L-2018-215, Resubmittal of 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

Resubmittal of 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

ML18334A250
Person / Time
Site:	Saint Lucie
Issue date:	11/30/2018
From:	Deboer D Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-215
Download: ML18334A250 (47)

Text

NOV 3 0 2018 *

• F=PL L-2018-215 10 CPR 50.90 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

Subject:

Resubmittal of 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-Informed Extended Completion Times - RITSTF Initiative 4b,'" February 25, 2017 (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-2018-215 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)

14. Florida Power & Light Company 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 (ML18316A030)

In Reference 1, as supplemented by References 5, 6, 7, 10, 11, 12, 13, and 14, 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 includes the corrected TS markups in attachments 2, 3, and 4 of the Reference 14 submittal that were inadvertently corrupted when the letter was prepared for electronic submittal.

No other changes were made.

This supplement does not alter the conclusions in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes.

No new or revised commitments are included in this letter

L-2018-215 Page 3 of 3 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 true and correct.

Executed on NOV* 3 0 2018 Sincerely,

{)JIJ~

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-2018-215 Attachment 1 Page 1 of 36 Attachment 1 Disposition and Resolution ofOperrF&Os RWT rupture 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 overly conservative. Without about SOC when it is implied that establish SOC. Charging pumps take make-up the level in the RCS This scenario was reviewed to be cooldown is being reviewed. suction from BAMTs and not VCT would drop, but there is more contrary to current plant practices Since this is a C-E designed which is isolated on SIAS (CVCS and EOPs. Use of RWT and plant, there is a separate pump letdown and VCT are only required than enough fluid in the Boric Acid Tanks and the VCT to BAMTs are required when RCS for HPSI and charging. The during operation). If the RCS level restore this level. The level does needs makeup due to shrinkage source for the charging pump at drops, for any reason, eves has not need 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 need 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 were to occur during makeup to the the RWT would not fail charging Hot Leg. SITs will be dumped at 250#

leg.

point where RCS cooling continues to makeup during cooldown. in U1 and 600# for U2, which are Estimated Level Drop 2250 psia at a rate of 1OOF/hr, and RCS level However, further review also setpoints above the interlocks for at 600 F (0.0217 ft 11 3/lbm) to 100 drops down to about midloop level. found gate M1 BORATN02 where SOC, restoring the full level of RCS psia at 300F (0.01766 ft113/lbm). EOP-02, step 4.5 prevent against failure of the RWT would fail and allowing entry into SOC if needed Given RCS liquid volume of this behavior by requiring that OP emergency boration. The gate at 235#. The referenced logic 10,400 ft113, this means ensure RCS inventory control is M1BORATN02 is an "OR" gate. correction is made into the current approximately 18,500 gallons maintained, and PZR level is This gate needs to be changed to working model which will be revised are required 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 RICT calculations impacting contains 4000 gallons. Fully PRZ scenario is perceived as not Charging System.

level is not required full credible. Comments shutdown cooling when core 1. lme.lementation Item:

damage is the alternative. The resolution of this F&O in the 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 Consider adding low pressure 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 the model for accident without any further actions. The Feed to S/Gs. The change favorably sequences involving loss of all Total Loss of MFW/AFW is about accident sequence notebook impacts RICT calculations associated 3% of CDF. Addin this credit will

L-2018-215 Attachment 1 Page 2 of36 Disposition and. Res(jlution of. Open F&Os Finding Resoluti()ns provided* to lndependenfReviewForFillding Cl.osure*

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

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

Procedure'. Operations is added to the model at this time.

directed to use low pressure 2. Implementation Item:

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

Crediting low-pressure feed will Model revision and associated eliminate those core damage documentation are an implementation sequences where the MFW item.

pumps are lost, but the condensate pumps are available.

If the TBVs are not available, then the hot well make-up control system (or an operation action) must be modeled to incorporate this alternative.

Adding LPF could reduce dependency on Once Through Cooling for a number of accident sequences.

(See F&O AS-03 also)

AS-08 AS-A5 Check Valves 09294 and 09252 Data analysis and CCF analysis Document PSL-1 FJR-03-009 was This is a documentation issue.

are common for both AFW, have been updated numerous reviewed. There is no Clarification to existing documents is MFW, and Low Pressure Feed. times since the development of this documentation of the logic required to close this finding. There is These CKVs currently appear F&O. CCF module FMM1SGCVLV changes made to resolve this no impact to RICT calculations.

only in the AFW system. The was added under gates F&O in the referenced may be some events (e.g. LOL) F1SG1APATH,F1SG1BPATH, calculation. It is unclear which where the turbine trips and F1SG1APATH-<4, and check valve CCF combinations steam generator pressure rises F1 SG1 BPATH-<4. Added events are appropriate to consider. The enough to cause the closure of FCVN109252 under gates fault tree was reviewed and a these check valves. Under these F1SG1APATH and F1SG1APATH- CCF module was added to the scenarios, the failure of both of <4. Added events FCVN109294 model in the common cause these checks would fail all under ates F1SG1BPATH and ates. This F&O is considered to

L-2018-215 Attachment 1 Page 3 o£36 Disposition and Resolution of Open F&Os Finding .Resolutions Provided to Independent Review For Finding Closure secondary side heat removal.

Currently, these CKVs are modeled under FMM1SGCVLV.

This event has a failure probability far lower than several three element CKV groups in the AFW system. There does not appear to be a basis for this difference. The failure likelihoods (independent and common cause) of the check valves in the AFW system should be consistent or the basis for the difference is documented.

Further, as the random failure of these CKVs could cause a LOFW trip and eliminate all secondary side feed to a single S/G, this is worthy of consideration as an initiating event.

AS-12 AS-A5 Currently, shutdown cooling is This finding was reviewed and The response for resolution is credited as a long-term cooling closed with no further action. inadequate. The LOCA for which method to eliminate the re- 3. Implementation Item:

SOC is used needs circulation requirement on To enter SOC during the course of documentation that the RWST is Finding AS-12 will be closed in certain ranges of LOCA breaks. mitigating a LOCA, an RCS level of still available for makeup. If the 30% in the Pressurizer is required accordance with Appendix X to NEI A certain amount of water must RWST is depleted, then the only 05-04, NEI 07-12 and NEI 12-13, be above the bottom of the hot by EOP-3. Further, once SOC has other source for water for long been entered AOP-03-02 requires "Close-out of Facts and leg to avoid drawing vapor into term cooling would be the Observations."

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

above this critical point. in the above referenced condition The AS notebook should is procedurally not allowed and document the basis for the range This calculation could be quite physically not possible. Therefore of LOCA sizes that can credit simple: 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-2018-215 Attachment 1 Page 4 of 36 Disposition and Resolution of Open F&Os cooling entry conditions, open, pending incorporation of determine the leakage rate at the documentation.

point, verify the RCS level will be adequate for the remaining part of the 24 hr mission without re-circulation or RCS make-up.

If this is not true, then addition make-up must be modeled through the emergency sump or eves.

AS-13 AS-A2 The PORVs are only assumed to This finding has been resolved and The PRA model fault tree was The current working model is revised lift given total loss of secondary closed by an update to the reviewed. It was confirmed that to increase fidelity and level of details side heat removal or a loss of model/documentation. several other initiators other than associated with anticipatory trip load with 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 appears non-conservative. considers only the assumed power would cause the PORVs to calculation. The current working model The only loss of load trips scenario. There are other lift. This was determined by will be revised prior to use for RICT considered are TT and loss of scenarios that were considered to reviewing the logic under gate calculations.

off-site power trips. This is based challenge the PORVs. See logic U 1QT03 and the ATWS logic on an informal calculation that under gate U1 QT03. Input on trips (U1 P01). However, the use of a 4. Implementation Item:

shows the RCS pressure likely to challenge PORVs were single event ('NLCD1TURB') for Model revision and associated exceeds 2300 psia, but stays received from fuels group and the anticipatory trip function was documentation are an implementation below the PORV open set point incorporated throughout the model not addressed. No item.

of 2400 psia. This does not update process. documentation for the basis for consider variations in the time this event is included in the delay between the turbine trip notebook. Until the anticipatory and the reactor trip nor does it trip is modeled in more detail or consider variations in the PRZ further documentation of the pressure set point. Consideration basis for a single event is of these variables may lead the provided, this F&O is considered analyst to conclude that the to be open.

likelihood of a PORV lift during this condition is much larger than analyzed.

Further, the portion of the tree (under Gate U 1QT99) that models the circuitry associated with the antici ato tri onl

L-2018-215 Attachment 1 Page 5 of 36 Disposition and Resolution of Open F&Os Finding .ResolUtions Provided to Independent Re'/iewFo(Finding Closure contains a single basic event. No other support system dependencies appear. For example, does the status of pressurizer spray affect this calculation? Are there support system failures that could cause a loss of load and disable or degrade the anticipatory trip function?

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

01 coincident unavailability for inter- closed with no further action. Rev.5 provides justification for Clarification to existing documents is systems was considered. lack of inter-system unavailability. required to close this finding. There is However, there was no clear This SR requires "EXAMINING" There are some non-staggered no impact to RICT calculations.

documentation to demonstrate coincident unavailability due to tasks which could be done at the maintenance for redundant same time so it looks like there such treatment.

equipment (both intrasystem and are some inter-system Coincident unavailability due to intersystem) that is a result of a maintenance which could be maintenance 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 system) 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.

Therefore, the calculation of is no coincident unavailability of coincident unavailabilities for "PLANNED" and "REPETITIVE" However, the resolution should intra-systems as a result of maintenance for redundant point to the administrative planned and repetitive activities equipment (both intrasystem and procedures that preclude such was not calculated. There was intersystem) to be allowed, per coincident unavailability. Further, no clear documentation on the plant T/S, procedure, guidelines, the discussions referred to in the treatment of coincident and instructions. GDOC Description should be unavailability for inter-systems. documented somewhere in the Discussion with the utility PRA actual data notebook. This F&O staff indicated that review of the should remain open.

plant operating history was performed to identify potential coincident unavailability for inter-systems. No such unavailabilities were identified. The PRA staff also demonstrated that the PRA

L-2018-215 Attachment 1 Page 6 of 36 model accounts for coincident unavailability for inter-systems by the use of appropriate mutually exclusive logic.

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

01 identified between the Rev 1, and PSL-BFJR-17-029 Rev BFJR-08-003, Revision 1 was Clarification to existing documents is documentation, the HRA 0. reviewed along with the PSL required to close this finding. There is calculator file and the CAFTA GDOC draft revision (rev. 1) that no impact to RICT calculations.

model; one example is provides the updated closure AHFL 1CST IV, which is indicated basis for this finding. A spot-as 2.7E-5 in the summary table check of the Unit 1 and 2 pre-3.0 while appears to have the initiator mean values identified in floor value from ASEP in the Tables 19 and 20 of document HRA calculator file (i.e., 1E-5) 08-003-Rev.1 were checked (See F&O HR-01-01). against the CAFTA.rr basic events for consistency. All basic A more conservative value has event values input to the CAFTA ben entered in the model, with model were found to be respect of what the HRA consistent.

calculator 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-2018-215 Attachment 1 Page 7 of 36

.Disposition and Resolution ofOpen F&Os Finding Resolutions Provided to Fi!'lding** Supporting Independent Review Description Independent Review For Finding Disposition for RICT Number Requirement *.* ..

Comments Closure .** ...

/

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 forward 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 SR is associated with the The latest revision of HRA analysis Documents PSL-BFJR-11-013 This is a documentation issue.

documentation of the process included use of revised and PSL-BFJR-17-029 were Clarification to existing documents is used to identify, characterize, dependency analysis methodology reviewed. In document PSL- required to close this finding. There is and quantify 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 actions considered in the PRA dependencies between HFEs that the dependency analysis is including the inputs, methods are considered in HRA Calculator. discussed, how the joint HEP and results. Although the overall The HRA Analysis document floor was applied, and how HRA analysis looks very good, included detailed steps taken to unanalyzed combinations were the current documentation for generate the revised dependency identified and treated. In the dependency analysis and analysis. Resolved in PSL-BFJR- document PSL-BFJR-17-029, treatment of post-initiator HRAs11-013 Rev 4. section 7.0, the methodology for is incomplete. The current the dependency analysis is documentation only states that discussed. Since PSL-BFJR all post-initiator HEPs are set to 013 is not signed this F&O is 1.0 and then fed into the HRA considered open. When the calculator to determine the document is signed and approved dependency between the HEP the F&O can be closed.

events. There is no discussion of Comments how the rest of the process is The performance of the performed, including how the dependency analysis may not HRA Recovery File is used to conform to the industry accepted

L-2018-215 Attachment 1 Page 8 of 36 Disposition and Resolution.ofOpen F&Os "reset" combination events to the practice (EPRI HRA calculator appropriate values based on the manual Chapter 17). The values dependency analysis, no for each HFE should be set at a discussion on why the HEP value as close to 1 as possible values in the BE file are set to (typically 0.99) so that the most 0.5, no discussion of how the HFE combinations possible are HRA calculators dependency capture in the cutsets produced at analysis was validated, etc. the truncation level of the model Additionally, there is no being analyzed.

assurance that all HEP The PSL dependency analysis combinations have been used 0.5 as the value for HFEs.

identified 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 There is no discussion on model This finding has been resolved and Documents PSL-BFJR-11-013 This is a documentation issue.

related uncertainties for pre- closed by an update to the and PSL-BFJR-17-029 were Clarification to existing documents is initiator HRA calculations. For model/documentation. reviewed. In document PSL- required to close this finding. There is post-initiator HFE, the EF BFJR-11-013, Section 3.3 the no impact to RICT calculations.

Pre-initiator and post-initiator HFE indicated in Table 9 are then not uncertainty analysis is discussed.

EFs were added to CAFTA RR-file propagated in the CAFTA file. It This provides the basis for the EF so UNCERT can use them in the is therefore not clear how the section and application and also uncertainty calculations.

uncertainty parameters are provides high-level sources of Discussion of HRA EF treated in the model. uncertainties and assumptions uncertainties is provided in the PSL applied to the HRA. This section A complete uncertainty HRA analysis document. Resolved was reviewed and provides assessment involves both in PSL-BFJR-11-013 Rev 4.

reasonable development of the stochastic uncertainties EFs that have been applied in the (included in the HRA calculator)

CAFTA .rr file. The CAFTA .rr file

L-2018-215 Attachment 1 Page 9 of 36 Disposition and Resolution of Open. F&Os Finding*Resolutions Provided to Independent Review lndependentReviewFor.Finding CommentS Closure and epistemic (model) was spot-checked for application uncertainties. A discussion on of EFs, which appear to be the assumptions made in the consistently applied. No issued analysis and their potential for identified during the review. In impact on the HEP calculations addition, the process to document is required to meet the SR. sources of model uncertainty and related assumptions is consistent The inconsistency between the with SR HR-13 and HR-06 for EF discussed in the post-initiator assessment of uncertainty in the HRA notebook (table 9 in HEPs.

Section 3.3) and the actual CAFTA file does not allow a In document PSL-BFJR-17-029, correct uncertainty analysis. which is still in draft form, there is Table 9 states that generic Error no discussion of uncertainty. The Factors are used, but there are assumptions are included as part no error factors in the BE file, so of the HRA Calculator it is unclear how the error factors documentation. The SR requires are propagated. Also, the uncertainty to be addressed. This Combination events, and the F&O is considered to still be renamed post-initiator single open.

events are not included in the BE file so it is unclear how their error factors are included in the analysis - or if they are even considered.

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

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

frequency expectation for BFJR-15-014, Rev 2 ISLOCA document PSL-BFJR-screening. 07-06, which included screening of penetrations based on Define the estimate for the lines perceived low frequency. Section

L-2018-215 Attachment 1 Page 10 o£36 Disposition and Resolution of Open F&Os Finding Resolutions .Provided to Independent Review For Finding*

Closure screened on low frequency and 2.1 of the RSC report says, "The show that the calculated scope of the modeling change frequency 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 fault tree model used for the This finding was resolved by PSL document RSC 14-05, "Inter- This is a documentation issue.

ISLOCA paths assumes that the analysis update document Systems LOCA Update", was Clarification to existing documents is status 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 the corresponding exposure BFJR-15-014, Rev 2 account for the status of each time is the refueling interval. isolation valve when estimating However, based on discussions the ISLOCA frequency. However, with knowledgeable staff, there PSL-BFJR-15-014 Rev. 2 does is no positive means to know not include evidence that the that more than one isolation quantitative screening criteria was valve is actually holding. Use of addressed in this document.

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

flow test which may not occur on

L-2018-215 Attachment 1 Page 11 of36 Disposition and. Resolution of Open F&Os Finding Resolutions Provided to Independent Review For ~in ding Closure a refueling basis but based on other studies could be as much as the life of the plant.

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

quantification report are blank closed by an update to the of incomplete sections in the PSL Clarification to existing documents is with a "later" in place of the table model/documentation. quantification notebook. The required to close this finding. There is or results. 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-2018-215 Attachment 1 Page 12 o£36 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 uncertainty 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 Unit 1 or Unit 2 model/documentation. for the PSL quantification results. required to close this finding. There is quantification 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-SNBK-QU, Revision 0) includes the results of the parametric uncertainty evaluations for CDF

L-2018-215 Attachment 1 Page 13 of 36 Disposition and Resolution of Open F&Os 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 CCF of ICW traveling This finding has been resolved and Based on review of PSL-BFJR- 5. Implementation Item 12 screen plugging and the CCF of closed by an update to the 06-008 (Quantification of Finding SL-CCF-12 will be closed in ICW strainers plugging as model/documentation. Common-Cause Failure accordance with Appendix X to NEI contributors to the loss of ICW The PSL models were revised to Probabilities), CCF of the ICW 05-04, NEI 07-12 and NEI12-13, initiator fault tree are missing include CCF of ICW traveling traveling screen plugging and "Close-out of Facts and from the model and no screen plugging and the CCF of strainer plugging from

L-2018-215 Attachment 1 Page 14 of36 Disposition and Resolution C>fOpen.F&Os Finding Resolutions Provided to.

Independent Review For Finding Closure explanation for their absence is ICW strainers plugging as environmental impacts has been provided. Common cause contributors to the loss of ICW assessed; however these impacts contributors to the loss of ICW system. They were not considered are included in the loss of ICW are judged to be both credible under IE fault tree to eliminate mitigative fault tree and are not and potentially risk-significant. double-counting. Calc PSL-BFJR- included in the loss of ICW This judgment is based on the 15-014. initiating event fault tree so as to failure of a intake screen avoid "double counting" of the reported in LER 84-09, 1011/84 impact. Because of the (Unit 1), the fact that these suspected double counting issue, issues are addressed in the plant the PSL PRA model does not Off-Nominal Operating include consideration of CCFs in Procedure 064030, and that data any of the initiating event fault is available for both of these trees. This appears to be failures in the NRC CCF contrary to general industry database. Given that common practice and guidance contained cause is likely to be a dominant in EPRI TR-1016741, "Support contributor to the loss of ICW System Initiating Events", and and that the nominal loss of ICW WCAP-16872 "Pilot frequency 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 for any CC level on CCF. that CCF event combinations Basis for Significance: associated with operating This F&O was assigned a equipment are assigned a Significance of A due to its mission time of one year and potential risk significance. combinations of CCF events of Additional Discussion: secondary standby equipment are This finding applies to both St. assigned a mission time as Lucie Unit 1 and 2 PRA models appropriate (e.g., mean time to repair). This finding is considered to remain open pending further explanation and justification for

L-2018-215 Attachment 1 Page 15 of 36 Disposition and Resolution of Open F&Os Independent Review 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 control 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 tree the AFW flow control personnel, AFAS would start discusses the justification for AFW system components are system is demanded 3 times, but pumps and open flow valves to using 3 demands for the failure developed with greater level of details the basis for using 3 demands is provide AFW flow to SGs. Small calculation. It should be noted in the current PRA model.

unclear. 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 cause 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 demand. cycles would be adequate to documentation and may not be closure documents is required to close The model does not differentiate capture or bound the total valve accurate. Also, the logic that this finding. There is no impact to between an overfill and under fill. failure prob. opens and closes these valves is RICT calculations.

Overfills in general could lead to not modeled. This F&O has not the failure of the turbine driven been addressed. This F&O is AFWpumps. considered to still be open.

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

But it is also clear the failure likelihood will increase. Given the importance of the AFW

L-2018-215 Attachment 1 Page 16 of 36 Disposition and . Resolution of Open F&Os ..

Finding Resolutions Provided to I Finding . * * **.***supporting Independent Review Description Independent Review For Finding **Disposition for .RICT Number Requirement Comments 1.

....... Closure MOVs, any increase to the failure rates can be quite significant.

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

Parameter methodology for closed by an update to the (Quantification of Common- Clarification to existing documents common cause analysis has model/documentation. Cause Failure Probabilities) and with example is required to close this resulted in conditions that The latest revision of CCF analysis PSL-BFJR-15-014 (Model Update finding. There is no impact to RICT appear to be an over estimation document clearly describes the Document) were reviewed. 06- calculations.

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

[three AFW pump discharge the 4/4 component CCF check valves] is more likely than probabilities are higher (more the common cause failure of two likely to occur) than the 3/4 check valves [two MFW check component failure probabilities.

valves to the steam generators 1- In the case of the recently added V09294 and I-V09252]). The EER fans failure-to-run CCF, the implementation of the 3/3 failure probability is slightly methodology includes an higher than the 2/3 failure assumption in the development probability. This was the subject of the parameters of staggered of the finding and was not testing. This assumption may be explained in the referenced CCF non-conservative. 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

L-2018-215 Attachment 1 Page 17 o£36 lndependenfR~vlew conilh~ht~

bi~~b~ition for RICT was not considered and factor anomaly.

justification provided for not including them was not included.

Some of the issues may be the result of the use of component specific and generic alpha parameter data.

Internal FloodP~ JV19~el Findings The consideration of human- This finding was reviewed and induced floods was not included closed with no further action. PSL-BFJR-11-006 Rev. 0 were Clarification to existing documents is in the internal flooding As noted in the main Flooding reviewed. This F&O is very required to close this finding. There is evaluation. Analysis document, no condition similar to F&O IE-51. In general, no impact to RICT calculations.

The consideration of human- reports that would reflect such human-induced flooding is not induced floods was not included problems, associated with the considered in the analysis. Only in the 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 provided generic data for likelihood of flooding, were to be was considered credible and this flood initiating event frequencies found. This possibility was was screened from further stated that "Human induced reviewed with experienced plant consideration. The fact that a causes of flooding that do not staff after the peer review that human-induced flood has not involve piping system pressure identified one issue "the periodic occurred at PSL to-date is not boundary failure such as transfer of waste water from Unit 2 sufficient rationale to screen such overfilling 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 release fluid from the issue. PSL-BFJR-11-006, Rev 0 resolution that plant personnel system 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

L-2018-215 Attachment 1 Page 18 of 36 Disposition and Resolution of()pen F&Os Finding Resolutions Provided to Independent Review For Finding Closure to remain open.

IFPP-B1- IFPP-A5 The documentation associated This finding was reviewed and PSL-BFJR-11-005 Rev. 0 and This is a documentation issue.

01 with the plant partitioning is closed with no further action. PSL-BFJR-11-006 Rev. 0 were Clarification to existing documents is scattered between the initial reviewed. The flooding analysis required to close this finding. There is No flood zones or flood sources portion of the document and the report (PSL-BFJR-11-005) now no impact to RICT calculations.

located within the reactor auxiliary walkdown report in Attachment includes some additional building were screened out. The B, which in reality is a discussion discussion of other plant buildings flooding analysis document was of the screening of main (such as the EDG buildings, CCW further revised to address flooding structures such as major building, etc.). The discussions in originating in the other buildings or structures. Section 4.4 of the notebook areas even if this is not truly address the "other buildings" The walkdown report does not "internal" flooding. These do not concerns noted in this F&O.

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

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

area identification and the The pipe size (i.e. 1" or smaller) screening are mixed, some should be specified. Also, the overlook have been noticed. For screening criteria in general are example, the walkdown notes used but do not appear to be explicitly 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 BLDG is only discussed in Table 6 lists the flood zones that the walkdown report and they are considered in each unit for are all screened out on the basis analysis. However, the Unit 1 that there is no service water condensate pump pit is listed as a

L-2018-215 Attachment 1 Page 19 of 36 Oispo$iti6n and Resolution of Open F&Os Finding Resolutions Provided to Independent Review Independent Review.F9r Finding Comments Closure (DG are air cooled); there is flood area, but the Unit 2 pump pit nevertheless no mention of the is not. Section 4.4.1 implies that potential spray effects of Fire all turbine building floods are Protection system on a single neglected. The documentation DG (FP lines have been noticed should be checked to ensure the during the walkdown that may turbine building zones are have the potential to spray on accurately listed.

the DG cabinet). While the screening of the DG BLD may still be possible (FP lines may be dry since there are large FP valves immediately outside of the DG building that may be deluge valve, or the DG AOT may be sufficient to recover from a spray event on the DG cabinet), the presence of a flood source that has the potential for impacting PRA equipment needs to be addressed.

The screening out of the Turbine Building is another example of screening process inconsistent with the screening criteria provided in the standard. While it is true that the TB BDLG is open, a rupture in the condenser expansion joints will induce an initiating event and for this reason the area cannot be screened out for flood considerations. The flood

L-2018-215 Attachment 1 Page 20 o£36 Disposition ahd Resolution of Open* F&Os scenario generated by a rupture of the condenser expansion joint may be screened for other reasons (e.g., it may be folded into an already existing IE category with identical plant effect but higher IEF), still a discussion of the reasoning and of the screening criteria needs to be provided.

Finally, section 4.1.1 points to the walkdown notes but incorrectly indicating Attachment C rather 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 mapping between the flood closed with no further action. flooding quantification notebook Clarification to existing documents is events and the basic events were reviewed. The Unit 1 required to close this finding. Although Mapping between impacted associated with impacted results no longer show a flood- there are differences between the components and associated basic equipment has been identified. induced ATWS as a dominant units, mapping in Unit 2 will be verified events was reviewed to ensure that According to table 20, the top contributor; however, failures of to be consistent with mapping in Unit the flood induce failure is cutsets have to do with ATWS both trains of batteries (due to a 1. There is no impact to RICT consistent with the failure mode induced by a spray event on the potential spray event, as well as a calculations.

modeled in the PRA model.

reactor trip switchgear. Spray on flood event) continue to dominate.

Changes to the mapping tables the reactor trip switchgear would While the flood event may be were implemented to address the result in loss of power, which credible, a spray event that fails concerns of this F&O. The one would result in the trip itself. both trains of DC seems inconsistency related to the spray Therefore, even though the conservative. For Unit 2, flood-event affecting the trip switchgear reactor trip switchgears are induced ATWS remains a has been corrected.

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

L-2018-215 Attachment 1 Page 21 of 36 Disposition and Resolution of Open*F&Os Independent Review Comments switchgear because their failure considered to still be open, is in the direction of the success. flood emanating from the battery pending confirmation that the rooms to the neighboring flooding results have been Another example of suspect switchgear rooms through the checked for consistency with the inconsistency in the mapping is connecting doors and submerging as-built plant.

observed from the review of the various electrical components main CDF contributors. A spray inside. Since the analysis does not from room 1RAB43-59/58 is not credit isolation of the break, the expected 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 evidence was provided to This finding was reviewed and PSL Internal Flooding PRA This is a documentation issue.

01 indicate that human-induced closed with no further action. document PSL-BFJR-11-05 was Clarification to existing documents is mechanisms were considered to reviewed. The report and PSL required to close this finding. There is As noted in the main Flooding determine their impact as F&O GDOC acknowledged that a no impact to RICT calculations.

Analysis document PSL-BFJR potential sources of flooding. CR review was performed (CR 005, Rev 0, no condition reports review identified no human-The flooding notebook indicated that would reflect such problems, induced events) and discussions that the EPRI guideline, as associated with the possibility that held with plarit personnel. The documented in report 1019194, plant design and operation potential for waste water flooding was used in performing the practices might affect the likelihood was mentioned in the scenario for flooding analysis. The EPRI of flooding, were to be found. This the rupture of the waste Guidance identified the flooding possibility was reviewed with management system in the waste mechanism that would result in a experienced plant staff after the holdup tank rooms. Although release. No evidence could be peer review who identified one there is some mention of human-found on the treatment of issue "the periodic transfer of induced interaction, the report human-induced flooding. It waste water from Unit 2 to Unit 1."

L-2018-215 Attachment 1 Page 22 o£36

~isposition and Resolution of OpenF&Os

• Finding Resolutions Provided to

• Independent Review Independent Review For Finding Comments Closure appears that only pipe failures were considered as flooding to address the issue. thorough review of the PSL plant-mechanism. 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-2018-215 Attachment 1 Page 23 of 36 Disposition and Resolution of Ope~ f&ps

/ >: .*::

• .**** .. Finding Resolutions.Providedto .* ..

Finding Suppe>~ing lndependent.Revi~w 1

• • * ** Description Independent ReviewFor Finding Dispositi<)h for RICT Number Reqoir~ment

• Comments

• Closure IFSO-A6- IFSO-A6 Confirmatory walkdown to This finding has been resolved and The GDOC response for this F&O This is *****a documentation issue.

01 assess the accuracy of the closed by an update to the indicates that new walkdowns Clarification to existing documents is information associated with the model/documentation. were performed and flood source required to close this finding. There is source identification and and scenario calculations were no impact to RICT calculations.

Confirmatory partial-walkdowns scenario definition were not updated to reflect the were performed after development performed. new/corrected information. The of this F&O and pipe isometric flooding notebook indicates that One walkdown was performed drawings were re-reviewed for some of the original battery room before the identification of the accuracy. The walkdown revealed sources were deleted (see for flood source 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 confirmed during a dedicated 43' are hidden within a pipe chase sources and scenarios for the confirmatory walkdown. Some near the ceiling and therefore not Unit 2 ECCS rooms also appears potential inconsistencies visible. As a result, the analysis to be complete. The Appendix A between the isometric drawings has been corrected by deleting the flooding spreadsheet appears to used for 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 configuration has been observed battery rooms. Any water from specific documentation during the peer review postulated breaks inside the chase concerning the walkdowns walkdown. For example was assumed to divert from the performed to support the flooding Appendix A indicates more than battery rooms to the adjoining analysis. Appendix B is referred 138' of CC piping in the U2 rooms. However, the water supply to as providing the walkdown Battery room A (2RAB43-35) but pipe to the shower station was notes, but it states that there are no CC 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 the other hand, demin water spreadsheet calculating rupture walkdown(s) is mentioned in the lines to 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 review walkdown in the corrected the input to FRANX.

walkdown notes available in battery room, which are not 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 show OW lines although it is PSL-BFJR-11-006, Rev 0.

considered to remain open,

L-2018-215 Attachment 1 Page 24 o£36

':*c ,, ,, ,

pi~position for RICf expected that eyewash station pending addition of information are also present and they are pertaining to the initial and indeed shown in the architectural subsequent walkdowns.

drawing). In 2RAB43-36, the batteries are mentioned to be potentially vulnerable to spray from fire protection but no fire protection is listed as potential source in the room.

Appendix A shows multiple examples of datasheet being incomplete even for critical rooms such as the ECCS rooms (see for example 2RAB-10-16B) that would challenge the selection of impacted equipment.

Fir~ P.RAModel Findings 4kV power and 125VDC control Reviewed component failure PSL-BFJR-16-039, PSL Fire PRA This is a documentation issue.

01 cables required to support the modes to ensure that components Component and PSL-BFJR Clarification to existing documents is operation of the Containment for which operation is credited 039, PSL Fire PRA Component required to close this finding. There is Spray Pump were not identified. include required power cables. and Cable Selection, was no impact to RICT calculations.

Fire PRA Plant Response model PSL-BFJR-16-039 reviewed. No list of components and other Fire PRA support added based on the MSO expert tasks are adversely affected. panel was available. As such, no Perform a comparison of the review of the cable selection components identified on the performed for these components MSO (multiple spurious could be done.

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

L-2018-215 Attachment 1 Page 25 o£36

...* Disposition and Resolution of Open F&Os Finding Resolutiol'ls Provided to Finding Suppqrting : Independent Review Description lndependentgevi~W For Finding* DispositiorlfofRICT

.... Nul11ber . ~e9uireffient

• .*.* ............ . Closure Comments 1

identified on the Appendix R safe shutdown equipment list). Verify that the cable selection for the common components supports all credited operations.

Fire PRA Plant Response model and other Fire PRA support tasks are adversely affected.

CS CS-81 No evaluation 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 cables associated with the performed including those power was reviewed. Section 3.0, Cable required to close this finding. There is Fire PRA is bounded by the supplies associated with Fire PRA Selection, contains the following no impact to RICT calculations.

existing overcurrent coordination components. text, "A review of power supplies analysis. for active components was performed and required power The evaluation was not 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-D1- ES-D1 Pl-03-003 provides instruction SSD and FPRA documentation PSL-8FJR-16-039, PSL Fire PRA This is a documentation issue.

01 for circuit analysis to include revised to provide enhanced Component and Cable Selection, Clarification to existing documents is review of interlocks, documentation of component was reviewed. Section 3 of the required to close this finding. There is instrumentation, and support selection and cable selection. report states, "A review of power no impact to RICT calculations.

system dependencies. Cable supplies for active components routing database was reviewed was performed and required and confirmed that interlocks, One set of SSD instrumentation will power supplies were also added

L-2018-215 Attachment 1 Page 26 of 36 Disposition and Resolution of Open f&Os Finding Resolutions Provided to Independent Review lndependentReview ForFinding Comments closure instrumentation, and support remains available to meet SSD to the FPRA component/cable system cables were included in systems for an area wide fire. The data. The circuit analysis equipment effects. correlation between SSD performed for the original safe instrumentation and operator shutdown analysis as well as for However, demonstration of a actions provided in the HRA report the FPRA components included review of power supplies, etc.

confirms that for each HFE the identification of cables was not readily apparent in the Appendix R instrumentation is associated with interlocks and Component Selection report.

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

however, it is important to instruments. Since the Appendix 8 of the report document this information to instrumentation availability is describes the review of Safe support peer reviews and defined on a fire area wide fire Shutdown equipment for applications. basis it will provide a conservative individual disposition for basis for instrumentation available It is suggested that document applicability in the FPRA. One for an individual scenario within the the review to show the criteria for inclusion in the FPRA fire area. Incorporated additional interlocks, power supplies, etc. is the equipment's function is discussion in HRA report, Section are included (or referenced) in related to reaching the safe and 3.

the development of the stable end state of hot shutdown, Component 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 states that SSEL equipment specific HEPs are being added to safe and stable end state. This required to place the plant in hot the quantification fault tree portion of the F&O is also met.

standby, the PRA end state, are including instrumentation cues. The included in the analysis while However, no connection to a fire-required cues were correlated to equipment only associated with related reactor trip or any SSD analysis instrumentation taking the plant to cold shutdown discussion related to how fire which is identified as available were excluded from analysis. impacts propagate through the instrumentation in the post-fire No information is provided to logic model could be found other shutdown procedures. This facilitate the assignment of than the following statement,

L-2018-215 Attachment 1 Page 27 o£36 Disposition and Resolution ofOpen F&Os Finding Resolution~ Provided to I Finding ~~PPprting I.*.* Independent *Review.

Description . lndepeQdenf Review For Finding Disposition for RICT Numb~r Requirement *..

Comments

• . *. *.>****** . . . Closure .. ....*

.. ***.****** ************ ..*. *.1

/

individual SSEL instrumentation imposes a failure of the HEP in any "Disposition codes were only to specific plant states, which scenario where all associated cues assigned to basic events that are complicates 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 NUREG-1921, specifically fault tree to allow FPRA Expand Component and Cable discussion regarding failure of cues quantification to capture the Selection tables to allow SSEL due to fire in accordance with impact of fire related initiating components to be associated NUREG-1921 section 4.5.5. events could be found. Since this with specific plant states.

does not fully meet the intent of ii. The fire specific HEPs have also Components are linked to fault SR ES-D1, this F&O remains been correlated to the SSA tree Basic Events, but suggest open.

instrumentation. The cues for these document all potential fire HEPs have also been incorporated induced sequences are into the fire PRA fault tree.

confirmed to be associated with a reactor trip initiating event in iii. The development of the fire the fault tree. specific HEPs included the review of post fire shutdown procedures.

Improve component selection Revisions to these procedures to report 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 did not postulate hydrogen Hydrogen for VCT tank isolated PSL-BFJR-16-042, PSL Fire PRA PSL Fire PRA model requires the 01 (H2) fires other than the turbine from other equipment components. Scenario Development, was addition of fire scenarios associated generator 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.

contains excess flow check Located in outdoor area thus various types of hydrogen fires. These scenarios are for a hydrogen valves. However, this will not limiting impact of this fire. Section 8.5, Scenario fire associated with the turbine prevent H2 fires. It's likely that Nomenclature, states that generator. Since the turbine generator

i. The hydrogen system at St. Lucie plants experiencing H2 fires that scenario names including "H2" is in an open environment, the risk provides hydrogen to the chemistry contributed to the "potentially are scenarios associated with impact of this scenario is minimal.

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

L-2018-215 Attachment 1 Page 28 o£36 had excess flow check valves. These systems are provided with scenarios were identified with the Implementation Item:

Recommend either postulating pressure monitoring, guard piping "H2" designation in the report and Model revision and associated H2 fires or developing a stronger and excess flow check valves the FRANX model. documentation are an implementation technical justification for their which preclude the release of a item.

PSL-BFJR-16-040, PSL Fire PRA exclusion. significant quantity of hydrogen Task 1 & 6 Plant Partitioning and which could cause a challenging PSL did not appear consider all FIF, was reviewed to determine fire. The design basis for these pump lube oil fire scenarios where the fire frequency for bin lines in the event of a complete line (e.g., AFW pumps, Charging 34, Turbine Generator Hydrogen, break is for the hydrogen Pumps, HPSI pumps, LPSI was accounted for. This concentration to be limited to no pumps, MFW pumps, etc.). frequency was documented in fire more than 2% hydrogen (Unit 1 These scenarios often involve zones 1-23 & 2-47(8) the LP UFSAR Appendix 9.5A Section significant quantities of oil Heater Area for Units 1 & 2 3.15.2 and Unit 2 UFSAR Appendix causing widespread damage in respectively; however no fire 9.5A Section 3.15.1). This is a the fire compartment. They can scenario with this ignition safety factor of 2 to the flammable also contribute to multi- frequency applied could be found limit for hydrogen in air. Therefore, compartment fire risk. in the scenario report or FRANX based on these design features no model.

Note that some lube oil specific scenarios associated with scenarios appear to have been a miscellaneous hydrogen fire are Sections 6.5 & 6.6.3 of the considered by PSL. Specifically, postulated. scenario development report MFW and turbine lube oil fires describes the treatment of oil spill ii. The current Fire PRA does not were postulated. In speaking fires. Fire ignition frequency for exclude any flammable liquid fire with the analysts, they indicated Bin 35, Turbine Generator Oil, is scenarios for fixed fire sources that that other pumps tend not to documented in two fire zones, 1-may contain combustible liquids. A have large quantities of lube oil 13 & 2-11 the Turbine Lube Oil review of the fire scenarios for and that source-target data for Reservoir for Units 1 and 2 pumps containing significant oil scenarios was often collected respectively, but no scenarios in quantities of oil identified existing during walkdowns. However, those fire zones have a Bin 35 scenarios for the Circulating Water there was little documentation of contribution to their fire ignition Pumps, Main Feedwater Pumps, this, and very few oil scenarios frequency. In addition, only the Heater Drain Pumps and were quantified in FRANC. RCP fires were identified in the Condensate pumps. A comparison report. The documentation of the PSL did not postulate H2 fires between Unit 1 and Unit 2 oil fires in the PRA model is not

L-2018-215 Attachment 1 Page 29 of 36 and oil fires as specified by identified several missing scenarios evident.

NUREG/CR-6850, and minimal for Unit 2 which were walked down open due to the identified issues basis for this deviation was and added to the Fire PRA. Diesel with both hydrogen and oil fires.

provided. These fires can be risk generator fire scenarios are base significant due to the potential for scenarios which include the impact widespread damage in the fire of a fire given that all targets in the compartment. 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 several cases, PSL Beyond 6850 methods, panel PSL-BFJR-16-042, PSL Fire PRA This is a documentation issue.

01 implemented 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 industry accepted guidance has a reference to the use of un- no impact to RICT calculations.

The use of the 69 kW HRR for documents (e.g., NUREG/CR- reviewed methods in the fire PRA transient fires has been limited to 6850 and its supplements). For model. Section 7.1 describes the those fire zones in which "zero example, PSL created their own treatment of transient HRRs. The transients" are allowed in order to multipliers I severity factors for use of 69kW transient fires was account for the potential violation of fires that cause damage beyond eliminated and replaced with the the administrative controls.

the ignition source by reviewing accepted 317kW fires from the EPRI 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" modeled 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 distribution, which is much damage and time to hot gas layer transient fires. Section 8.1 smaller than the transient fire (HGL). The time to target damage describes the application of distribution. A third example is evaluates the direct heat flux severity factors based on

L-2018-215 Attachment 1 Page 30 of 36 Finding Resolutions Provided to Independent Review ForFinding Closure not applying the "Location incident on a target due to the fire.

Factor" to account for wall/corner The time to HGL evaluates the factors was eliminated and effects on flame height and volume temperature effects due to wall/corner factors were applied plume temperature distribution. the fire. as appropriate. Section 7.5 states that the use of location While these methods seem The LAR-submitted model used the factors has not been applied to appropriate, documentation of approach that these two analyses increase heat release rates used the technical bases for these were independent of each other in the model, and this section methods was generally lacking. and therefore one was not needs to be updated to reflect the Methods beyond industry conditioned on. the other. The adjustment factors used in the accepted guidance (e.g., updated approach, generated to final PRA model. This F&O is NUREG/CR-6850 and its support the RAJ responses considered to remain open, supplements) should have considers the two analyses as pending revision of the section documented technical bases of dependent. Since the time to target 7.5 discussion.

similar quality and magnitude to damage in most cases is less than those provided in NUREG/CR- the time to HGL, the time to HGL is 6850. conditioned on the time to target damage. For example, consider a Also, PSL should be aware that time to target damage of 5 minutes methods beyond industry and a time to HGL of 30 minutes, in accepted guidance documents the context of the event tree in may be 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 appropriate, the level of nonsuppression (MS) distribution documentation provided did not from NUREG/CR-6850, allow detailed review by the peer Supplement 1, Chapter 14 with a reviewers. In addition, methods lambda value of 0.102 (electrical beyond industry accepted fires), the MSI probability is 0.602.

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

L-2018-215 Attachment 1 Page 31 of 36 Disposition and Resolution of Open F&Os 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-2018-215 Attachment 1 Page 32 of 36 Disposition and Resolutio.n of0pel1 F&Os 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-2014-109 (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-2018-215 Attachment 1 Page 33 of 36 Disposition ~11d Resolution ofOpen F&Os .** .... *..

Finding Resolutions Provided to Finding Supporting Independent Review .....

• Description Independent Review For Finding .Dispositiortfor. RICT Number RequireJl'lent Comments

• ... .* I Closure 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-2018-215 Attachment 1 Page 34 o£36 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-2018-215 Attachment 1 Page 35 of 36 Disposition and R~solution.ofOpen F&Os

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 review of modeled actions is The use of the screening approach PSL-BFJR-16-041, PSL Fire PRA Each operator action is developed 01 planned to be performed once for adjusting FPIE model HEPs and Human Failure Evaluation Report, based on analysis of the existing draft procedures are generated the use of screening HEPs is was reviewed. The report has not procedures. For the Fire PRA model, from the Fire PRA. However, at sufficient to support this been updated since the original new operator actions were developed present no such review has been application. peer review comment was made. for fire responses based on the performed except for a limited To satisfy capability category II of existing plant operating procedures, PSL-BFJR-16-041 board walkthrough documented the ASME/ANS standard, a things like local control of the AFW in Appendix C of the Human walkthrough with operators on the valves or aligning the fire protection Failure 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-2018-215 Attachment 1 Page 36 o£36 Disposition and Resoluti<)h ofOpen F&Os 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 Overall PRM documentation is Added discussion in PSL-BFJR-16-039, PSL Fire PRA This is a documentation issue.

01 sparse and doesn't provide the Component/Cable report Section Component and Cable Selection, Clarification to existing documents is information addressed in the 5.0. was reviewed. Insufficient required to close this finding. There is SRs associated with the HLRs information was added to section no impact to RICT calculations.

PSL-BFJR-16-039 described in the Category I, II 5.0 to describe the plant response and Ill criteria of PRM-C1. In model, or assumptions made. No addition, the development of discussion of initiating events, changes made in Tables 01 and accident sequence changes, 03 are not described (PRM-89). system model changes, LERF impacts, or any new operator Recommend a separate PRM actions was found. In addition, report that documents in a there is limited documentation of structured and consistent way the changes to the CAFTA model.

the requirements described in This F&O is considered to remain the PRM SRs open.

L-2018-215 Attachment 2 Page 1 o£3 Attachment 2 St. Lucie Unit 1 - Markup of the Operating License

L-2018-215 Attachment 2 Page 2 of3 INSERT J 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 change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

L-2018-215 Attachment 2 Page 3 of 3

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 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:

(a) Demonstrate that St. Lucie Unit 1 safety analyses remain conservatively 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.~

Revises ey lel:ter eateEI Marsl:l $1, 2Q1 a

L-2018-215 Attachment 3 Page 1 of 3 Attachment 3 St. Lucie Unit 2 - Markup of the Operating License

L-2018-215 Attachment 3 Page 2 of3 INSERTO

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 Info1med 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 Inf01mation 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 sL'C 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-2018-215 Attachment 3 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 21icensing 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 jiNSERT~ 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.

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

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. 4-Sr Re'v'ised ay letter dates Felmtal')' 13, 2017

L-2018-215 Attachment 4 Page 1 of2 Attachment 4 St. Lucie Unit 2- Markup ofTechnical Specification 3.6.1.3

L-2018-215 Attachment 4 Page 2 o£2 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 inoperabl~

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 '1'?"-"-:";---::;---:---:--:--:---:-c:-:--....,...,

in the affected air lock(s) and

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 H OWN.

~ ~ lock(s)

b. With tRe containment air leek= perable, except as the result of an inoperable air lock doo 1ntain at least one air lock door closed;- estore the inoperable air leek- OPERABLE status within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> eF e 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 SHUT 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 enter SHUTDOWN.

within the OT

otherwise, r

NOTE 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. ~, 88, 47G, 484