reduced RCS inventory level, even level eed only be above the hot SOC, even in case if RWT rupture tank or the RWT. So failure of before reaching the level for top of the leg.

were to occur during makeup to the the RWT would not fail charging Hot Leg. SITs will be dumped at 250#

point where RCS cooling continues to makeup during cooldown.

in U1 and 600# for U2, which are Esti~ated Level Drop 2250 psia at a rate of 1 OOF /hr, and RCS level However, further review also setpoints above the interlocks for at 601 F (0.0217 ftA3flbm) to 100 drops down to about mid loop level.

found gate M1BORATN02 where SOC, restoring the full level of RCS psia t 300F (0.01766 ftA3flbm).

EOP-02, step 4.5 prevent against failure of the RWT would fail and allowing entry into SOC if needed Giver RCS liquid volume of this behavior by requiring that OP emergency boration. The gate at 235#. The referenced logic 1 0,4C 0 ftA3, this means ensure RCS inventory control is M1BORATN02 is an "OR" gate.

correction is made into the current apprc ximately 18,500 gallons maintained, and PZR level is This gate needs to be changed to working model which will be revised are rE quired to restore the PRZ restored between 30% to 35%.

"AND" the suction sources. This prior to use for RICT calculations. The level. Each Boric Acid Tank SOC will not continue until PZR F&O remains open pending model change may have favorable contains 9700 gallons the VCT level is restored. The concerned correction of this logic error.

impact on RlCT calculations impacting contains 4000 gallons. Fully PRZ scenario is perceived as not Charging System.

level s not required full credible.

Comments shutd own cooling when core The resolution of this F&O in the

1. lmg}ementation Item:

dam<: ge is the alternative.

GDOC should be revised to Model revision and associated address the loss of the RWT documentation are an implementation during plant cooldown.

item.

AS-06 AS-A3 Con{dec adding low P'""re This finding has been resolved and There is no documentation to The current working model for Unit 1 feed using Condensate pumps) considered closed.

support the resolution to close was revised to credit Low Pressure to th model for accident Total Loss of MFW/AFW is about without any further actions. The Feed to S/Gs. The change favorably sequ nces involving Joss of all 3% of CDF. Addinq this credit will accident sequence notebook impacts RICT calculations associated I

L-2018-201 Page 2 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments MF1AFW.

require developing new HRA that should include a brief discussion with only small portion scenarios Usin condensate pumps to feed would counter-affect its benefit and as to why the condensate feed associated with Total Loss of Feed will not significantly change the capability was conservatively not and does not significantly impact the S~'s is in both EOP 6 'Total conclusion. Therefore, credit of low credited. This F&O is considered overall CDF/LERF scenarios. The Loss Ef Feed' and EOP-15 pressure feed is considered with to still be open.

current working model will be revised

'F""f"a' Reoove"'

neutral benefit and will not be prior to use for RICT calculations.

Proc dure'. Operations is added to the model at this time.

direc ed to use low pressure

2. lme.fementation Item:

feed 1n 1-EOP-06 (Step 8.8.3.1).

Model revision and associated Credi ing low-pressure feed will elimi ate those core damage documentation are an implementation sequ nces where the MFW item.

pum~ s are lost, but the cond nsate pumps are available.

If the TBVs are not available, then he hot well make-up contr Dl system (or an operation actio ) must be modeled to in cor orate this alternative.

Addir g LPF could reduce depe rdency on Once Through Cooli rg for a number of accident sequ nces.

(See F&O AS-03 also)

AS-08 AS-AS Ch~ Valve;, 09294 and 09252 Data analysis and CCF analysis Document PSL-1 FJR-03-009 was This is a documentation issue.

are c mmon for both AFW, have been updated numerous reviewed. There is no Clarification to existing documents is MF

, and Low Pressure Feed.

times since the development of this documentation of the logic required to close this finding. There is Thes CKVs currently appear F&O. CCF module FMM1 SGCVL V changes made to resolve this no impact to RICT calculations.

only i the AFW system. The was added under gates F&O in the referenced may ~e some events (e.g. LOL)

F1SG1APATH, F1SG1BPATH, calculation. It is unclear which wher the turbine trips and F1SG1APATH-<4, and check valve CCF combinations ste] genecatoc P""'""' rtses F1SG1BPATH-<4. Added events are appropriate to consider. The enou h to cause the closure of FCVN 109252 under gates fault tree was reviewed and a thes check valves. Under these F1SG1APATH and F1SG1APATH-CCF module was added to the seen rios, the failure of both of

<4. Added events FCVN109294 model in the common cause thes checks would fail all underqates F1SG1BPATH and

_gates. This F&O is considered to

L-2018-201 Page 3 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments seco1dary side heat removal.

F1SG1BPATH-<4 Implemented still be open.

Currently, these CKVs are in current update (Calc PSL-1 FJR-mode led under FMM1SGCVLV.03-009, Rev 0).

This vent has a failure prob~ bility far lower than several three element CKV groups in the AFW system. There does not appe r to be a basis for this differ nee. The failure likelihoods (in de ' en dent and common cause ) of the check valves in the AFW system should be consi stent or the basis for the differ nee is documented.

Furth er, as the random failure of these CKVs could cause a LOF\\1 ~trip and eliminate all secorndary side feed to a single S/G, his is worthy of consi ~eration as an initiating even.

AS-12 AS-A5 Curre ntly, shutdown cooling is This finding was reviewed and The response for resolution is credi ed as a long-term cooling closed with no further action.

inadequate. The LOCA for which

3. lme_/ementation Item:

meth d to eliminate the re-SOC is used needs circul ~tion requirement on To enter SOC during the course of documentation that the RWST is Finding AS-12 will be closed in certa in ranges of LOCA breaks.

mitigating a LOCA, an RCS level of still available for makeup. If the accordance with Appendix X to NEI Acer ain amount of water must 30% in the Pressurizer is required RWST is depleted, then the only 05-04, NEI 07-12 and NEI12-13, be at ove the bottom of the hot by EOP-3. Further, once SOC has other source for water for long "Close-out of Facts and leg to~ avoid drawing vapor into been entered AOP-03-02 requires term cooling would be the Observations."

the s utdown cooling system.

OTC to be re-established if RCS containment sumps. The level falls below 29 feet 9.5 inches SomE calculation must be done (Top of Hot Leg). Operation of SOC containment sumps can only to en ure that the RCS will be supply water via recirculation.

abov this critical point.

in the above referenced condition The AS notebook should is procedurally not allowed and document the basis for the range This alculation could be quite physically not possible. Therefore of LOCA sizes that can credit simp! a: determine the RCS water the question is highly hypothetical SOC for long-term cooling. This level at the point of shutdown and not applicable at PSL.

F&O is considered to still be

L-2018-201 Page 4 of36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments coolir g entry conditions, open, pending incorporation of deter nine the leakage rate at the documentation.

point, verify the RCS level will be adeq ate for the remaining part of the 24 hr mission without re-circul 3tion or RCS make-up.

If this is not true, then addition make up must be modeled throu' h the emergency sump or eve~.

AS-13 AS-A2 The rRV' ace ooly a""med to This finding has been resolved and The PRA model fault tree was The current working model is revised lift gi en total loss of secondary closed by an update to the reviewed. It was confirmed that to increase fidelity and level of details side eat removal or a loss of model/documentation.

several other initiators other than associated with anticipatory trip load ith no anticipatory trip.

It is not true that the model loss of load and loss of offsite function. There is no impact on RICT This ppears non-conservative.

considers only the assumed power would cause the PORVs to calculation. The current working model The nly loss of load trips scenario. There are other lift. This was determined by will be revised prior to use for RICT

"'"~eced ace TT aod I<= of scenarios that were considered to reviewing the logic under gate calculations.

off-sit power trips. This is based challenge the PORVs. See logic U 1 QT03 and the A TWS logic on an informal calculation that under gate U1 QT03. Input on trips (U1P01). However, the use of a

4. lmeJementation Item:

shows the RCS pressure likely to challenge PORVs were single event ('NLCD1TURB') for Model revision and associated excejds 2300 psia, but stays received from fuels group and the anticipatory trip function was bela 1 the PORV open set point incorporated throughout the model not addressed. No documentation are an implementation of 24([)0 psi a. This does not update process.

documentation for the basis for item.

consi~er variations in the time this event is included in the delay between the turbine trip notebook. Until the anticipatory aod 'r ceactoctrip ooc doe' If trip is modeled in more detail or consi er variations in the PRZ further documentation of the press re set point. Consideration basis for a single event is of thefe variables may lead the provided, this F&O is considered analy t to conclude that the to be open.

likelihood of a PORV lift during fhl' tdltioo ;, m"ch lacgec thao analy ed.

Furth r, the portion of the tree (und~r Gate U1 QT99) that models the circuitry associated with tlhe anticipatory trip only

L-2018-201 Page 5 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments contams a single basic event. No other support system depe dencies appear. For exam pie, does the status of press urizer spray affect this calcu ation? Are there support syste tn failures that could cause a losl of load and disable or deg~tte the anticipatory trip functi n?

DA-C14-DA-C14 It ap~ears that the treatment of This finding was reviewed and Table (A-1) in PSL-BFJR-06-008 This is a documentation issue.

01 oo;n~:ent "navaUabWty foe ;ntec-closed with no further action.

Rev.5 provides justification for Clarification to existing documents is syste s was considered.

This SR requires "EXAMINING" lack of inter-system unavailability.

required to close this finding. There is How ver, there was no clear There are some non-staggered no impact to RICT calculations.

docu ~ entation to demonstrate coincident unavailability due to tasks which could be done at the such reatment.

maintenance for redundant same time so it looks like there equipment (both intrasystem and are some inter-system Caine ident unavailability due to intersystem) that is a result of a maintenance which could be main enance for different trains planned, repetitive activity based done at the same time. Non-of the same system (intra-on actual plant experience. The staggered tasks are also syste tn) is not allowed by key words here are "PLANNED" identified in Table (2) of the same established plant procedures.

and "REPETITIVE". At PSL, there report.

Ther fore, the calculation of is no coincident unavailability of coin~tdent unavailabilities for "PLANNED" and "REPETITIVE" However, the resolution should intra-ystems as a result of maintenance for redundant point to the administrative planrd and repetitive activities equipment (both intrasystem and procedures that preclude such was ot calculated. There was intersystem) to be allowed, per coincident unavailability. Further, no cl ar documentation on the plant T/S, procedure, guidelines, the discussions referred to in the tceatrnt of oo;nddent and instructions.

GDOC Description should be unav ilability for inter-systems.

documented somewhere in the Disc ssion with the utility PRA actual data notebook. This F&O staff i dicated that review of the should remain open.

plant operating history was performed to identify potential co inc dent unavailability for inter-syste s. No such unavailabilities were identified. The PRA staff also-J~monstrated that the PRA

L-2018-201 Page 6 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments model accounts for coincident unav!ilability for inter-systems by th use of appropriate mutu lly exclusive logic.

HR HR-01 Som~ inconsistencies have been Resolved per PSL-BFJR-08-003, For pre-initiator HEPs, PSL-This is a documentation issue.

01 identired between the Rev 1, and PSL-BFJR-17-029 Rev BFJR-08-003, Revision 1 was Clarification to existing documents is docurentation, the HRA

0.

reviewed along with the PSL required to close this finding. There is calcu ator file and the CAFTA GDOC draft revision (rev. 1) that no impact to RICT calculations.

modr one example,,

provides the updated closure AHF 1 CSTIV, which is indicated basis for this finding. A spot-as 2. E-5 in the summary table check of the Unit 1 and 2 pre-3.0 w ile appears to have the initiator mean values identified in floor alue from ASEP in the Tables 19 and 20 of document HRA ~alculator file (i.e., 1 E-5) 08-003-Rev.1 were checked (See &0 HR-01-01).

against the CAFTA.rr basic Amo e conservative value has events for consistency. All basic benE ntered in the model, with event values input to the CAFTA model were found to be respe ct of what the H RA consistent.

calcu ator provides.

For post-initiator HEPs, PSL-BFJR-15-014, the RR file and the recovery file were reviewed. For these HEPs, there were still inconsistencies. This F&O is considered to still be open.

Comments It was noted that there were inconsistencies between the HRA calculator and the PRA notebook for post initiators: LHFPMANUAL AND NHFPMANUALS on both units. These should be corrected.

L-2018-201 Page 7 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments At best the documentation process for revising the PSL Model Update Reports is confusing. The revisions of these reports are stand-alone documents and the information is not carried fo!Ward in successive revisions. The process of updating the associated PRA documents rather than identifying changes only in the model update document should be improved.

HR-12-01 HR-12 This :>R is associated with the The latest revision of HRA analysis Documents PSL-BFJR-11-013 This is a documentation issue.

docu nentation of the process included use of revised and PSL-BFJR-17-029 were Clarification to existing documents is used o identify, characterize, dependency analysis methodology reviewed. In document PSL-required to close this finding. There is and c uantify the pre-initiator, that ensured generation HEP BFJR-11-013, Section 3.2 and no impact to RICT calculations.

post-initiator, and recovery combinations consistent with Appendix E, the methodology for actio Is considered in the PRA dependencies between HFEs that the dependency analysis is

'"]"'!he loputs, method' are considered in HRA Calculator.

discussed, how the joint HEP and r suits. Although the overall The HRA Analysis document floor was applied, and how HRA nalysis looks very good, included detailed steps taken to unanalyzed combinations were the crrent documentation for generate the revised dependency identified and treated. In the d pendency analysis and analysis. Resolved in PSL-BFJR-document PSL-BFJR-17-029, trea1eot of P"'t-loltiatm HR!\\,11-013 Rev4.

section 7.0, the methodology for is inc mplete. The current the dependency analysis is docu entation only states that discussed. Since PSL-BFJR all po t-initiator HEPs are set to 013 is not signed this F&O is 1.0 al d then fed into the HRA considered open. When the calcu ator to determine the document is signed and approved depefeocy betweeo the HEP the F&O can be closed.

even s. There is no discussion of Comments how t e rest of the process is The performance of the perfo~ed, including how the dependency analysis may not HRA ecovery File is used to conform to the industry accepted

L-2018-201 Page 8 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments "res~" combination events to the practice (EPRI HRA calculator appr priate values based on the manual Chapter 17). The values depe~dency analysis, no for each HFE should be set at a discu sion on why the HEP value as close to 1 as possible valut in the BE file are set to (typically 0.99) so that the most 0.5, o discussion of how the HFE combinations possible are HRAJalculators dependency capture in the cutsets produced at anal Fis was validated, etc.

the truncation level of the model Additionally, there is no being analyzed.

assu~ance that all HEP The PSL dependency analysis comt inations have been used 0.5 as the value for HFEs.

identi ied and evaluated - see This would be acceptable if the F&O HR-G6-01 for more detail.

number of cutsets produced at 0.99 was beyond the capacity of the software but not to reduce the number of to prevent a perceived problem in the software.

HR-13-01 HR-13 Ther; is no discussion on model This finding has been resolved and Documents PSL-BFJR-11-013 This is a documentation issue.

relat d uncertainties for pre-closed by an update to the and PSL-BFJR-17-029 were Clarification to existing documents is initiarr HRA calculations. For model/documentation.

reviewed. In document PSL-required to close this finding. There is post-nitiator HFE, the EF Pre-initiator and post-initiator HFE BFJR-11-013, Section 3.3 the no impact to RICT calculations.

indic ted in Table 9 are then not EFs were added to CAFTA RR-file uncertainty analysis is discussed.

propJgated in the CAFTA file. It so UNCERT can use them in the This provides the basis for the EF is thet'efore not clear how the uncertainty calculations.

section and application and also uncernty pacameteffi ace Discussion of HRA EF provides high-level sources of treat d in the model.

uncertainties is provided in the PSL uncertainties and assumptions applied to the HRA. This section A co plete uncertainty HRA analysis document Resolved was reviewed and provides asse sment involves both in PSL-BFJR-11-013 Rev4.

reasonable development of the stochastic uncertainties (inclufed in the HRA calculator)

EFs that have been applied in the CAFTA.rr file. The CAFTA.rr file

L-2018-201 Page 9 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments and E pistemic (model) was spot-checked for application unce ainties. A discussion on of EFs, which appear to be the a sumptions made in the consistently applied. No issued analy sis and their potential for identified during the review. In impa, ton the HEP calculations addition, the process to document is rec uired to meet the SR.

sources of model uncertainty and The i ~consistency between the related assumptions is consistent with SR HR-13 and HR-06 for EFdi kussed in the post-initiator assessment of uncertainty in the HRA notebook (table 9 in HEPs.

Secti bn 3.3) and the actual CAF A file does not allow a In document PSL-BFJR-17-029, corre t uncertainty analysis.

which is still in draft form, there is TablE 9 states that generic Error no discussion of uncertainty. The Factc rs are used, but there are assumptions are included as part no er or factors in the BE file, so of the HRA Calculator it is u nclear how the error factors documentation. The SR requires are p opagated. Also, the uncertainty to be addressed. This Com ' ination events, and the F&O is considered to still be renar ned post-initiator single open.

events are not included in the BE file sJ it is unclear how their error facto s are included in the anal~sis - or if they are even consifered.

IE-C6-01 IE-C6 A scr eening approach is utilized This finding was resolved by PSL documents PSL-BFJR This is a documentation issue.

for sc me lines based on low analysis update document 014, Rev 2 and RSC 14-05 were Clarification to existing documents is frequ ency but this is not developed by RSC (document RSC reviewed. The RSC document required to close this finding. There is quan ified. The SR indicates a 14-05 Rev 0). See also Calc PSL-references the original PSL no impact to RICT calculations.

frequ ency expectation for BFJR-15-014, Rev 2 ISLOCA document PSL-BFJR-scree ning.

07-06, which included screening Defin e the estimate for the lines of penetrations based on perceived low frequency. Section

L-2018-201 Page 10 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments scree ned on low frequency and 2.1 of the RSC report says, "The show that the calculated scope of the modeling change frequ 3ncy supports screening.

was limited to the development of the specific scenarios defined by the existing study. The screening process was not revised and the data utilized is the same as for the existing study." Based on this, previous screening of penetrations has not been superseded and there is no evidence that a quantitative basis has been provided to support the screening as required by the SR.

This F&O should remain open.

IE-C9-01 IE-C9 The f ult tree model used for the This finding was resolved by PSL document RSC 14-05, "Inter-This is a documentation issue.

ISLO "":,A paths assumes that the analysis update document Systems LOCA Update", was Clarification to existing documents is statu of all valves is known developed by RSC (document RSC reviewed. The RSC document required to close this finding. There is when the plant is brought online 14-05 Rev 0). See also Calc PSL-models appears to adequately no impact to RICT calculations.

and t e corresponding exposure BFJR-15-014, Rev 2 account for the status of each time i ~the refueling inteNal.

isolation valve when estimating Ho1e', ba'ed oo d;""";oo' the ISLOCA frequency. However, with nowledgeable staff, there PSL-BFJR-15-014 Rev. 2 does is no ositive means to know not include evidence that the that ore than one isolation quantitative screening criteria was valve is actually holding. Use of addressed in this document.

statu lights is not definitive Therefore this F&O is considered since there is a +/-5% margin to still be open, pending betwE en light changing and reconciliation of the PRA valve seating. The exposure time documentation to reflect the shoul 8 be based on a positive changes made to the model.

flowt ~st which may not occur on

L-2018-201 Page 11 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments a refl eling basis but based on other studies could be as much as th life of the plant.

QU-02 AS-C3 A lotf results sections in the This finding has been resolved and The F&O concerned the presence This is a documentation issue.

quan ification report are blank closed by an update to the of incomplete sections in the PSL Clarification to existing documents is with "later in place of the table model/documentation.

quantification notebook. The required to close this finding. There is or re1 ults.

The current PRA Update F&O cites AS-C3 and DA-E3, no impact to RICT calculations.

documents included final results which particularly pertain to the and completed analysis. Calc documentation of sources of PSL-BFJR-15-014, latest Rev.

model uncertainty. The current QA notebook (PSL-SNBK-QU, Revision 0) is complete and includes reference to the Uncertainty notebook, which includes discussion of sources of uncertainty. However, the QU notebook documents the results as of 2012. Since that time, subsequent updates have included only a summary set of quantification results in a "PRA update report". The CDF appears to have reduced significantly, for example. There is no justification as to why the previous QU notebook results remain valid.

Since an updated QU notebook (including all of the risk results reporting required by the QU

L-2018-201 Page 12 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments SRs) does not exist for the current PRA, this F&O is considered to still be open.

Comments Although the 2012 QU notebook attempts to address all of the QU documentation requirements, some of the required evaluations (e.g., Sections 7.1, "Significant Accident Sequence Review", 7.2, "Importance Measures Review and Comparison", and 7.5, "Non-Significant Accident Sequence Review") are addressed using only summary discussions that don't provide any details as to the methods used, what was reviewed, etc. Additional details should be provided to more fully meet the QU SR documentation requirements.

QU-04 AS-85 No u certainty analysis has This finding has been resolved and The F&O concerns the lack of This is a documentation issue.

been performed on the results closed by an update to the parametric uncertainty analyses Clarification to existing documents is from lJnit 1 or Unit 2 model/documentation.

for the PSL quantification results.

required to close this finding. There is quan ification results.

Completed uncertainty/sensitivity However, the F&O references no impact to RICT calculations.

analysis and related evaluations AS-85 and 86, which do not are included in the current pertain to uncertainty analysis; it Quantification Notebook document is assumed that the SR PSL-SN8K-QU Rev 0 references are incorrect. The 2012 QU notebook (PSL-SN8K-QU, Revision 0) includes the results of the parametric uncertainty evaluations for CDF

L-2018-201 Page 13 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments and LERF. Sections 4.2 and 7.9 refer to PSL-SNBK-UNCERT, Revision 0, "UNCERTAINITY NOTEBOOK For ST. LUCIE UNITS 1 & 2" which documents Accident Sequence Analysis Uncertainty, Success Criteria Uncertainty, System Analysis Uncertainty, HRA Uncertainty, Data Analysis Uncertainty, Internal Flooding Uncertainty, Quantification Uncertainty (Documented in Quantification Notebook), LERF Analysis Uncertainty (Documented in Quantification Notebook).

However, the subsequent PRA Update notebooks, which document the results of later model revisions, do not include updated uncertainty evaluations.

This F&O remains open, pending the creation of a new QU notebook for the current PRA that includes an updated parametric uncertainty evaluation.

SL-CCF-IE-A6 The ( CF of ICW traveling This finding has been resolved and Based on review of PSL-BFJR-

5. lmfJ.Iementation Item 12 screJn plugging and the CCF of closed by an update to the 06-008 (Quantification of Finding SL-CCF-12 will be closed in ICW r,trainers plugging as model/documentation.

Common-Cause Failure accordance with Appendix X to NEI contr butors to the loss of ICW The PSL models were revised to Probabilities), CCF of the ICW 05-04, NEI 07-12 and NEI12-13, initi~\\~r fault tree are missing include CCF of ICW traveling traveling screen plugging and "Close-out of Facts and from he model and no screen plugging and the CCF of strainer plugging from

L-2018-201 Page 14 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments expla ration for their absence is ICW strainers plugging as environmental impacts has been Observations."

pro vi ed. Common cause contributors to the loss of ICW assessed; however these impacts contr ibutors to the loss of ICW system. They were not considered are included in the loss of ICW arejL dged to be both credible under IE fault tree to eliminate mitigative fault tree and are not and r otentially risk-significant.

double-counting. Calc PSL-BFJR-included in the loss of ICW Thisj udgment is based on the 15-014.

initiating event fault tree so as to failur of a intake screen avoid "double counting" of the rep or ed in LER 84-09, 1011/84 impact. Because of the (Unit 1 ), the fact that these suspected double counting issue, issue ~ are addressed in the plant the PSL PRA model does not Off-Npminal Operating include consideration of CCFs in Protu"' 064030, aod that data any of the initiating event fault is av ilable for both of these trees. This appears to be failur s in the NRC CCF contrary to general industry data ase. Given that common practice and guidance contained caus ;l is likely to be a dominant in EPRI TR-1 0167 41, "Support contr butor to the loss of ICW System Initiating Events", and and t rat the nominal loss of ICW WCAP-16872 "Pilot frequ ~ncy is judged to be very Implementation of EPRI low( 1 E-5/rx-yr), the modeling Guidance for Fault Tree Modeling of the loss of ICW initiating event of Support Systems Initiating is judged to not meet SR IE-A6 Events". This guidance suggests foe af cc level 00 CCF.

that CCF event combinations Basi for Significance:

associated with operating This &0 was assigned a equipment are assigned a Signi icance of A due to its mission time of one year and pote tial risk significance.

combinations of CCF events of Addirnal Discussion:

secondary standby equipment are This inding applies to both St.

assigned a mission time as Lucil Uoit 1 aod 2 PRA models appropriate (e.g., mean time to repair). This finding is considered to remain open pending further explanation and justification for

L-2018-201 Page 15 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments the current CCF modeling approach to the initiating event fault trees.

SY-12 AS-A10 It appears that in general key This finding was reviewed and Documents PSL-PRA-SNBK-Independent Review team reviewed contrt.l systems in the St. Lucie closed with no further action.

AFW and PLS-BFJR-02-027 were 2002 documents instead of the current Plant are not modeled. In the Per discussions with operations reviewed. Neither document PRA documents. AFAS system and fault ree the AFW flow control personnel, AFAS would start discusses the justification for AFW system components are syste rn is demanded 3 times, but pumps and open flow valves to using 3 demands for the failure developed with greater level of details the b ~sis for using 3 demands is provide AFW flow to SGs. Small calculation. It should be noted in the current PRA model.

uncle ar. No analysis has been adjustments to valve position over that the AFW valves cycle open Calculations and Justification of done to determine the number of time would be performed by the and close to supply the SG and number of demand for these valves cycle the AFW system will operator to maintain desired SG are not open throttled valves.

and any SSCs are provided as part of undergo. Further, the common level. There would not be a series The basis for the 3x demand on the latest periodical data analysis caus MOV demand failure rate of valve open and close cycles. It is the AFW discharge valves should evaluation This is a documentation does only considers a single judged that the assumed 3 valve be explained in the issue. Clarification to existing finding dem~ nd.

cycles would be adequate to documentation and may not be closure documents is required to close The r hodel does not differentiate capture or bound the total valve accurate. Also, the logic that this finding. There is no impact to betw en an overfill and under fill.

failure prob.

opens and closes these valves is RICT calculations.

Over,ills in general could lead to not modeled. This F&O has not the f~ ilure of the turbine driven been addressed. This F&O is AFW pumps.

considered to still be open.

Note: If the MOVs are demanded twice it is doubtful that the failur likelihood would double.

But it is also clear the failure likeli~ ood will increase. Given the in portance of the AFW

L-2018-201 Page 16 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments MOV, any increase to the failur rates can be quite sign if cant.

SY-15 DA-A4 The i lnplementation of the Alpha This finding has been resolved and Documents PSL-BFJR-06-008 This is a documentation issue.

Parar heter methodology for closed by an update to the (Quantification of Common-Clarification to existing documents comlon cause analysis has model/documentation.

Cause Failure Probabilities) and with example is required to close this resul ed in conditions that The latest revision of CCF analysis PSL-BFJR-15-014 (Model Update finding. There is no impact to RICT appe r to be an over estimation document clearly describes the Document) were reviewed. 06-calculations.

of thJ contribution from common application of Alpha-Factor method 008 provides a comprehensive caus~ and results that do not and applicable data using 2009 discussion on the application and make obvious sense (i.e. cutsets INUNRC database. Calc PSL-use of the alpha method of in whrh the common cause BFJR-15-014 common-cause. However, based failur of three check valves on inspection of Table 2, some of

[three APN pump discharge the 4/4 component CCF chec~ valves] is more likely than probabilities are higher (more the c~mmon cause failure of two likely to occur) than the 3/4 checl valves [two MFW check component failure probabilities.

valve to the steam generators 1-In the case of the recently added V092 94 and I-V09252]). The EER fans failure-to-run CCF, the imple In entation of the 3/3 failure probability is slightly meth ' dology includes an higher than the 2/3 failure as sur )lption in the development probability. This was the subject of the parameters of staggered of the finding and was not testin b* This assumption may be explained in the referenced CCF non-e onservative. The common document. This F&O should cause failure of the check valves remain open pending further in the pump recirculation lines explanation of this CCF alpha

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Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments was ot considered and factor anomaly.

justifi ation provided for not including them was not included.

Som~ ofthe '""e' may be the resul of the use of component speci ic and generic alpha paraneter data.

lnterne~IFiood.PRAModel Findings

• IFEV-A7-IFEV-A7 The c onsideration of human-This finding was reviewed and PSL-BFJR-11-005 Rev. 0 and This is a documentation issue.

01 inducFd floods was not included closed with no further action.

PSL-BFJR-11-006 Rev. 0 were Clarification to existing documents is in thtnternal flooding As noted in the main Flooding reviewed. This F&O is very required to close this finding. There is evalu tion.

Analysis document, no condition similar to F&O IE-51. In general, no impact to RICT calculations.

The donsideration of human-reports that would reflect such human-induced flooding is not indu rd floods was not included problems, associated with the considered in the analysis. Only in th~ internal flooding possibility that plant design and a single type of human-induced evaluation. EPRI report 1013141 operating practices might affect the flood (transfer of waste water) that tvided genecic data foe likelihood of flooding, were to be was considered credible and this flood initiating event frequencies found. This possibility was was screened from further state that "Human induced reviewed with experienced plant consideration. The fact that a causf.s of flooding that do not staff after the peer review that human-induced flood has not invo~e piping system pressure identified one issue "the periodic occurred at PSL to-date is not boun ary failure such as transfer of waste water from Unit 2 sufficient rationale to screen such ove llling tanks and to Unit 1." The document was events from consideration.

The inappropriate valve operations further revised to address the GDOC does state in the that r :>lease fluid from the issue. PSL-BFJR-11-006, Rev 0 resolution that plant personnel syste m are not included."

were interviewed and plant procedures were reviewed. The result of this work was that human induced floods could not occur at PSL. Since there is no documentation in the flood notebooks (quantification or

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Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments analysis), this F&O is considered to remain open.

IFPP IFPP-A5 The ocumentation associated This finding was reviewed and PSL-BFJR-11-005 Rev. 0 and This is a documentation issue.

01 with t e plant partitioning is closed with no further action.

PSL-BFJR-11-006 Rev. 0 were Clarification to existing documents is scatt red between the initial No flood zones or flood sources reviewed. The flooding analysis required to close this finding. There is porti n of the document and the located within the reactor auxiliary report (PSL-BFJR-11-005) now no impact to RICT calculations.

walk own report in Attachment building were screened out. The includes some additional flooding analysis document was discussion of other plant buildings of th screening of main further revised to address flooding (such as the EDG buildings, CCW struc ures such as major originating in the other buildings or building, etc.). The discussions in struc ures.

Section 4.4 of the notebook areas even if this is not truly address the "other buildings" The Jalkdown report does not "internal" flooding. These do not concerns noted in this F&O.

inclu e any explanatory picture result in additional scenarios that However, section 5.3 of PSL-and Jixes the definition of the need be quantified as no previously BFJR-11-005 states: "applied-all area nd their screening, without unaddressed reactor scram need flooding scenarios excepting spelli 1g out the generic criteria ensue after such an event. This SR used *or the screening of specific explicitly requires discussing other those originating in small diameter domestic water lines struc ures. This organization of than spray/submergence failure and drain lines were considered."

the in ormation is prone to modes. PSL-BFJR-11-005 This is a screening criteria but it is confu sian; moreover, since the too general to be acceptable.

area dentification and the The pipe size (i.e. 1" or smaller) scree ning are mixed, some should be specified. Also, the over! ' ok have been noticed. For screening criteria in general are exam pie, the walkdown notes used but do not appear to be explic itly mention which bldg.

consistently applied. This F&O is has been walked down and the considered to still be open.

DG BLDG is not listed among those, still, the screening of the Comments DG B LOG is only discussed in Table 6 lists the flood zones that thew ~lkdown report and they are considered in each unit for are a I screened out on the basis that t ere is no service water analysis. However, the Unit 1 condensate pump pit is listed as a

L-2018-201 Page 19 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments (DG < re air cooled); there is flood area, but the Unit 2 pump pit neve he less no mention of the is not. Section 4.4.1 implies that pater tial spray effects of Fire all turbine building floods are Prote~tion system on a single neglected. The documentation DG r Uoes have beeo ootioed should be checked to ensure the durin the walkdown that may turbine building zones are have he potential to spray on accurately listed.

the Df cabinet). While the "1;og of the DG BLD may still b possible (FP lines may be dry since there are large FP valve immediately outside of the dG building that may be delu e valve, or the DG AOT may fe sufficient to recover from a sprf.y event on the DG cabinet), the presence of a flood sourc e that has the potential for impa ting PRA equipment needs to be addressed.

The' creening out of the Turbine Build ng is another example of scree ning process inconsistent with t re screening criteria pro vi ed in the standard. While it is tru that the TB BDLG is open, a rup ure in the condenser expa sian joints will induce an initiat ng event and for this reasc n the area cannot be scree ned out for flood cons i~erations. The flood

L-2018-201 Page 20 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments scenirio generated by a rupture of th condenser expansion joint may e screened for other reasc ns (e.g., it may be folded into a n already existing IE categ ory with identical plant effec but higher IEF), still a discu psi on of the reasoning and of th~'cceeo;og criteria oeed' to be pr vided.

Final!, section 4.1.1 points to the wrelkdown notes but incor ectly indicating Attachment C rat er than Attachment B.

IFQU-A1-IFQU-A1 SomE inconsistencies in the This finding was reviewed and The results presented in the This is a documentation issue.

02 map~ ing between the flood closed with no further action.

flooding quantification notebook Clarification to existing documents is even~s and the basic events Mapping between impacted were reviewed. The Unit 1 required to close this finding. Although asso1iated with impacted components and associated basic results no longer show a flood-there are differences between the equi~ment has been identified.

events was reviewed to ensure that induced ATWS as a dominant units, mapping in Unit 2 will be verified Acco f.ding to table 20, the top the flood induce failure is contributor; however, failures of to be consistent with mapping in Unit cutse shave to do with ATWS consistent with the failure mode both trains of batteries (due to a

1. There is no impact to RICT

od"r by a 'P"'Y event oo the modeled in the PRA model.

potential spray event, as well as a calculations.

react r trip switchgear. Spray on Changes to the mapping tables flood event) continue to dominate.

the r actor trip switchgear would were implemented to address the While the flood event may be resul in loss of power, which concerns of this F&O. The one credible, a spray event that fails woul result in the trip itself.

inconsistency related to the spray both trains of DC seems Ther fore, even though the conservative. For Unit 2, flood-react, r trip switchgears are event affecting the trip switchgear induced ATWS remains a actually impacted by the spray has been corrected.

contributor, so it is not clear if the eveni, the flood initiator needs The scenario referenced in the Unit 2 models were updated, or if not tc be mapped with the basic second part of the review comment this is the result in unit even associated with the does not involve a spray in rooms differences. This F&O is

L-2018-201 Page 21 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments swi!Iear because the;c fait""

1 RAB43-58 and -59 but rather a considered to still be open, is in t e direction of the success.

flood emanating from the battery pending confirmation that the Anot er example of suspect rooms to the neighboring flooding results have been switchgear rooms through the checked for consistency with the incon~stency in the mapping is connecting doors and submerging as-built plant.

obse I ed from the review of the main CDF contributors. A Sf?ray various electrical components inside. Since the analysis does not from rom 1 RAB43-59/58 is not credit isolation of the break, the expe ted to impact both trains flooding will persist over the since the originating room only number of hours. The mapping hosts 1 train of batteries reflects the equipment disabled by the accumulating water not only in the battery rooms but also in the neighboring electrical rooms, affecting both electrical trains.

Flooding Analysis PSL-BFJR 006.

IFSO-A4-IFSO-A4 No eJidence was provided to This finding was reviewed and PSL Internal Flooding PRA This is a documentation issue.

01 indic te that human-induced closed with no further action.

document PSL-BFJR-11-05 was Clarification to existing documents is mechlanisms were considered to As noted in the main Flooding reviewed. The report and PSL required to close this finding. There is dete~;oe the;c ;mpact as Analysis document PSL-BFJR F&O GDOC acknowledged that a no impact to RICT calculations.

pote tial sources of flooding.

005, Rev 0, no condition reports CR review was performed (CR review identified no human-The f ooding notebook indicated that would reflect such problems, induced events) and discussions that r EPRI g";deHoe, as associated with the possibility that held with plant personnel. The docu ented in report 1019194, plant design and operation was sed in performing the practices might affect the likelihood potential for waste water flooding was mentioned in the scenario for floodi g analysis. The EPRI of flooding, were to be found. This the rupture of the waste G";droe ;deotifled the flood;,,

possibility was reviewed with management system in the waste mechanism that would result in a experienced plant staff after the holdup tank rooms. Although relea e. No evidence could be peer review who identified one there is some mention of human-faun on the treatment of issue "the periodic transfer of induced interaction, the report humcjn-induced flooding. It waste water from Unit 2 to Unit 1."

L-2018-201 Page 22 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments appe rs that only pipe failures The document was further revised lacks detail and evidence of a were considered as flooding to address the issue.

thorough review of the PSL plant-mech an ism.

specific events data (and applicability of generic data),

needed to identify significant potential human-induced flooding mechanisms.

IFSO-A4 requires the identification of flooding mechanisms that would result in a release for each potential source of flooding including item (b),

human-induced mechanisms that could lead to overfilling tanks, diversion of flow-through openings created to perform maintenance; inadvertent actuation of fire-suppression system. It is judged that this limited consideration of induced flooding does not meet the intent of SR IFSO-A4. Therefore, this F&O remains open.

L-2018-201 Page 23 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments IFSO-A6-IFSO-A6 Confi matory walkdown to This finding has been resolved and The GDOC response for this F&O This is a documentation issue.

01 asse s the accuracy of the closed by an update to the indicates that new walkdowns Clarification to existing documents is infor+/-ation associated with the model/documentation.

were performed and flood source required to close this finding. There is source identification and Confirmatory partial-walkdowns and scenario calculations were no impact to RICT calculations.

scen,rio definition were not were performed after development updated to reflect the P*~r of this F&O and pipe isometric new/corrected information. The One alkdown was performed drawings were re-reviewed for flooding notebook indicates that some of the original battery room befor the identification of the accuracy. The walkdown revealed sources were deleted (see for flood ource began but flood that the CCW piping segments example, sections 4.2.1.9 and sources have not been inside the vital battery rooms at el.

4.2.1.12). The discussion of the confilmed during a dedicated 43' are hidden within a pipe chase sources and scenarios for the confi matory walkdown. Some near the ceiling and therefore not Unit 2 ECCS rooms also appears poter tial inconsistencies visible. As a result, the analysis to be complete. The Appendix A betw1 en the isometric drawings has been corrected by deleting the flooding spreadsheet appears to used or the identification of the CCW piping from the list of be consistent with the notebook flood sources and actual potential flood sources in the text. However, there is no con fie uration has been observed battery rooms. Any water from specific documentation durin~ the peer review postulated breaks inside the chase walkc'own. For example was assumed to divert from the concerning the walkdowns performed to support the flooding Appe hdix A indicates more than battery rooms to the adjoining analysis. Appendix B is referred 138', f CC piping in the U2 rooms. However, the water supply to as providing the walkdown Batte r>' room A (2RAB43-35) but pipe to the shower station was notes, but it states that there are no C piping has been observed added as a potential flood source no walkdown notes available.

in the room during the walkdown.

in each battery room. The Although the performance of a On th e other hand, demin water spreadsheet calculating rupture walkdown(s) is mentioned in the lines o the emergency eyewash frequencies was updated with the base document and in the GDOC have been observed during the above corrections which also response, there are no specific peer ~view walkdown in the corrected the input to FRANX.

walkdown notes available in battel coom, which ace oot Finally, the datasheets were Attachment B, as these have listed in the Appendix A reviewed and updated as well.

been transformed into the flood datasheet. 2RAB43-36 also does PSL-BFJR-11-005. Rev 0 and area summaries. This F&O is not s ow OW lines although it is PSL-BFJR-11-006, Rev 0.

considered to remain open,

L-2018-201 Page 24 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments expe1 ted that eyewash station pending addition of information are a lso present and they are pertaining to the initial and indeef. shown in the architectural subsequent walkdowns.

drawi g). In 2RAB43-36, the batter ace mentioned to be paten ially vulnerable to spray from 1re protection but no fire prate tion is listed as potential source in the room.

Appe 1dix A shows multiple exam pies of datasheet being in con plete even for critical room such as the ECCS rooms (see or example 2RAB-10-16B) that ~auld challenge the selec ion of impacted equipment.

• Fi~e.PRA Mode!Findihgs..

CS-A3-CS-A3 4kV ~ ower and 125VDC control Reviewed component failure PSL-BFJR-16-039, PSL Fire PRA This is a documentation issue.

01 cable ~ required to support the modes to ensure that components Component and PSL-BFJR Clarification to existing documents is oper< tion of the Containment for which operation is credited 039, PSL Fire PRA Component required to close this finding. There is Spra Pump were not identified.

include required power cables.

and Cable Selection, was no impact to RICT calculations.

Fire F RA Plant Response model PSL-BFJR-16-039 reviewed. No list of components and c ther Fire PRA support added based on the MSO expert tasks are adversely affected.

panel was available. As such, no Perfo m a comparison of the review of the cable selection camp onents identified on the performed for these components MSO (multiple spurious could be done.

opere tion) list against the Fire Comments PRA omponents for which new Appendix D incorrectly states cable selection was performed reference 16 is the MSO expert (i.e., omponents not previously panel report.

L-2018-201 Page 25 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments identi ied on the Appendix R safe shutd pwn equipment list). Verify that t e cable selection for the oom f" oompooeo" '"pporn all cr dited operations.

Fire RA Plant Response model and o her Fire PRA support tasks I are adversely affected.

CS CS-81 No etluation was performed to A detailed review of the PSL-8FJR-16-039, Task 2 This is a documentation issue.

01 verify that the new components coordination analysis was Component and Cable Selection, Clarification to existing documents is and 1rbles associated with the performed including those power was reviewed. Section 3.0, Cable required to close this finding. There is Fire RA is bounded by the supplies associated with Fire PRA Selection, contains the following no impact to RICT calculations.

existi g overcurrent coordination components.

text, "A review of power supplies analy sis.

for active components was TheE valuation was not performed and required power supplies were also added to the completed at this time.

FPRA component I cable data."

No mention of coordination could be found in the report. The review of breaker coordination needs to be added or referenced in the report for traceability. This F&O remains open pending inclusion of documentation of the coordination study.

ES ES-01 Pl-03 003 provides instruction SSO and FPRA documentation PSL-8FJR-16-039, PSL Fire PRA This is a documentation issue.

01 for ci cuit analysis to include revised to provide enhanced Component and Cable Selection, Clarification to existing documents is revie 'N of interlocks, documentation of component was reviewed. Section 3 of the required to close this finding. There is instru mentation, and support selection and cable selection.

report states, "A review of power no impact to RICT calculations.

syste jn dependencies. Cable supplies for active components routir g database was reviewed was performed and required and c onfirmed that interlocks, One set of SSO instrumentation will power supplies were also added

L-2018-201 Page 26 of36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments instru mentation, and support remains available to meet SSD to the FPRA component/cable syste In cables were included in systems for an area wide fire. The data. The circuit analysis equip ~nent effects.

correlation between SSD performed for the original safe How:rer, demonstration of a instrumentation and operator shutdown analysis as well as for revie of power supplies, etc.

actions provided in the HRA report the FPRA components included confirms that for each HFE the identification of cables was r ot readily apparent in the Appendix R instrumentation is associated with interlocks and Com~ anent Selection report.

available to support the cue for the instrumentation permissives, the Thed evelopment of the Fire action. Guidance provided in SSD failure of which could impact the PRA 3quipment list inherently procedures will identify the safe shutdown/FPRA consi ers the entire component instruments available post fire and component." This portion of the and it s supporting equipment; focus operator cues on these F&O is addressed.

howe1 er, it is important to instruments. Since the Appendix B of the report docurnt th '""'"nation to instrumentation availability is describes the review of Safe supp 'rt peer reviews and defined on a fire area wide fire Shutdown equipment for appli ations.

basis it will provide a conservative basis for instrumentation available individual disposition for It is s ggested that document for an individual scenario within the applicability in the FPRA. One the rJview to show the fire area. Incorporated additional criteria for inclusion in the FPRA interl~cks, power supplies, etc.

discussion in HRA report, Section is the equipment's function is are illuded (or referenced) in

3.

related to reaching the safe and the d velopment of the stable end state of hot shutdown, Comrnent Selection section.

i. As part of the task of replacing not cold standby. As such, the the screening HEP values with equipment which is included in The Equipment selection report detailed FPRA HEPs, FPRA-the list is needed to reach said state~ that SSEL equipment specific HEPs are being added to safe and stable end state. This requi ed to place the plant in hot the quantification fault tree portion of the F&O is also met.

stand py, the PRA end state, are including instrumentation cues. The in clue ed in the analysis while required cues were correlated to However, no connection to a fire-equip ~nent only associated with SSD analysis instrumentation related reactor trip or any takin~ the plant to cold shutdown which is identified as available discussion related to how fire were excluded from analysis.

instrumentation in the post-fire impacts propagate through the No in ormation is provided to shutdown procedures. This logic model could be found other facilit te the assignment of than the following statement,

L-2018-201 Page 27 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments

,,d,vr*' ssEL lostrumematloo imposes a failure of the HEP in any "Disposition codes were only to sp cific plant states, which scenario where all associated cues assigned to basic events that are camp icates review against this are lost due to fire damage. The under the FPRA top gate." No SR.

treatment of cues is consistent with mention of any logic added to the Expa d Component and Cable NUREG-1921, specifically fault tree to allow FPRA discussion regarding failure of cues quantification to capture the Selec ion tables to allow SSEL due to fire in accordance with impact of fire related initiating camp bnents to be associated NUREG-1921 section 4.5.5.

events could be found. Since this with s becific plant states.

does not fully meet the intent of Comr onents are linked to fault ii. The fire specific HEPs have also SR ES-D1, this F&O remains been correlated to the SSA tree E asic Events, but suggest instrumentation. The cues for these open.

docur~ent all potential fire HEPs have also been incorporated indue ~d sequences are into the fire PRA fault tree.

confir [ned to be associated with a rea 'tor trip initiating event in iii. The development of the fire the fa lilt tree.

specific HEPs included the review lmpro ve component selection of post fire shutdown procedures.

Revisions to these procedures to repori to address items identified ensure that operators are focused in this F&O.

on non-fire impacted cues and to update the required actions in a manner FSS-A1-FSS-A1 PSL c id not postulate hydrogen Hydrogen for VCT tank isolated PSL-BFJR-16-042, PSL Fire PRA PSL Fire PRA model requires the 01 (H2) ~res other than the turbine from other equipment components.

Scenario Development, was addition of fire scenarios associated gene rtor H2 fires. PSL used the AFW steam driven pump oil fire reviewed. Sections 6.6.2 through with the documented Bin 34 Turbine basis that their H2 piping addressed in AFW C pump fire.

6.7.2 describes the treatment for Generator Fire Ignition Frequency.

contars excess flow check Located in outdoor area thus various types of hydrogen fires.

These scenarios are for a hydrogen valve. However, this will not limiting impact of this fire.

Section 8.5, Scenario fire associated with the turbine P""t H2 '""* "' likely that

i. The hydrogen system at St. Lucie Nomenclature, states that generator. Since the turbine generator plant experiencing H2 fires that provides hydrogen to the chemistry scenario names including "H2" is in an open environment, the risk contri uted to the "potentially are scenarios associated with impact of this scenario is minimal.

chall,nging" fire frequency also lab and the volume control tank in hydrogen fires. A number of the reactor auxiliary building.

Finding \\ Supporting Number Requirement j_

Description had e~cess flow check valves.

Reco mend either postulating H2 fir s or developing a stronger technical justification for their exclusion.

PSL did not appear consider all pumpllube oil fire scenarios (e.g., if.FW pumps, Charging Pum~s. HPSI pumps, LPSI pum~~. MFW pumps, etc.).

Thes~-scenarios often involve signifipant quantities of oil causifg widespread damage in the fir compartment. They can also ontribute to multi-camp rtment fire risk.

Note hat some lube oil seen rios appear to have been consi ered by PSL. Specifically, MFW and turbine lube oil fires were postulated. In speaking with t~e analysts, they indicated that other pumps tend not to have large quantities of lube oil and t~at source-target data for oil sc,narios was often collected durinq walkdowns. However, there~was little documentation of this, nd very few oil scenarios were uantified in FRANC.

PSL qid not postulate H2 fires Disposition and Resolution of Open F&Os Finding Resolutions Provided to Independent Review For Finding Closure These systems are provided with pressure monitoring, guard piping and excess flow check valves which preclude the release of a significant quantity of hydrogen which could cause a challenging fire. The design basis for these lines in the event of a complete line break is for the hydrogen concentration to be limited to no more than 2% hydrogen (Unit 1 UFSAR Appendix 9.5A Section 3.15.2 and Unit 2 UFSAR Appendix 9.5A Section 3.15.1 ). This is a safety factor of 2 to the flammable limit for hydrogen in air. Therefore, based on these design features no specific scenarios associated with a miscellaneous hydrogen fire are postulated.

ii. The current Fire PRA does not exclude any flammable liquid fire scenarios for fixed fire sources that may contain combustible liquids. A review of the fire scenarios for pumps containing significant quantities of oil identified existing scenarios for the Circulating Water Pumps, Main Feedwater Pumps, Heater Drain Pumps and Condensate pumps. A comparison between Unit 1 and Unit 2 Independent Review Comments scenarios were identified with the "H2" designation in the report and the FRANX model.

PSL-BFJR-16-040, PSL Fire PRA Task 1 & 6 Plant Partitioning and FIF, was reviewed to determine where the fire frequency for bin 34, Turbine Generator Hydrogen, was accounted for. This frequency was documented in fire zones 1-23 & 2-47(8) the LP Heater Area for Units 1 & 2 respectively; however no fire scenario with this ignition frequency applied could be found in the scenario report or FRANX model.

Sections 6.5 & 6.6.3 of the scenario development report describes the treatment of oil spill fires. Fire ignition frequency for Bin 35, Turbine Generator Oil, is documented in two fire zones, 1-13 & 2-11 the Turbine Lube Oil Reservoir for Units 1 and 2 respectively, but no scenarios in those fire zones have a Bin 35 contribution to their fire ignition frequency. In addition, only the RCP fires were identified in the report. The documentation of the oil fires in the PRA model is not L-2018-201 Page 28 o£36 Disposition for RICT

6. Implementation Item:

Model revision and associated documentation are an implementation item.

L-2018-201 Page 29 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments and o I fires as specified by identified several missing scenarios evident. This F&O is considered NURl G/CR-6850, and minimal for Unit 2 which were walked down open due to the identified issues basisjtor this deviation was and added to the Fire PRA. Diesel with both hydrogen and oil fires.

provi ed. These fires can be risk generator fire scenarios are base signifilcant due to the potential for scenarios which include the impact widespread damage in the fire of a fire given that all targets in the comp f!rtment.

room are impacted. Main, Auxiliary and Startup Transformer scenarios are included in the current Fire PRA, as is a turbine generator related fire.

Ref ML14135A395 PSL L-2014-109 FSS-H1-FSS-H1 In se 'eral cases, PSL Beyond 6850 methods, panel PSL-BFJR-16-042, PSL Fire PRA This is a documentation issue.

01 imple !nented methods beyond factor approach, has been Scenario Development, was Clarification to existing documents is those available in beyond eliminated from the PSL Fire PRA.

reviewed. The report no longer required to close this finding. There is indus ry accepted guidance The use of the 69 kW HRR for has a reference to the use of un-no impact to RICT calculations.

do cur rents (e.g., NUREG/CR-transient fires has been limited to reviewed methods in the fire PRA 6850 ~nd its supplements). For those fire zones in which "zero model. Section 7.1 describes the exam pie, PSL created their own transients" are allowed in order to treatment of transient HRRs. The multii liers I severity factors for account for the potential violation of use of 69kW transient fires was fires t ~at cause damage beyond the administrative controls.

eliminated and replaced with the the ig rition source by reviewing accepted 317kW fires from the ELRI Fire Events Database.

i. The St. Lucie Fire PRA model NUREG/CR 6850. Only fire A second example is that PSL implements two types of scenario zones in which "zero transient" modelled transient fires using the manual suppression factors for an combustible controls are in place motor fire heat release rate ignition source: time to target use a 69kW heat release rate for distrit ution, which is much damage and time to hot gas layer transient fires. Section 8.1 small ~r than the transient fire (HGL). The time to target damage describes the application of distrit ution. A third example is evaluates the direct heat flux severity factors based on

L-2018-201 Page 30 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments not a plying the "Location incident on a target due to the fire.

NUREG-6850. The use of panel Facto r" to account for wall/corner The time to HGL evaluates the factors was eliminated and effect ~ on flame height and volume temperature effects due to wall/corner factors were applied plumE temperature distribution.

the fire.

as appropriate. Section 7.5 While these methods seem The LAR-submitted model used the states that the use of location appr~priate, documentation of approach that these two analyses factors has not been applied to increase heat release rates used the I"'" base' foe the'e were independent of each other in the model, and this section meth 'ds was generally lacking.

and therefore one was not Meth ds beyond industry conditioned on. the other. The needs to be updated to reflect the acce ted guidance (e.g.,

updated approach, generated to adjustment factors used in the final PRA model. This F&O is NUR G/CR-6850 and its support the RAI responses considered to remain open, supp~ments) should have considers the two analyses as docu ented technical bases of dependent. Since the time to target pending revision of the section similar quality and magnitude to damage in most cases is less than 7.5 discussion.

those provided in NUREG/CR-the time to HGL, the time to HGL is 6850.

conditioned on the time to target Also, PSL should be aware that damage. For example, consider a meth ds beyond industry time to target damage of 5 minutes accer ted guidance documents and a time to HGL of 30 minutes, in the context of the event tree in mayl, e viewed critically by the Figure 1. The first node, event MSI, NRC.

represents the time to target While these methods seem damage. Using the manual apprc priate, the level of nonsuppression (MS) distribution do cur rentation provided did not from NUREG/CR-6850, allow detailed review by the peer Supplement 1, Chapter 14 with a cevler"* '" additioo, method' lambda value of 0.102 (electrical beyo d industry accepted fires), the MSI probability is 0.602.

guida ce (e.g., NUREG/CR-The second node, event MS2, 6850 nd its supplements) represents the time to HGL and is shoul* have documented conditioned on the first node. In technjcal bases of similar quality order to condition MS2 on MS 1,

L-2018-201 Page 31 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments and n agnitude to those provided the time credited for MS 1 is in NU REG/CR-6850.

subtracted from the time available for MS2. In this example that would leave 25 minutes available for MS2, which, using NUREG/CR-6850, Supplement 1, Chapter 14, has an MS value of 0.079. Figure 1 in L-2014-1 09 (pg. 52) shows the resulting fire scenario MS values for the three respective fire scenarios applying the node MSI and MS2 values. The HGL fire scenario gets a 0.0474 MS value, which corresponds to a 30-minute non-suppression probability.

The minimum manual non-suppression probability used is 0.001.

ii. Reliability and unavailability of automatic detection systems were assumed in the LAR submitted model to be incorporated in the manual non-suppression probabilities specified in NUREG/CR-6850, Appendix P, as revised in NUREG/CR-6850, Supplement 1. Reliability of automatic suppression systems was based on values specified in NUREG/CR-6850, while availability was not considered to impact the reliability data given that plant

L-2018-201 Page 32 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments procedures specify compensatory actions to be implemented when the systems are not available. In order to address the concern that the information inherent in the NUREG/CR-6850 data may not be bounding, the model has been updated to incorporate this additional failure potentiaL The scenario development event tree incorporates an additional node, before any suppression (manual or automatic) is credited. The event tree detection failure path includes a 15-minute time delay before manual suppression is allowed to be credited (using SOP guidance for detection time for locations without detection systems). Figure 1 in L-2014-1 09 (pg. 53)shows an event tree without consideration of detection failure. Figure 2 in L-2014-109 (pg. 53) shows the Updated approach which incorporates detection failure. Note that the MS1/MS 15 and MS2/MS _15 values are bounded to a maximum value of 1. This results in zero ignition frequency being applied to the success branch for instances where the time to target damage or time to hot gas layer is less than 15 minutes. NUREG/CR-

L-2018-201 Page 33 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments 6850 Appendix P suggests a bounding failure probability for smoke detection based on the Halon suppression failure probability. The data used to develop the Halon suppression failure probability included detection failure (smoke detection),

so the detection failure probability by itself is bounded by the Halon failure probability.

NUREG/CR-6850 Appendix P does not specify guidance on thermal detection failure probability, therefore the use of the associated suppression system failure probability is applied to the corresponding detection system.

The failure probability specified in NUREG/CR-6850 Appendix P for deluge or pre-action sprinkler systems is conservatively applied as the failure probability for thermal detectors associated with actuation of a preaction system.

iii. no credit for an NSP is used in the analysis of HEAF or oil fire HGL impact (all HEAF and oil fire scenarios will be assumed to result in a hot gas layer in the associated fire zone).

Ref ML14135A395 PSL L-2014-109 (pg. 51-53)

L-2018-201 Page 34 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments Unreviewed Analysis Methods were eliminated (panel factors methodology was eliminated, wall and corner factors were applied where appropriate) or revised (revised use of 69 kW HRR for transient fires to limit its use to locations specific locations) by application of the guidance provided in the June 21, 2012 Joseph Giitter to Biff Bradley memo. The items addressed in this memo and their disposition with respect to the PSL Fire PRA is addressed below:

1. Frequencies for Cable Fires Initiated by Welding and Cutting -

not used

2. Clarification for Transient Fires -

methodology applied is consistent with the approach accepted by the methods review panel and the NRC. See RAI PRA 4 for further details.

3. Alignment Factor for Pump Oil Fires - not used

4. Electrical Cabinet Fire Treatment Refinement Details -eliminated from Fire PRA supporting PSL LAR submittal as stated in PSL NFPA 805 LAR Section V.2 and in RAI

L-2018-201 Page 35 o£36 Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments PRA01.m.

5. EPRI 1022993 -"Evaluation of Peak Heat Release Rates (HRRs) in Electrical Cabinet Fires" - not used No other methods used in support of the PSL Fire PRA are considered deviations from accepted methods and approaches.

Ref ML14135A395 PSL L-2014-109 (pg. 57/58)

HRA-A4-HRA-A4 A rev ew of modeled actions is The use of the screening approach PSL-BFJR-16-041, PSL Fire PRA Each operator action is developed 01 plann~d to be performed once for adjusting FPIE model HEPs and Human Failure Evaluation Report, based on analysis of the existing draft f.rocedures are generated the use of screening HEPs is was reviewed. The report has not procedures. For the Fire PRA model, from ]he Fire PRA. However, at sufficient to support this been updated since the original new operator actions were developed pres~nt no such review has been application.

peer review comment was made.

for fire responses based on the perfo med except for a limited PSL-BFJR-16-041 To satisfy capability category II of existing plant operating procedures, boarc walkthrough documented the ASME/ANS standard, a things like local control of the AFW in Ap endix C of the Human walkthrough with operators on the valves or aligning the fire protection Failu e Evaluation report.

procedures that were generated pump to provide a means to refill the for the fire recovery actions is CST. Each of these actions was required. No fire response developed based on operator procedure review/talk through interviews and feedback on the key with plant operations and training action steps. The issue that exists is personnel was conducted. Also, that the documentation of the operator no mention of screening values is interviews in not complete in the HRA provided in the report. This F&O calculator database or in PSL-BFJR-is considered to remain open.16-041. This F&O was left open to ensure that the documentation is added to the database and/or the

L-2018-201 Page 36 o£36 I

Disposition and Resolution of Open F&Os Finding Supporting Finding Resolutions Provided to Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement Closure Comments GOOC.

This is a documentation issue.

Clarification to existing documents is required to close this finding. There is no impact to RICT calculations.

PRM-C1-PRM-C1 Overc:'ll PRM documentation is Added discussion in PSL-BFJR-16-039, PSL Fire PRA This is a documentation issue.

01 spars f' and doesn't provide the Component/Cable report Section Component and Cable Selection, Clarification to existing documents is inforrr ation addressed in the 5.0.

was reviewed. Insufficient required to close this finding. There is SRs c: ssociated with the HLRs PSL-BFJR-16-039 information was added to section no impact to RICT calculations.

descr bed in the Category I, II 5.0 to describe the plant response and II criteria of PRM-C1. In model, or assumptions made. No additi Dn, the development of discussion of initiating events, chan~ es made in Tables 01 and accident sequence changes, 03 ar ~ not described (PRM-89).

system model changes, LERF Reo1 meod a 'epacale PRM impacts, or any new operator actions was found. In addition, repo that documents in a there is limited documentation of struct red and consistent way the changes to the CAFTA model.

the repuirements described in This F&O is considered to remain the P~M SRs open.

St. Lucie Unit 1 -Markup of the Operating License L-2018-201 Page 1 o£3

INSERTJ L-2018-201 Page 2 of3 J.

FPL is authorized to implement the Risk Informed Completion Time Program as approved in License Amendment No. XXX subject to the following conditions:

1. FPL will complete the following prior to implementation of the Risk Informed Completion Time Program:

a.

The items listed in the table of implementation items in the enclosure to FPL letter L-2018-006, "Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk Informed Extended Completion Times-RITSTF Initiative 4b'," February 1, 2018, and

b. The six implementation items listed in Attachment 1 to FPL letter L-2018-201, "Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,' "November 9, 2018.

2. The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the ch~nge is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

6.

Training on integrated fire response strategy

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders H.

Control Room Habitability L-2018-201 Page 3 of 3 Upon implementation of Amendment No. 205, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.7.1.e, in accordance with TS 6.8.4.m, the assessment of CRE habitability as required by Specification 6.8.4.m.c. (ii), and the measurement of CRE pressure as required by Specification 6.8.4.m.d, shall be considered met.

Following implementation:

(a)

The first performance of SR 4.7.7.1.e, in accordance with Specification 6.8.4.m.c(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01.

(b)

The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.m.c(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.c.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from June 30, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

I.

RODEX2 Safety Analyses RODEX2 has been specifically approved for use for St. Lucie Unit 1 licensing basis analyses. Upon NRC's approval of a generic supplement to the RODEX2 code and associated methods that accounts for thermal conductivity degradation (TCD), FPL will within six months:

---

la-}--8emoostr-ate--tl9-at-St-;-b:teie-l:ffiiH-s-afety-aRalyses-r-emaift--ooFlseFVffiively'--------

bounded in licensing basis analyses when compared to the NRC-approved generic supplement to the RODEX2 methodology, or (b)

Provide a schedule for the re-analysis using the NRC-approved generic supplement to the RODEX2 methodology for any of the affected licensing basis analyses.

Renewed License No. DPR-67 Amendment No. 231 Revised by letter dated March 31, 2016 St. Lucie Unit 2 -Markup of the Operating License L-2018-150 Page 1 o£3

INSERT 0 L-2018-150 Page2 of3

0. FPL is authorized to implement the Risk Informed Completion Time Program as approved in License Amendment No. XXX subject to the following conditions:

1.

FPL will complete the following prior to implementation of the Risk Informed Completion Time Program:

a.

The items listed in the table of implementation items in the enclosure to FPL letter L-2018-006, "Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk Informed Extended Completion Times-RITSTF Initiative 4b'," February 1, 2018, and

b.

The six implementation items listed in Attachment 1 to FPL letter L-2018-201, "Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4b,'" November 9, 2018.

2.

The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

L-2018-201 Page 3 of 3 NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 6.15.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from November 13, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

N.

FATES3B Safety Analyses (Westinghouse Fuel Only)

FATES3B has been specifically approved for use for St. Lucie Unit 2 licensing basis analyses based on FPL maintaining the more restrictive operational/design radial power fall-off curve limits as specified in Attachment 4 to FPL Letter L-2012-121, dated March 31, 2012 as compared to the FATES3B analysis radial power fall-off curve limits. The radial power fall-off curve limits shall be verified each cycle as part of the Reload Safety Analysis Checklist (RSAC) process.

4.

This renewed license is effective as of the date of issuance, and shall expire at midnight April 6, 2043.

Attachments:

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by J. E. Dyer, Director Office of Nuclear Reactor Regulation

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan

3. Appendix C, Antitrust Conditions

4. Appendix D, Antitrust Conditions Date of Issuance: October 2, 2003 Renewed License No. NPF-16 Amendment No. 182 Revised by letter dated February 13, 2017 St. Lucie Unit 2-Markup ofTechrucal Specification 3.6.1.3 L-2018-201 Page 1 of2

L-2018-201 page 2 of2 CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIMITING CONDITION FOR OPERATION 3.6.1.3 Each containment air lock shall be OPERABLE with:

a.

Both doors closed except when the air lock is being used for normal transit entry and exit through the containment, then at least one air lock door shall be closed, and

b.

An overall air lock leakage rate in accordance with the Containment Leakage Rate Testing Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a.

With one containment air lock door inoperable*:

1.

Maintain at least the OPERABLE air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or lock the OPERABLE air lock door closed.

2.

Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days.

3.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

b.

With the containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

If the inner air lock door is inoperable, passage through the OPERABLE outer air lock door is permitted to effect repairs to the inoperable inner air lock door. No more than one airlock door shall be open at any time.

ST. LUCIE-UNIT 2 3/4 6-9 Amendment No. 39, g&, 4-+G, 184