L-2018-001, Supplement to Response to Fourth Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide..

Supplement to Response to Fourth Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide..

ML18046A597
Person / Time
Site:	Turkey Point
Issue date:	02/15/2018
From:	Coffey R Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF5455, CAC MF5456, L-2018-001
Download: ML18046A597 (44)

Text

February 15, 2018 L-2018-001 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251 Supplement to Response to Fourth Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications 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-2014-369, License Amendment Request No. 236 Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B, December 23, 2014 (ML15029A297)

2. NRC E-mail Request for Additional Information re. Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456), April 14, 2016 (ML16105A459)

3. NRC E-mail Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456), April 18, 2016 (ML16110A004)

4. NRC E-mail Request for Additional Information re. Turkey Point 3 & 4 LAR-236 (CACs MF54555 & MF5456), June 1, 2016 (ML16154A339)

5. Florida Power & Light Company letter L-2016-116, Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b," June 16, 2016 (ML16180A178)

6. Florida Power & Light Company letter L-2016-136, Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, August 11, 2016 (ML16243A104)

Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035

Florida Power & Light Company L-2018-001 Page 2 of 3

7. Florida Power & Light Company letter L-2017-006, Supplement to License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times -

RITSTF Initiative 4b, February 9, 2017 (ML17060A249)

8. NRC E-mail Request for Additional Information Re. Turkey Point TSTF-505 LAR 236 (CACs MF5455 and MF5456) March 30, 2017

9. Florida Power & Light Company letter L 2017-063, Response to Third Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times -RITSTF Initiative 4b, April 27, 2017 (ML17117A618)

10. NRC E-mail Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456), August 10, 2017 (ML17223A061)

11. Florida Power & Light Company letter 2017-168 Response to Fourth Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, October 30, 2017 In Reference 1, as supplemented by References 5, 6, 7, 9, and 11, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 236 for Turkey Point Units 3 and 4. 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.

During a conference call on November 21, 2017, the NRC staff requested supplemental information to clarify the responses in Reference 11. The Enclosure to this letter provides FPLs response to the request for supplemental information. to the Enclosure provides markups of the operating licenses for Turkey Point Units 3 and 4 that add a license condition regarding PRA methods used in the Risk Informed Completion Time Program. These markups supersede the markups of the operating licenses in Reference 11. provides a markup of TS 6.8.4.n, Risk Informed Completion Time. This markup supersedes the markup of proposed TS 6.8.4.n, Risk Informed Completion Time, in Reference 11. contains a table showing disposition and resolution of open peer review findings and self-assessment open items.

This supplemental information 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.

Florida Power & Light Company L-2018-001 Page 3of3 Should you have any questions regarding this submittal, please contact Robert Hess, Licensing Manager, at (305) 246-4112.

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

Executed on February 1<;"" , 2018 Sincerely, Robert Coffey Regional Vice President - Southern Region Florida Power & Light Company Enclosure cc: NRC Regional Administrator, Region II NRC Senior Resident Inspector NRC Project Manager Ms. Cindy Becker, Florida Department of Health

Florida Power & Light Company L-2018-001 Enclosure Page 1 of 7 Response to Request for Supplemental Information The NRC staff requested Florida Power & Light (FPL) provide supplemental information for several answers included in the response to the request for additional information (RAI) submitted on October 30, 2017. This enclosure contains the relevant RAI questions and original FPL responses followed by additional information that supplements the original responses.

APLA RAI-2.01 Fire PRA In response to APLA RAI 02, the licensee stated that the fire PRA that will be used to support the risk-informed completion times (RICT) calculations will be the same fire PRA that was determined to be acceptable for the NFPA 805 transition and future self-approval. In a related response to APLA RAI 09, FPL states that [a]t the time of implementation of the RICT program, core damage frequency (CDF), and large early release frequency (LERF) will be estimated based on modifications completed for NFPA 805 as well as other changes in the model. The RICT program will only be implemented if it satisfies the limitations and conditions in Section 4, item 6 of the NEI 06-09

[safety evaluation].

As discussed in the May 28, 2015, safety evaluation on the amendment to transition the fire protection program to Section 50.48(c) of Title 10 of the Code of Federal Regulations (10 CFR), FPL used the guidance in frequently asked question (FAQ) 08-0046, "Closure of National Fire Protection Association 805 Frequently Asked Question 08-0046 Incipient Fire Detection Systems" to incorporate its very early warning fire detection system (VEWFDS) into the fire PRA. When FAQ 08-0046 was released, there was limited test data and PRA experience available for in-cabinet applications. In December 2016, the NRC staff published new guidance on modeling VEWFDS in NUREG-2180, "Determining the Effectiveness, Limitations, and Operator Response for Very Early Warning Fire Detection Systems in Nuclear Facilities, (Delores-VEWFIRE)," which resulted from a confirmatory research program (including the evaluation of recent operating experience) to advance the state of knowledge for in-cabinet applications. The research program was unable to confirm several key assumptions from FAQ 08-0046 that were used in the calculation of risk. Upon further evaluation of operating experience and the results of recent testing, the program determined that the risk reduction available for cabinet fires that are monitored by a VEWFDS system using the new assumptions was significantly reduced. The method provided in NUREG-2180 is more robust and technically justifiable. The methodology in NUREG-2180 is currently the best available guidance and replaces the guidance in FAQ 08-0046, which has been retired.

By letter dated November 17, 2016 (ADAMS Accession No. ML16253A111), the NRC staff informed the industry that, [i]f a licensee is performing a periodic or interim PRA update, performing a fire risk evaluation in support of self-approval, or submitting a future risk informed license amendment request, the staffs expectation is that they will assess the impact of new operating experience and information [e.g., NUREG-2180] on their PRA analyses and incorporate the change as appropriate per Regulatory Guide 1.200, Revision 2.

a) If FPL will use the methodology in NUREG-2180 please provide

Florida Power & Light Company L-2018-001 Enclosure Page 2 of 7

1. An estimate of the current CDF and LERF for all quantified hazards using the NUREG-2180 methodology in the fire PRA.

2. If the current CDF and LERF estimates do not satisfy the limitations and conditions in Section 4, item 6 of the NEI 06-09 safety evaluation explain how these guidelines will be met before implementation of the RICT program.

3. If the methodology (e.g., approach, methods, data, and assumptions) has not been incorporated into the fire PRA (i.e., PRA model changes and documentation completed and the upgrade peer reviewed), explain when it will be incorporated into the PRA model of record that will be used to estimate RICTs (response may reference the response to APLA RAI 15 which requests a list of implementation items).

b) If FPL proposes not to use the methodology in NUREG-2180 please provide:

1. Confirmation that the methodology in the retired FAQ 08-0046 is not the proposed methodology.

2. A description of the proposed methodology (e.g., approach, methods, data, and assumptions) that will be used in the fire PRA. The description should include a detailed comparison of that proposed methodology with the methodology in NUREG-2180.

3. Justification of the proposed methodology including comparison with available experimental results. Development and use of a proposed alternative may result in additional RAIs and significantly extend the time and resources required to complete the review.

4. An estimate of the current CDF and LERF for each quantified hazard with fire PRA results: (1) without credit for VEWFDS, (2) that would be obtained had the guidance in NUREG-2180 been applied, and (3) obtained using the proposed methodology.

5. If the current CDF and LERF estimates do not satisfy the limitations and conditions in Section 4, item 6 of the NEI 06-09 safety evaluation, explain how these guidelines will be met before implementation of the RICT program.

6. An evaluation on how using the proposed methodology instead of the NUREG-2180 methodology could impact the RICT estimates.

7. If the methodology (e.g., approach, methods, data, and assumptions) has not been incorporated into the fire PRA (i.e., PRA model changes and documentation completed and the upgrade peer reviewed), explain when it will be incorporated into the PRA model of record that will be used to calculate the RICTs (response may reference the response to APLA RAI 15 which requests list a of implementation items).

FPL Response a) FPL will follow the methodology in NUREG 2180 or the latest approved operating experience (OE).

1. A sensitivity study performed with NUREG 2180 for all quantified hazards indicate the result is slightly over the threshold for CDF. However, these results do not include credit for mitigating strategies. For example, there is currently no credit for local

Florida Power & Light Company L-2018-001 Enclosure Page 3 of 7 operation of the auxiliary feedwater pumps due to assumed loss of indication in Fire PRA. Additionally Flex mitigating strategy is not included in fire PRA. Considering these credits offsets any increase in risk due to incipient detection.

2. These guidelines will be met by continually incorporating operating experience and methodology enhancements into the fire PRA consistent with the maintenance and upgrade process.

3. The methodology in NUREG-2180 will be incorporated into the fire PRA model of record used to estimate RICTs as part of the next fire PRA model consistent with the maintenance and update process in Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.

b) Not applicable Supplemental Information The methodology in NUREG-2180 will be incorporated into the Turkey Point Fire PRA model. This update will include incorporation of the new event tree factors for the very early warning fire detection system (VEWFDS) as well as further refinements to the Fire PRA scenarios based on the conservatisms described below. These updates will be done using existing NRC approved Fire PRA methodologies.

The sensitivity evaluation for estimate of CDF and LERF for all quantified hazards with the NUREG-2180 methodology is as follows:

U3 CDF U3 LERF U4 CDF U4 LERF IE 7.18E-07 1.87E-08 7.13E-07 1.81E-08 IE Flood 1.62E-07 8.36E-10 1.13E-07 4.11E-10 Seismic 6.98E-07 6.98E-08 6.98E-07 6.98E-08 Fire 8.66E-05 5.35E-06 7.69E-05 4.85E-06 2180 Increase 1.03E-04 1.20E-05 1.03E-04 1.31E-05 Total with new fire 1.91E-04 1.74E-05 1.81E-04 1.80E-05 estimate Note: Seismic risk was evaluated based on plant-level High Confidence of Low Probability of Failure (HCLPF) using plant-specific data developed by EPRI. The bounding plant-level Seismic CDF is calculated as shown and LERF value is conservatively estimated as 10% of CDF value. See RAI-APLA-17, External Events, response As the current CDF and LERF estimates do not satisfy the limitations and conditions in Section 4, item 6 of the NEI 06-09 safety evaluation, additional refinements to the fire PRA are needed to meet these guidelines prior to implementation of the RICT program. These guidelines will be met by implementing the following published NUREGs and Fire PRA Frequently Asked Questions to the Fire PRA model:

Florida Power & Light Company L-2018-001 Enclosure Page 4 of 7

• NUREG-2169, Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database,

• NUREG-2178, Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire

• FAQ 13-005, Cable Fires Special Cases: Self Ignited and Caused by Welding and Cutting, and

• FAQ 13-006, Modeling Junction box Scenarios in a Fire PRA In addition to the above referenced standards, there are other known conservatisms in the current fire modeling used in the Turkey Point PRA. As an example, for cable spreading room panels, only two potential fire damage states are considered: (1) damage confined to the electrical panel, and (2) a more severe fire causing a hot gas layer to form resulting in full room damage. Another potential outcome would credit the installed Halon suppression system if a cabinet fire were to propagate externally. The Halon system would likely suppress the fire prior to bulk ignition of the cables and the resulting formation of a hot gas layer. Adding this intermediate fire damage state is an example of the changes that could be made to add realism to the PRA results (fire damages some fraction of cables in the vicinity but does not cause full room damage), reducing conservatism.

APLA RAI-12 Remaining Unresolved F&Os In Table 1 in LAR Enclosure 2, the licensee identified eleven unresolved facts and observations (F&Os) from the 2013 focused scope peer review. For each F&O FPL stated, [t]his will be resolved in the next model update to take place before implementation of 4b at [Turkey Point].

Expected to have little effect on 4b RICTs.

However, the NRC staff notes that it has not reviewed any proposed resolution to these F&Os during this 4b review and therefore has not accepted any of these resolutions as part of its review.

The NRC staff can review proposed changes to the PRA during the review of the LAR. However, the anticipated license condition will limit future changes to the PRA to acceptable PRA methods.

a) Please provide the resolution to any of these F&Os, with supporting evaluation as appropriate, for the staff to accept the resolution during the completion of the LAR review.

b) Please provide an implementation item identifying all remaining unresolved F&Os and specifying that Turkey Point shall resolve them using NRC approved methods (response may reference the response to APLA RAI 15 which requests a list of implementation items).

FPL Response The eleven findings listed as unresolved at the time of the LAR submittal have been resolved or closed in accordance with the NRC approved F&O closeout process.

As part of the process for F&O close out, some findings that were considered resolved in the submittal were determined to be not closed pending documentation update or additional justification. As part of the response to APLA RAI 15, these findings will be closed or a sensitivity case will be completed prior to implementation of the RICT Program.

Florida Power & Light Company L-2018-001 Enclosure Page 5 of 7 Supplemental Information A list of open F&Os is provided in Attachment 3 to this enclosure, Disposition and Resolution of Open Peer Review Findings and Self-Assessment Open Items.

APLA RAI-15 Implementation Items Please provide a list of activities (i.e., implementation items) that are credited as part of the approval of the request to implement a RICT program that will not be completed before issuing the amendment but must be complete before implementation of the RICT program.

a) Propose a mechanism to require the changes to be made before implementation of the RICT program such as a reference to the table of implementation items in a license condition in the proposed amendment to the Operating License.

b) The NRC staff considers the following as potential implementation activities.

• Modelling VEWFDS according to NUREG-2180 in the fire PRA (RAI 2.01)

• Confirming that the all hazards CDF and LERF estimates will be less than 1E- 04/year and 1E-05/year respectively before implementing the RICT program (RAI 2)

• Implementing minimum joint HEP or sequence level justification into the internal events PRA (RAI 06.01.b)

• Resolving all of the eleven unresolved F&Os from the 2013 focused scope peer review identified in Table 1, LAR Enclosure 2. (RAI 12)

FPL Response a) FPL proposes the following license condition for Turkey Point Units 3 and 4:

FPL will complete the items listed in the table of implementation items in the enclosure to FPL letter L-2017-168 dated October 30, 2017 prior to implementation of the Risk Informed Completion Time Program.

b) Table of implementation items:

Item Implementation Date

1. Confirm that the all hazards CDF and LERF estimates will be less than 1E- 04 per year and 1E-05 per year, respectively.

2. Close all open facts and observations findings or Prior to implementation perform a sensitivity study case to determine the impact of the Risk Informed on the CDF and LERF results that could be adversely Completion Time affected by each open finding. Program

3. Implement a joint HEP floor of 1E-06 or a similarly technically justified floor value in the internal events model.

Florida Power & Light Company L-2018-001 Enclosure Page 6 of 7 Supplemental Information FPL proposes the table of implementation items and the associated license condition as shown below.

Table of implementation items:

Item Implementation Date

1. Confirm that the all hazards CDF and LERF estimates achieved using NRC accepted methods will be less than 1E- 04 per year and 1E-05 per year, respectively.

2. All findings will be closed. Prior to implementation of the Risk Informed

3. Implement a joint HEP floor of 1E-06 in the internal Completion Time events model. For future model updates, once the HFE Program combinations have been analyzed and the HEP floor of 1E-06 applied, individual HFE combination probabilities may be set below 1E-06 if a detailed analysis is performed and technical justification is provided.

License Condition:

FPL will complete the items listed in the table of implementation items in the enclosure to FPL letter L-2018-001 dated February 15, 2018 prior to implementation of the Risk Informed Completion Time Program.

APLA RAI-16 License Condition In Section 4.0, "Limitations and Conditions" of the NRC Staff safety evaluation to NEI 06-09, the staff stated:

As part of its review and approval of a licensee's application requesting to implement the [Risk Managed Technical Specifications] RMTS, the NRC staff intends to impose a license condition that will explicitly address the scope of the PRA and non-PRA methods approved by the NRC staff for use in the plant specific RMTS program. If a licensee wishes to change its methods, and the change is outside the bounds of the license condition, the licensee will need NRC approval, via a license amendment, of the implementation of the new method in its RMTS program.

Please propose a license condition limiting the scope of the PRA and non-PRA methods to what is approved by the NRC staff for use in the plant-specific RMTS program. An example is provided below.

Florida Power & Light Company L-2018-001 Enclosure Page 7 of 7 The risk assessment approach, methods, and data shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods currently approved by the NRC for generic use. If a licensee wishes to change its methods and the change is outside the bounds of this license condition, the licensee will need prior NRC approval, via a license amendment.

FPL Response In lieu of a license condition, FPL proposes to add paragraphs f and g below to the Risk Informed Completion Time Program in Specification 6.8.4.n in the administrative section of the TS. This addition to the program limits the scope of the PRA and non-PRA methods to those approved by the NRC staff for use in the plant-specific RMTS program.

f. A RICT must be calculated using internal events, internal floods, and fire PRA. The PRA maintenance and upgrade process will validate that changes to the PRA models used in the RICT program follow the guidance in Appendix 1-A of ASME/ANS RA-Sa-2009, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications."

g. A report shall be submitted following each PRA upgrade and associated peer review, and prior to using the upgraded PRA to calculate a RICT. The report shall describe the scope of the upgrade.

Supplemental Information FPL withdraws its proposed change to add items f and g to the Risk Informed Completion Time Program in Specification 6.8.4.n. Instead, FPL proposes the following license condition, which is the same as that approved for Vogtle Units 1 and 2 in License Amendments 188 and 171, respectively, on August 8, 2017 (ML15127A669):

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.

Florida Power & Light Company L-2018-001 ATTACHMENT 1 Markup of the Unit 3 and Unit 4 Operating Licenses

Florida Power & Light Company L-2018-001 INSERT OL I. 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 items listed in the table of implementation items in the enclosure to FPL letter L-2018-001 dated February 15, 2018 prior to implementation of the Risk Informed Completion Time Program.

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.

8 H. PAD TCD Safety Analyses

1. PAD 4.0 TCD has been specifically approved for use for the Turkey Point licensing basis analyses. Upon NRCs approval of a revised generic version of PAD that accounts for Thermal Conductivity Degradation (TCD), FPL will within six months:

a. Demonstrate that PAD 4.0 TCD remains conservatively bounding in licensing basis analyses when compared to the new generically approved version of PAD w/TCD, or

b. Provide a schedule for the re-analysis using the new generically approved version of PAD w/TCD for any of the affected licensing basis INSERT OL analyses.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight July 19, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Signed by Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications for Unit 3 Appendix B - Environmental Protection Plan Date of Issuance: June 6, 2002 Renewed License No. DPR-31 Amendment No. 262

8 H. PAD TCD Safety Analyses

1. PAD 4.0 TCD has been specifically approved for use for the Turkey Point licensing basis analyses. Upon NRCs approval of a revised generic version of PAD that accounts for Thermal Conductivity Degradation (TCD), FPL will within six months:

a. Demonstrate that PAD 4.0 TCD remains conservatively bounding in licensing basis analyses when compared to the new generically approved version of PAD w/TCD, or

b. Provide a schedule for the re-analysis using the new generically INSERT OL approved version of PAD w/TCD for any of the affected licensing basis analyses.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight April 10, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Signed by Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications for Unit 4 Appendix B - Environmental Protection Plan Date of Issuance: June 6, 2002 Renewed License No. DPR-41 Amendment No. 257

Florida Power & Light Company L-2018-001 ATTACHMENT 2 Markup of the Technical Specifications

Florida Power & Light Company L-2018-001 INSERT RICT PROGRAM

n. Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b: Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0-A, November 2006. The program shall include the following:

a. The RICT may not exceed 30 days;

b. A RICT may only be utilized in MODES 1 and 2;

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. If the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1. Numerically accounting for the increased possibility of CCF in the RICT calculation, or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

I. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operations are met:

a. The Surveillance Frequency Control Program shall contain a list of frequencies of those Surveillance Requirements for which the frequency is controlled by the program.

b. Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the frequencies established in the Surveillance Frequency Control Program.

m. Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (lSI) requirements for supports. The program shall be in accordance with the following:

a. This program shall meet 10 CFR 50.55a(g) lSI requirements for supports.

b. The program shall meet the requirements for lSI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(a) subject to the use and conditions on the use of standards listed in 10 CFR 50.55a(b) and subject to Commission approval.

c. The program shall, as required by 10 CFR 50.55a(b)(3)(v), meet Subsection ISTA, "General Requirements" and Subsection ISTD, "Preservice and lnservice Examination INSERT RICT PROGRAM and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4),

10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)(3)(v))

subject to the conditions listed therein.

6.8.5 DELETED TURKEY POINT - UNITS 3 & 4 6-14 AMENDMENT NOS. 272 AND 267

Florida Power & Light Company L-2018-001 Page 1 of 27 ATTACHMENT 3 Disposition and Resolution of Open Peer Review Findings and Self-Assessment Open Items

L-2018-001 Attachment 3 Page 2 of 27 ATTACHMENT 3 Disposition and Resolution of Open Peer Review Findings and Self-Assessment Open Items Capability Finding Supporting Category Description Resolution for Independent Review Independent Review Comments Disposition for RICT Number Requirement(s)

(CC)

Internal Events PRA Model Findings DA-2 DA-7 NOT The test and maintenance probabilities used for individual Logic was introduced to the model to The CAFTA model (ptnrev11.caf) was Documentation updates are needed MET components are based on actual outage time as collected by the change the opposite-unit EDG test and reviewed. The logic and basic events and to close this finding. The plant. The component outage time was clearly collected over the maintenance probability during outage associated BE values used to account for documentation updates will not affect period of time the plant was in Mode 1, 2, 3. conditions through the use of flags opposite unit cross-tie/EDG unavailability the results.

The fault trees and event trees use several crossties from AC representing the operating mode of the while in Modes 5/6 was reviewed and No impact on RICT application.

power, HHSI, and AFW. In the use of these crossties, the unit. These flags were also used to appears reasonable. It also appears that opposite unit components have T&M events. The opposite unit model the effect of the opposite unit's modeling of the opposite unit EDG crosstie may be in Mode 4, 5, 6 at the time of demand and the desired mode on the different system crossties. in Modes 5/6 is handled solely by the fault equipment may have lesser Tech Specs than those assumed for tree logic and basic events. However, PTN-power operation. The T&M event probabilities for the opposite BJFR-02-026 states: only T&M unavailability unit components must consider unavailability over the total when the unit is in Mode 1 through 4 was period of demand, not just during power operation. This can be considered. This is inconsistent with what done at the fault logic level (with house events for OOS) or in the appears to be in the model. In addition, the data probabilities. Currently, neither is done. GDOC resolution refers to the use of flag The most important case of this is the DG's. The DG T&M files to model/capture the opposite unit unavailability is about 6E-3 (55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br /> per year). If the OOS time crosstie/EDG unavailability. The flag files (if for major overhaul were considered, the unavailability would be any) were not reviewed. Some additional

.03 to .05. Consider revising the T & M event probabilities for the information was provided concerning the opposite unit components to account for unavailability over the specific unavailability values used, but this total period of demand. As stated above, this can be done at the information is not contained in any of the fault logic level or in the data probabilities. PRA documentation. This F&O is considered to remain open pending revision of the documentation to reflect what is actually in the fault tree model.

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HR- HR-A2 NOT This HR requires identification, through a review of procedures An approach (see SR HR-D2) was used Pre-initiator HFE identification and modeling Documentation updates are needed A2-01 HR-B1, MET and practices, those calibration activities that if performed for the pre-initiators which assumed pre- is described in the pre-initiator HFE to close this finding. The HR-B2, incorrectly can have an adverse impact on the automatic initiation initiators are always possible, and notebook, PTN-BFJR-09-011. An alternative documentation updates will not affect HR-C3, of standby safety equipment. The system notebooks contain a detailed evaluations of procedures were approach used to identify, screen and quantify the results.

HR-I2 detailed listing of testing and maintenance procedures that were made only for risk-significant items. pre-initiators from the assumed approach in No impact on RICT application.

identified for each system, but there is no discussion as to which Screening values were used for the non- the PRA Standard. Figure 3 in the notebook procedures were determined to have the potential to result in risk-significant pre-initiators. See PTN- summarizes the process. All key modeled equipment being left in a miscalibrated condition, and which were BFJR-09-011, Rev. 1. components are initially assigned a pre-screened from consideration with the basis for screening. A initiator event, set to a screening value of review of the procedures listed in the system notebooks should 3E-3 for individual events and 3E-4 for be performed to identify those that could result in potential events affecting multiple trains of equipment.

miscalibration events, and provide a justification for those that If the initial quantification of the model were excluded from further consideration. For miscalibrations shows the HFE to be significant, then that have the potential to impact multiple systems, ensure that detailed HRA evaluation is performed. If the they are treated consistently between both systems, and that event has low importance, it is left at its appropriate HFEs are listed in all impacted system notebooks. screening value. For those events that are Similar traceability needs to be provided for other test and potentially significant, a review of plant maintenance procedures that have the ability to render a procedures is then performed to determine if system/equipment unavailable as well. these HFEs could occur. Those that are determined to be impossible or for which procedures do not exist are either deleted from the model or set to a low (1E-6) value.

The remaining events are quantified using ASEP. This approach seems reasonable, and an ASME inquiry about the acceptability of this method is pending. Table 3 shows the initial results of the importance review for all of the HFEs. Table 4 lists those selected for detailed evaluation and Table 5 shows the final listing of all HFEs. The list includes both single and common cause pre-initiators as required by the Standard. However, a comparison of the tabulated BE values with those shown in the model shows differences.

For example event HHFA3A106 is listed as having a probability of 3E-3 screening value; however, its value in the model is 1E-4.

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Similarly, event AHFA0PUMPC is listed as having a 3E-3 value but is in the model as 1E-4. Information was provided to show that 1E-4 is the correct value for these events.

This F&O is considered to remain open pending an update of the documentation to reflect the actual values used in the PRA model.

HR- HR-B2 NOT This SR does not allow screening of activities that could This F&O addressed the following The GDOC provides a discussion of the Documentation updates are needed B2-01 MET simultaneously have an impact on multiple trains of a redundant valves, which were assumed not to be status of each of the valves noted in this to close this finding. The system or diverse system. In the HHSI system notebook, the under maintenance while either unit is at F&O for pre-initiator inclusion. Verified documentation updates will not affect following valves are assumed not to be under maintenance while power: MOV-*-¬864A, B; *-864C; *- RWST OOS in the model. Verified 845 & the results.

either unit is at power: MOV-*-¬864A, B; *-864C; *-845A, B, C, 845A, B, C, D; MOV-878A, B; MOV-* 882 are locked open manual valves in 0-OSP- No impact on RICT application.

D; MOV-878A, B; MOV-* 856A, B;

• 847C;

• 882. Because 856A, B;

• 847C;

• 882. 205. Verified 856 A&B and 874C are HHSI these valves have the potential to impact BOTH Units, they For the 864 valves, the model has a recirc valves in 3-OSP-062.3 and 4-OSP-cannot be screened in this manner. Based on this assumption, T&M event for each RWST to account 068.3. Several valves are noted as not these valves would only be worked on while both Units are for the time the RWST contents are requiring pre-initiator modeling (e.g., locked shutdown, which is probably not realistic. Review the actual test used to fill the refueling canal, which is valves). For those for which HFEs were and maintenance procedures associated with these valves and the only time the 864 valves could be added in the model, it doesnt appear that determine when they can be subject to testing or maintenance. If maintained. these events have been added to the Pre-they can be subject to testing or maintenance when either of the The 845 and 882 valves are locked-open initiator HFE Notebook, PTN-BFJR-09-011.

Units is shutdown, then a T&M needs to be added into the model manual valves, so no T&M or pre- For example, the HFEs for 878B as well as consideration for a pre-initiator mis-alignment of the initiator is needed there. (GHFAMOV878B) and 856A valves, and a post-initiator HRA to re-align if necessary. The HHSI recirculation valves 856 and (GHFAMOV4856A) are not shown in the 874C, if closed for maintenance take out notebook. This F&O is considered to remain their related HHSI pumps. The 856 open pending update of the pre-initiator HFE valves are stroke-tested during the documentation to reflect the contents of the associated unit refueling outages. PRA model.

Evaluated pre-initiators for the 856 valves and added these to the model.

The 878A and 878B valves, if closed for maintenance, would prevent opposite-unit SI. Evaluated pre-initiators for the 878 valves and added these to the model.

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HR- HR-C2 NOT There is no provided documentation of the plant-specific or In the latest data update, condition The GDOC indicates that a review of plant Documentation updates are needed C2-01 MET applicable generic operating experience for equipment left reports were reviewed for the time operating experience was performed; to close this finding. The unavailable for response in accident sequences. Provide period 1992-2006 for component however, there is no documentation of such a documentation updates will not affect documentation of the review of plant-specific or generic failures. No failure modes outside the review in the pre-initiator notebook. Another the results.

operating experience and confirm that no additional failure mode ones already modeled were found, Data Update will be released soon (PTN No impact on RICT application.

is required. including failure-to-restore events. BFJR 02-026, Revision 2) and will address this issue. This F&O is considered to remain open.

HR- HR-D1 NOT The human failure event probabilities appear to be evaluated with AHA0N2BK1, among others, had The response addresses only the two specific Documentation updates are needed D1-01 MET a systematic process that includes an initial screening value and already been analyzed in detail, and the examples cited in the F&O text and fails to to close this finding. The the identification of risk-significant action for which a detailed results from the detailed analysis used in address the broader implication of documentation updates will not affect analysis through ASEP method is used. Although there appear to the model, even though the events risk inconsistency in documentation. the results.

be some inconsistencies in the values of the HEF, especially for importance was low. The AHFA0N2BK1 event mentioned in the No impact on RICT application.

HEF already existing in previous version of the model. For The probability of AHFPAFWTHROT F&O now is consistent between the model example, action AHFA0N2BK1 is indicated as a pre-existing in the HRA file does match that in the and the pre-initiator notebook (PTN-BFJR-action (i.e., not highlighted in Table 3, page 22) with an initial .rr file. The misread might be the result 09-011) value. The AHFPAFWTHROT value of 1.10E-3. There is no further discussion of this action of looking at the seed optimization event is no longer used in the internal events (i.e., the action is not indicated in Table 4 at page 27 as one of the probability value given in the FACTOR model, but an event of the same name (with a action requiring further analysis). Still in Table 5 at page 31 the field. The PROB field matches. different probability) now exists in the fire action has a value of 4.0E-5 (consistently with what is in the model (Revision 11). Given the fact that no model). Another example of inconsistency between the evidence of a more comprehensive review of documentation, the HRA Calculator file and the CAFTA model all HFEs was performed, this F&O is is post-initiator action AHFPAFWTHROT). considered to remain open.

LE- LE-D2 NOT Electrical penetration assembly failure modes have been found to For containment isolation, the Level 2 The current Level 2 Notebook (PTN-BFJR- Documentation updates are needed D2-01 MET be important contributors to overall containment fragility at other update incorporated the existing 00-010) does not discuss electrical penetration to close this finding. The large dry PWRs, and in at least 2 instances, tend to be the most containment isolation analysis; it did not failures are potential contributors to LERF, documentation updates will not affect limiting in terms of ultimate failure pressure. Additionally, early revisit this issue directly. The place in nor explain why they are not included. The the results.

studies at Sandia National Laboratories have considered the the Level 2 model where this would document does discuss the containment No impact on RICT application.

potential impact of very high (beyond design basis) temperatures have an effect would be the isolation system (CIS) which is used to isolate on elastomer seals (this latter issue is more critical for small "Containment Failure at Vessel Breach" fluid systems. The GDOC notes that it is volume containments such as BWR Mark I). Perform a scoping events, which were determined via assumed that such failures would be a assessment of the potential impact of electrical penetration NUREG sources to be minimal. It is not negligible contributor (since they are assumed thermal mechanical response to severe accidents. Consider using known whether these referenced to be only of concern following vessel some of the following

References:

NUREG/CR-4944, CR-5083, NUREGs already factored such breach), but that it is not known if these CR-5096, CR-5118, and CR-5334. considerations into their containment failures are addressed in the NUREGs used strength estimates and failure as the bases for the vessel breach effects

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(CC) probabilities, but it is not expected to evaluation. Since the specific failure have a significant effect. mechanisms noted in this SR were not addressed, this F&O is considered to remain open.

QU-3 QU-26 NOT The quantification of a linked fault tree model involves the Changes to the mutually exclusive event The quantification notebook and model Documentation updates are needed QU-19 MET proper integration of several files which can affect the results. For combinations, flag file, circular logic update notebook for Turkey Point 3 and 4 to close this finding. The HR-21 example: breaks, and recovery rule file are were reviewed. There is no evidence of documentation updates will not affect

a. The quantification flag file is used to set logic flag events true documented in the change database and documentation of the recovery or the the results.

or false to represent normal system alignment. At PTN, this flag the model updates. Details of the mutually exclusive files. The development and No impact on RICT application.

file is also used to set certain maintenance events false. quantification process are documented use of these files is discussed. These files

b. The mutually exclusive file is used to remove cutsets from the in the Quantification Notebook and the need to be in the notebook so that there is a results file which contain certain combinations of events model updates. Truncation level is set as record of the justification for the mutually representing disallowed maintenance or illogical event low as the hardware and software will exclusive event and/or the reason for combinations (i.e., events for failure to open and spurious allow, or until convergence is achieved. crediting recoveries. Also having the files opening of the same valve in a single cutset). Uncertainty analysis input is documented in the notebook ensures a review

c. The recovery rule file is used to add recovery events to the documented in the model update by a qualified PRA engineer. Since there is no cutset results based on the appearance of certain combinations of calculations. documentation of either of these files in the failure events. At PTN, this process is also used to apply human quantification notebook, this F&O is error factors to the quantification results. considered to remain open.

Since these files control vital processes during quantification, independent review and thorough documentation is needed to ensure that the quantification results do not exclude valid failure sequences. The current mutually exclusive events file (PTN2KMEE.TXT) was changed as a result of the addition of new T&M events for LC/SWGR HVAC AHUs and Sump Level Indicators. The calculation package includes a description of "add double maintenance events for these basic events to mutually exclusive events." However, no justification for making the events mutually exclusive or specifying the combinations that are mutually exclusive is provided. In addition, the review of the mutually exclusive events file indicates that some complimentary combinations related to AFW pump maintenance may not be included. While this would lead to conservative results due to failure to remove invalid cutsets, the addition of inappropriate mutually exclusive combinations would have the opposite result.

Similar errors can be introduced through the recovery file through the inappropriate application of recovery events to

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(CC) sequences which do not represent the conditions assumed in the HRA analysis. Consider developing a documentation package for the flag file, mutually exclusive events file and the recovery rules which provides the basis of each item in the respective files.

Cross-disciplinary review of the flag file and mutually exclusive events file by plant personnel may also be considered.

QU-8 QU-31 NOT The subtier criteria for a grade 3 on this element considers the a. A comparison of PTN CDF cutsets to Reviewed the quantification notebook and Documentation updates are needed MET following to be indicative of a good understanding of the Robinson's CDF cutset was made and is model update notebook. The quantification to close this finding. The dominant risk contributors: documented in the Quantification notebook provides a comparison and documentation updates will not affect

a. The accident sequence results by sequence, sequence types, and Notebook. Where differences in the explanation of PTN CDF cutsets to the results.

total should be reviewed and compared to similar plants to assure cutsets occurred, they could be Robinson's CDF cutsets. This provides No impact on RICT application.

reasonableness and to identify any exceptions. explained by design or data differences. interesting information but it is not clear how

b. A detailed description of the Top 10 to 100 accident cutsets b. A list of the top 50 cutsets is provided useful this is at the cutset level. Also it is not (CAFTA or NUPRA) or accident sequences (RISKMAN) should in the model updates. clear if the Robinson results are recent and if be provided because they are be important in ensuring that the c. Initiating event pie charts, system this information is updated periodically. The model results are well understood and that modeling assumption importance charts, and a table listing the model update notebook also contains the impacts are likewise well known. individual sequence contributions are latest PTN CDF results at the functional

c. The dominant accident sequence groups or functional failure included in each model update sequence level and at the cutset level but groups should also be discussed. These functional failure groups calculation. there is not a detailed discussion of the should be based on a scheme similar to that identified by NEI in cutsets and why the results are reasonable.

NEI 91-04, Appendix B. There is also a breakdown of initiating event There is no discussion of results in the calculation packages for contributions to CDF/LERF, system updates provided to the review team to indicate that this type of importance contributions and CDF/LERF evaluation is done of the quantification results. Also, the uncertainty distributions, but there is not a calculation packages provide no discussion of how the dominant discussion of these results as well. A cutsets or important systems were affected by the changes to the comparison between U3 and U4 was model when compared to the previous revision. Consider conducted. While the documentation expanding the discussion of the quantification results in the addresses some of the requirements noted in calculation packages or developing a PSA Summary Document the F&O, a more comprehensive containing this type of evaluation for each revision. documentation of the results and their significance is needed. This F&O is considered to remain open.

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Internal Flood PRA Model Findings IFQU IFQU-A7 NOT This SR states: PERFORM internal flood sequence quantification The quantification is discussed now in IFQU-A7 invokes all of the QU requirements Documentation updates are needed

-A7- IFQU-A10 MET in accordance with the applicable requirements described in the documentation of the internal for internal events and IFQU-A10 requires to close this finding. The 01 IFQU-B2 paragraph 4.5.8. The internal flooding analysis has been flooding quantification. See PTN-BFJR- that an evaluation of the internal events documentation updates will not affect quantified in accordance with internal events quantification 11-009, Rev. 1. LERF sequences to ensure they are not the results.

requirements; however, supporting documentation should be impacted by the flooding scenarios that are No impact on RICT application.

provided which describes the process. The quantification process being evaluated. While Section 4.3 of the IF should either be documented in the flooding analysis, or if the notebook provides some information same process has been used elsewhere, the flooding analysis concerning how the flooding quantification should point to that process. Additionally a review of the was performed and presents the scenario level quantification should be documented. results, the documentation does not meet the requirements of all of the QU SRs. Examples include lack of truncation studies, lack of discussion of dominant results and important basic events, require of non-significant cutsets, review of cutsets and dominant events to determine that the results make sense, etc.) Note that the QU notebook does not include flooding initiators, so all of this information would need to be included in the IF notebook. For IFQ-A10, there is no information presented that demonstrates that a review of internal events LERF sequences was performed to ensure that they are applicable to the flooding events. Therefore, this F&O is considered to remain open.

IFSN- IFSN-A2 NOT No identification of flood alarms or floor drains has been made No credit taken for operator action to PTN-BFJR-11-009, revision 1, was reviewed. Documentation updates are needed A2-01 MET in the flood analysis document. PTN should document and mitigate flood; therefore, there was no In this document, it is stated that a reasonable to close this finding. The identify the presence of flood alarms and floor drains as related to need to credit flood alarms. time for the flood to be terminated was based documentation updates will not affect their treatment in the analysis. Documentation was updated to reflect on alarms. However, as stated in section the results.

the fact that drain lines were not 3.2.1, no credit is assumed for operator No impact on RICT application.

credited in determining the impact of a actions to mitigate flooding consequences.

flood in a particular room. Added to The only alarms identified are high sump Section 3.1.3, In looking at flood level alarms. The flood walk downs should propagation by backflow through shared have included identifying a room alarm (SR drain lines, no credit was taken for check IFSN-A2). So even if the alarms are not credited (which does not agree with the

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(CC) valves. See PTN-BFJR-11-009, Rev. 1. statement for termination), the alarms should be identified. The consequences of sump overflow are also not discussed. Based on information provided in Section 3.2, the smaller diameter (~4-inch) floor drain impact on flooding scenarios has been assessed. In general, the consequences of flooding considered the possibility that drains and sump pumps do not function unless the drain flow added to the consequences of the event.

It is also noted that the flood scenario descriptions typically include mention of the floor drains and associated impacts, but relatively little detail is provided. This F&O is considered to remain open pending improvement of the documentation of the alarms and drains.

IFSN- IFSN-A4 NOT No supporting information has been provided to justify the A discussion of the flooding calculations Report PTN-BFJR-11-009, Rev. 1, Internal Documentation updates are needed A4-01 IFSN-A9 MET estimations regarding flood volumes and the subsequent flooding has been added to Section 3.2. The Flooding Analysis, was reviewed. The to close this finding. The height. PTN should document the calculations performed in software used for the flooding capability of the flood calculation code documentation updates will not affect determining flood volumes in a given flood area as it relates to calculations and the output files are (performed in C++) is summarized in Section the results.

equipment in the room (the floor area the equipment takes up), referenced and added to the calc folder. 3.2. Obviously hydraulic calculations and No impact on RICT application.

the capacity of the system, the length of time the flood persists, See PTN-BFJR-11-009, Rev. 1. room/equipment flood and propagation etc. calculations were performed. However, the specific calculations performed for the scenarios are not referenced, and the calculational inputs used to characterize the flood scenarios were not readily available nor described in the documentation. It is unclear what this timing information is used for and what it justifies. Due to the lack of explanation for the timing information, this F&O is considered to still be open.

IFSN- IFSN-A6 NOT This SR States: For the SSCs identified in IF-C2c, IDENTIFY It is now documented in the internal Document PTN-BFJR-11-009, revision 1, In the ASME PRA Standard, the A6-01 MET the susceptibility of each SSC in a flood area to flood-induced flooding analysis documentation that was reviewed. Section 3.1.2 does address quantitative analysis of environmental failure mechanisms. INCLUDE failure by submergence and spray spray and submergence damage were HELB in the auxiliary building. This does not effects such as humidity and in the identification process. included in the scope of the evaluation. address the environmental conditions temperature is only required for Cat.

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EITHER: See PTN-BFJR-11-009, Rev. 1. (humidity or temperature) in any of the other III for IFSN-A6. For Cat. II, a a) ASSESS qualitatively the impact of flood-induced mechanisms Added to section 3.1.2, paragraph 5 end buildings. Also, there is no discussion of qualitative analysis or a note that are not formally addressed (e.g., using the mechanisms listed - "In light of this, it should be noted that feedwater line break environmental effects in documenting that these effects were under Capability Category III of this requirement), by using only spray and submergence damage the turbine building. It should be noted that not considered is required.

conservative assumptions; OR were included in the scope of this in the ASME roadmap IFSN-A6 is noted as Documentation updates are needed b) NOTE that these mechanisms are not included in the scope of evaluation." an open item. This F&O is considered to still to close this finding. The the evaluation. be open. documentation updates will not affect No discussion has been provided for the impact due to the the results.

additional flood failure mechanisms. Analysis should be No impact on RICT application.

performed which includes failure by submergence or spray, and a qualitative assessment of other failure mechanisms needs to be provided (e.g. jet impingement, pipe whip, humidity, condensation, temperature concerns, and any other identified failure modes in the identification process.) Note that the qualitative assessment is a requirement of the NRC Clarification of this SR.

IFSN- IFSN-A8 NOT This SR states: IDENTIFY inter-area propagation through the Inter-area propagation is discussed in Document PTN-BFJR-11-009, revision 1, Drains, wall penetrations, and floor A8-01 MET normal flow path from one area to another via drain lines; and Appendix B of the internal flooding was reviewed. The propagation through penetrations are examined for each areas connected via back flow through drain lines involving failed analysis documentation. alternate paths such as drain lines, or flood scenario and are documented in check valves, pipe and cable penetrations (including cable trays), Added to Section 3.1.3, "These pathways overflowing sumps is noted in the walkdown Appendix B of PTN-BFJR-11-009.

doors, stairwells, hatchways, and HVAC ducts. INCLUDE are listed in Appendix B under the documentation. There is no discussion in the Enhancement of this documentation potential for structural failure (e.g., of doors or walls) due to "Drainage" section of each zone." See propagation section on possible propagation may be necessary to satisfy the flooding loads. PTN-BFJR-11-009, Rev. 1. through drain lines to other flood zones. The concerns of the F&O closure Although the obvious propagation pathways (e.g. doors, documentation of identified "less obvious" reviewer. The documentation stairwells, grating) were identified, a good discussion associated pathways, in particular, is lacking. This does updates will not affect the results.

with less obvious pathways (e.g. failed backflow check valves, not meet the intent of the F&O. This F&O is No impact on RICT application.

cable penetrations, cable trays, etc.) for individual zones was not considered to still be open.

found. Documentation of less obvious possible propagation pathways needs to be addressed.

IFSO- IFSO-A1 NOT Based on a confirmatory walkdown performed the Peer Review The findings involved the chilled water Document PTN-BFJR-11-009, revision 1, The documentation states that the A1-01 MET Team, the locations/impacts of some pipes containing water may system. The chilled water system was reviewed. The GDOC response indicates chilled water system operates at very have been overlooked in the analysis. It is recommended that the operates at very low pressure and the that this F&O pertains only to the Chilled low pressure and the lines are analyst ensure that spatial information be captured appropriately lines are insulated, precluding the Water system, but the F&O appears to be insulated which is justification for for spray concerns. Equipment has been identified in walkdown possibility of a spray. This information more broadly worded. Concerning the chilled the low likelihood of strong spray sheets for elevation, but not spatial location. Additionally the was added to the scenario descriptions. water system, it is analyzed. It is stated that it from a rupture. Any documentation analyst should ensure that all potential fluid sources in a given is unlikely that a rupture of the chilled water updates needed to close this finding flood area are identified, and all potentially impacted equipment is line will result in strong spray. There is no will not affect the results.

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(CC) identified the impact of it failing is evaluated. justification for this statement. Also, it is No impact on RICT application.

stated in the switchgear room that a rain shield on top of the cabinets will protect the cabinets. This is reasonable and does not require further explanation. Due to the lack of documentation of how this F&O was fully addressed, this F&O is considered to still be open.

IFSO- IFSO-A4 NOT No human-induced mechanisms have been included in the Human-induced mechanisms are already Report PTN-BFJR-11-009, Rev. 1, Internal Maintenance-induced flood events are A4-01 IFEV-A7 MET analysis, and additionally, no process which justifies their taken into account in the general failure Flooding Analysis, was reviewed. While there not included in the failure rates.

exclusion was provided. it is recommended that specific instances data. is mention of a possible human-induced flood Based on Figure 7-1 of EPRI report be discussed as it relates specifically to operator induced failures. associated with charging pump and RCP seal 3002000079, Pipe Rupture Additionally, a process or program should be identified which water filters during maintenance, there is no Frequencies for Internal Flooding prevents human-induced floods from occur, thereby justifying assessment of human-induced or Probabilistic Risk Assessments, their exclusion from the analysis. maintenance induced flooding events Revision 3, 30% of the internal documented. In fact, Section 2. states "In this flooding initiating events are analysis, all causes of flooding were maintenance-induced. The internal considered except plant-specific maintenance flooding CDF is currently is 1.6E-07 activities". Section 3.1.2 Flood Sources, states per year. If the lack of inclusion of that, "By considering the guillotine rupture of maintenance-induced floods is lines, we ensure that we address the fact that approximated by increasing the catastrophic failures might result from internal flooding CDF by 30%, the operator error (e.g., maintenance-induced internal flooding CDF is 2.1E-07 per floods)....". Finally, both Table D1 of the year. The increase of 5E-08 per year flooding document and the PTN GDOC is much smaller than the combined misinterpret the scope of the EPRI flood CDF from internal events and fire event data, which includes human or and is orders of magnitude smaller maintenance-type events only if these events than the NUREG-2180 sensitivity had resulted in a metallic breach (pipe break). risk increase.

Otherwise, maintenance and human induced flooding events are not accounted for in the generic data. A thorough assessment of maintenance or human induced flooding events has not been documented. This F&O is considered to remain open.

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(CC)

IFSO- IFSO-A5 NOT No summary or characterization of flood sources included in the Flooding calculations and discussion of Document PTN-BFJR-11-009, revision 1, Drains, wall penetrations, and floor A5-01 MET analysis has been provided. It is difficult to tell what the decisions flood sources has been added to the was reviewed. Section 4.2, Flooding penetrations are examined for each making up the source characterization were. Characterize flood documentation of the internal flooding Scenarios, identify tank capacities and flood scenario and are documented in sources in terms of capacity, flow rate, pressure, temperature, etc. analysis. See Section 3.2 of PTN-BFJR- makeup flow for the tanks and piping in the Appendix B of PTN-BFJR-11-009.

Additionally, document the justification for a given flow rate.11-009, Rev. 1. flood zone. There is no discussion of Enhancement of the documentation PTN should also document the process used to identify potential temperature or pressure. There is also no may be necessary to satisfy the flood sources. discussion of drains and the possibility of concerns of the F&O closure sump overflow. There is no consideration for reviewer. The documentation systems to be emptied into the plant. Only updates will not affect the results.

the surge/makeup tanks were considered. If No impact on RICT application.

the pipe break were on the outlet of the pump, the system would empty all its water in the flood plus any makeup flow. This was not considered. Without these conditions being discussed the flooding analysis may be non-conservative. This F&O is considered to remain open.

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(CC)

Fire PRA Model Findings 1-3 AS-B1 NOT The PRA Assumes a reactor trip rather than mapping the This F&O has been resolved. The issues The Component and Cable Selection Report Documentation updates are needed ES-A1 MET components to all of the previously modeled internal events and concerns identified in the F&O (PTN-BFJR-16-004) and the fire PRA fault to close this finding. The ES-A3 Initiating events. As a result, the equipment that can cause the related to the fire-induced initiating tree was reviewed to address how the documentation updates will not affect ES-A4 various initiating events are not mapped to individual initiating events were reviewed. The review found assumed reactor trip due to fire is modeled in the results.

FQ-A2 events. several instances where a change to the the fire PRA. The fire related impacts are No impact on RICT application.

The internal events PRA model has numerous locations in the modeling was required to allow the assigned to the logic as defined in Table 4.1-2 model where the specific initiating event results in a model existing treatment methodology to be of the notebook. However a disposition of impact. For example, under gate U3QT07; initiating events that retained. The review did not identify any the items identified in the F&O was not can cause a PORV or SRV to lift are ANDed with the failure to instances where specific fire initiating found. Therefore this F&O is considered to reclose the PORV or SRV. In this case, special initiator event logic beyond that already in the remain open. The following was noted in a

%ZZIP6U3 is identified as an initiating event that will cause a model was needed. review of the model logic documented in the PORV lift, along with %ZZT2U3. Equipment that can cause F&O. The logic noted under gate I62115 each are not mapped or modeled in the Fire PRA. does not have fire induced failures associated As a result of a previous review, the modeling of Feed-and-Bleed with it, either in the fault tree model directly was changed to assume a loss of feedwater (low SG level) or in the FRANX impacts. The logic under occurred. The shorter time results in a higher HEP for feed-and- gate E1104A does have a propagation of the bleed in all scenarios, regardless of whether a loss of FW risk impacts due to fire via the DC bus occurred. mapping in FRANX.

However, numerous other modeling impacts can occur, that are not modeled.

Under gate I62115, logic for HVAC unit 3S230 failure to start is included when a Loss of offsite power would occur. This logic is applicable only for when a LOOP occurs, and not applicable for non-LOOP events. This type of logic is contained throughout the internal events PRA modeling.

Another example is under gate E1104A, where loss of DC power results in lockout relay failures. There are many other examples throughout the PRA.

Additionally, the identification of the specific initiating event for quantification was not performed per the requirements of FQ-A2. For quantification, the modeled initiating event is assumed to be a reactor trip in all cases.

This treatment does not meet the intent of SR FQ-A2, where the quantified model should encompass the risk contribution from all applicable initiating events. Map all identified internal events

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(CC) initiating events to the specific components that can cause the event, and modify the FPRA to determine the CCDP based on the fire-induced initiating event that results.

1-10 IGN-A9 NOT Transient Fires are postulated in all fire compartments, as listed in This F&O has been resolved. A While the transient influence factors for the Documentation updates are needed MET Appendix B and Table 3-6 of the Ignition Frequency Report. All sensitivity evaluation was performed that PRA might have been updated, as discussed to close this finding. The factors affecting the fire frequency were assessed based upon a involved increasing the weighting factor in the RAI responses, the current documentation updates will not affect slightly modified NUREG/CR-6850 approach. for occupancy and storage from low to documentation still alludes to the use of a the results.

However, the rankings that were provided do not appear to be medium for all instances where such a sensitivity study on the overall PRA as a No impact on RICT application.

consistent with the methods in NUREG/CR-6850, result in an condition could reasonably be expected justification for not updating the factors. As underestimate for fire frequencies in some areas, and an over to occur. The results of this sensitivity this is still the basis for potentially inaccurate estimate in other areas. One F&O is provided on this SR. found that the impact on the calculated values this finding is considered open.

In particular: a) Areas were ranked as zero in maintenance, CDF for each unit was less than 1E-7.

occupancy, or storage even though entrance to the areas is Given this small impact, the existing physically possible, b) Areas were ranked as 1, even though analysis is adequate for the application.

activities were not prohibited by plant procedure.

In areas where the room is sealed during operation (roof plugs),

transients could have been left in the room prior to sealing, so the ranking on this factor should not be zero - per the 6850 guidance.

During the walkdown, Compartments 70 and 71 both had permanently stored breaker grounding devices, with poly-covers, and 71 had a temporary transformer for the polar crane (operating). Both should be ranked as 'medium' for storage.

Similarly, the cable room had storage of 3 temporary fans, cables and blankets and should be marked as medium for storage. This room also appears to include numerous components that will likely be worked on during power, (ranking moderate for non-hot work), and numerous people were present during our limited walkdown.

Compartment 88, an open area in front of the switchgear room, had numerous combustibles stored and located, and should probably be marked as medium or high (presently marked as low). Both area 85 and 88 have frequent foot traffic, and should be marked as medium for occupancy. 85 appears as if it should be moderate for storage (no controls). Similarly; no controls appear to be in place for 116.

The above are samples of identified issues, based on our limited walkdown. It appears there will be similar issues with other areas

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(CC) in the plant. We looked at other areas adjacent to the areas we were in (compartments 87, 84, etc), and expect similar problems with the present rankings.

(This F&O originated from SR IGN-A9) Re-assess the transient fire rankings per the Guidance in NUREG/CR-6850. Confirm the rankings by walkdown of each area, taking into account the actual condition.

1-17 IGN-A10 NOT Table 3-2 includes uncertainty values (EF) for prior and posterior This F&O has been resolved. The The Summary Report (PTN-BFJR-16-057) Documentation updates are needed QU-E3 MET values. However, Error Factors are not propagated to the quantitative uncertainty analysis was was reviewed for the disposition of to close this finding. The UNC-A1 compartment specific ignition frequencies. The other parameters, prepared subsequent to the peer review. uncertainties associated with the error factors documentation updates will not affect UNC-A2 such as conditional failure probabilities for circuit failures, do not A parametric uncertainty evaluation that for the events in the cutsets. The the results.

have uncertainty intervals. The lack of uncertainty intervals would considers fire ignition frequency as well methodology for propagating uncertainties in No impact on RICT application.

not generate meaningful uncertainty interval of the CDF/LERF as other variables was performed that the model is documented in Section 3.14; results. uses a Monte Carlo sampling process. however that section points to Appendices J (This F&O originated from SR IGN-A10) Estimate EFs for The results of the analysis showed a - M as the location of the uncertainty results.

significant fire compartments. mean that was slighter higher than the These sections are identified as Will be ESTIMATE the uncertainty interval of the CDF results. calculated results which was expected. added in follow up revision. This F&O is ESTIMATE the uncertainty intervals associated with parameter considered to remain open uncertainties (DA-D3, HR-D6, HR-G8, IE-C15), taking into account the state-of-knowledge correlation.

1-18 IGN-A7 NOT During walkdowns, several key areas appeared to have ignition This F&O has been resolved. The The fire PRA model was reviewed and only A model change is required to add MET sources not included on the ISDS. specific instances identified in the F&O some of these ignition sources were the new ignition sources in the cable For example, in the cable spreading room, 2 transformers were in were reviewed and the analysis updated dispositioned; however there are still missing spreading room. The impact of these the compartment (3X033 - 75KVA, 3X130 - 45KVA), both accordingly. In addition, the ignition sources. This F&O is considered to new ignition sources is bounded by within the screening distance of targets. Also in the compartment supplemental walkdowns that were remain open. the NUREG-2180 sensitivity risk is CP-600 spectralink cabinet, an open cabinet, the RCP Vibration performed as part of ongoing analysis increase.

Monitoring Cabinet, 4P21 and 4P09 instrument AC panel. Note; refinements efforts for the significant we did not do a 100% review of the CS room, so additional fire areas did not identify any other cabinets may be missing. omissions.

See also F&O 1-19.

(This F&O originated from SR IGN-A7) Perform a re-verification of the ISDS for significant fire areas in the FPRA.

Add missing components to each ISDS, where applicable.

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(CC) 1-19 IGN-A7 NOT It appears the Ignition Source Counting did not count Lighting This F&O has been resolved. A re- The lighting panels that were identified in the Documentation updates are needed MET Panels or other similar panels. For example, there were at least 8 assessment of the lighting panels was finding are still screened out from the fire to close this finding. The lighting panels in the cable spreading room that were not on the performed. The re-assessment focused analysis; however there is no disposition or documentation updates will not affect ISDS. Additional similar panels are located in most electrical on the need for treatment as a fire basis for making this determination. This the results.

rooms we walked down, such as the switchgear rooms and other initiating event. No effort was finding is considered open. No impact on RICT application.

electrical rooms. undertaken to alter the population of Based on our walkdowns, many of the lighting panels should be electrical cabinets considered in the fire included in the ISDS, based on guidance in 6850 and the frequency development.

subsequent FAQ on sealed cabinets. A review of the generic Therefore, the existing values potentially guidance provided for ignition counting did list the screening of have a conservative bias. The assessment small, wall mounted cabinets (sealed). However, the lighting did not identify any instances were panels do not appear to meet the criteria listed in the procedure explicit treatment as a fire initiating (not sealed, numerous switches/breakers), etc. Many of the event was needed.

cabinets are located close to cable trays or other intervening combustibles, so a small fire could result in a larger fire due to spreading.

(This F&O originated from SR IGN-A7) Include unsealed lighting panels and similar electrical cabinets in the ISDS as potential ignition sources.

1-25 FQ-E1 NOT There does not appear to be a review of non-significant cutsets in This F&O has been resolved. Review of Section 4.0 of the Summary Notebook (PTN- Documentation updates are needed QU-D5 MET the PRA documentation. non-significant cutsets performed and BFJR-16-057) notes that A review of the to close this finding. The (This F&O originated from SR QU-D5) Perform a review of documented. cutsets generated from the quantification to documentation updates will not affect non-significant cutsets and accident sequences, as discussed in confirm that nonsignificant cutsets were valid the results.

QU-D5 for the FPRA. was performed, however there is no actual No impact on RICT application.

documentation of this review to support the conclusion that this review was done. This F&O is considered to remain open.

1-27 FQ-E1 NOT Significant fire compartment contributors to LERF are This F&O has been resolved. Added The Summary Report (PTN-BFJR-16-057) Documentation updates are needed LE-F1 MET documented in Appendix C of the summary report. However, the LERF top cutsets and importances run does document the risk results based on to close this finding. The LE-F2 contribution from plant damage states is not provided or the as well as sensitivity analysis in Summary LERF; however there is no disposition of the documentation updates will not affect LE-F3 contributors from LE-B SRs. Report. Also performed and plant damage states as alluded to by the the results.

UNC-A1 Sources of uncertainty, including sensitivity analysis performed, documented the uncertainty evaluation finding; therefore this finding remains open. No impact on RICT application.

are not evaluated for LERF. (This F&O originated from SR LE- for LERF.

F1) Document the contributors to LERF based on the requirements of LE-F1 of the internal events section of the standard, as required by FE-Q1. Document the Sources of uncertainty, including sensitivity analysis performed for CDF in

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(CC)

Appendix D of the Summary Report.

1-38 FQ-F1 NOT Results of the Fire PRA did not include the following: This F&O has been resolved. The The Summary notebook (PTN-BFJR-16-057) Documentation updates are needed QU-F2 MET (e) the total plant CDF and contributions from the different documentation of the analysis results has was reviewed for the items identified in the to close this finding. The UNC-A2 initiating events and accident classes been expanded to include the finding. Only the discussion of importance documentation updates will not affect (i) the uncertainty distribution for the total CDF information noted in the F&O. These measures related to CDF and LERF have the results.

(j) importance measure results results were also reviewed for been added to the notebook, the remainder No impact on RICT application.

(l) asymmetries in quantitative modeling to provide application reasonableness and no issues or of the items identified have not be users the necessary understanding of the reasons such concerns were identified. dispositioned.

asymmetries are present in the model (m) the process used to illustrate the computer code(s) used to perform the quantification will yield correct results process. Some of these issues are listed in other F&Os. However, item e (accident classes), l (asymmetries) and m (validation of computer codes) is not covered elsewhere. (This F&O originated from SR QU-F2) Provide required documentation per QU-F2 and FQ-F1.

3-3 PP-B1 NOT A few cases of special separation are credited in the PB&P. Most This F&O has been resolved. Openings The Plant Partitioning and Fire Ignition Documentation updates are needed MET notable are separation of Fire Compartments 058 and 037 and between fire zones were addressed with Frequency notebook (PTN-BFJR-16-027) to close this finding. The PP-B3 004 and 010. respect to targets on the other side of an was reviewed for a discussion of fire barriers documentation updates will not affect The FHA notes in the write-up for fire zone 004: 'There is a opening which are within the zone of that might credit spatial separation, and no the results.

partial height concrete wall on the South side of this room with a influence of an ignition source. Targets text discussing this position was identified. No impact on RICT application..

full height opening to Fire Zone 10'. were evaluated for fire damage The Hot Gas Layer and Multi-Compartment No justification is provided for this separation, hence it is not regardless of the zone in which they Analysis (PTN-BJFR-16-056) and the Fire clear that the credited separation may be expected to contain the were located. The multi-compartment PRA Scenario Report (PTN-BFJR-16-034) effects of a fire. Accordingly the effect of a fire beyond the analysis considered the volume were also reviewed to see if there is any identified fire compartment boundary may occur. While this associated with adjacent zones with discussion about the zones identified in the effect would be expected to be identified through performance of openings between the zones in F&O and there was no mention of how these the multicompartment analysis the level of documentation evaluating the potential for hot gas layer items were dispositioned in the fire PRA provided in support of the PB&P does not satisfy the standard formation. model; therefore this finding remains open.

requirements.

(This F&O originated from SR PP-B)

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(CC) 3-5 SF-A1 NOT According to the Section 3.13 of the PTN FPRA Summary This F&O has been resolved. The low The Fire PRA Summary notebook (PTN- Documentation updates are needed MET Report the effect of an earthquake on ignition source scenarios is seismic spectra applicable to the Turkey BFJR-16-057) was reviewed for a discussion to close this finding. The discussed in the IPEEE and Potential Fire Related Vulnerabilities Point site have been validated via the the seismic fire interaction. The assessment of documentation updates will not affect self assessment. Review of the Potential Fire Related IPEEE with respect to the potential for the seismic interaction is that there is not the results.

Vulnerabilities self assessment did not reveal an analysis that causing unique fire scenarios. Their potential for a seismic event at Turkey Point; No impact on RICT application.

specifically addresses generation of fire ignition source scenarios potential for causing damage to pipes or however beyond this there is no discussion which could result from an earthquake, nor does this assessment tanks containing combustible gases or about the unlikely nature for a seismic event address the potential risk significance of these scenarios. This liquids or to initiation of electrical fires is causing damage to the suppression systems or assessment does identify fire vulnerabilities in terms of fuels, considered negligible. causing new ignition sources. This F&O is ignition sources, and oxidizers however these discussions are not considered to remain open.

specific to seismic events nor do they include evaluation of special ignition scenarios that may arise from an earthquake.

(This F&O originated from SR SF-A1) 5-13 FQ-A3 NOT Turkey Point FPRA Summary Report NUREG/CR-6850 Task This F&O has been resolved. The The Fire PRA Summary Report (PTN-BFJR- Documentation updates are needed MET 16 Report No. 049306006.005 Rev. 1 Tables A-1, A-2, B-1 and B- identified data differences were reviewed 16-057) in Appendix I states that the to close this finding. The 2 documented the Units 3 & 4 Fire PRA quantification Results and confirmed to be reflective of the asymmetry was discussed with the site and documentation updates will not affect for both CDF and LERF for all fire scenarios that were design and layout of the units. that the configuration is consistent with plant the results.

quantified. Scenario 096-A was randomly picked review for both Additional comparison of the design. As noted in the current FRANX No impact on RICT application.

Units 3 & 4. The CDF/LERF results are consistent between the quantification results between the two models the additional altered events that only Summary Report and ZoneScenarios in database files, Unit 3 units was also performed to ensure that impact Unit 4 are still present; however in the CDF any significant differences in results are quantification of these scenarios FRANX consistent with the actual unit provides a warning message that the assumed PTNFIRE_W_LERF_MH_ESF.mdb, Unit 3 LERF differences. Various asymmetries in the altered events cannot be added to the fire PTNFIRE_W_LERF_MH_ESF.mdb, Unit 4 CDF plant layout were identified. scenario because the nominal basic events are U4PTNFIRE_W_LERF_MH_ESF.mdb, and Unit 4 LERF not damaged by the fire. There is no U4PTNFIRE_W_LERF_MH_ESF.mdb. However, reviewing discussion of the asymmetry in the document the AlteredEvents table in each database files shows inconsistent or others that are alluded to in the F&O basic events impacted between Unit 3 and 4. Unit 3 have no basic resolution. This F&O is considered to remain event impacted, while Unit 4 have 9 basic events listed. open.

(This F&O originated from SR FQ-A3)

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(CC) 6-9 FQ-A4 NOT The parametric uncertainty analysis as discussed in QU-E3 This F&O has been resolved., The Summary Report (PTN-BFJR-16-057) Documentation updates are needed MET (estimate of uncertainty intervals, etc.) is not performed. Parametric uncertainty has been was reviewed for the disposition of to close this finding. The QU-A3 performed for CDF and LERF for each uncertainties associated with the error factors documentation updates will not affect Also, the state-of- knowledge correlation between fire-specific units FPRA. for the events in the cutsets. The the results.

event probabilities (e.g., suppression system unavailabilities, fire methodology for propagating uncertainties in ignition frequencies, hot short conditional probabilities, etc.) No impact on RICT application.

the model is documented in Section 3.14; hasn't yet been applied. (This F&O originated from SR QU-A3) however that section points to Appendices J

- M as the location of the uncertainty results.

These sections are identified as Will be added in follow up revision. This F&O is considered to remain open.

6-20 CF-A2 NOT The parametric uncertainty associated with conditional circuit This F&O has been resolved., The PRA database (.RR file) did not contain Documentation updates are needed UNC-A2 MET failure probabilities are not evaluated and are not incorporated Parametric uncertainty has been error factors (EFs) for events such as fire- to close this finding. The into the model. performed for CDF and LERF for each induced valve failures or spurious actuations documentation updates will not affect (This F&O originated from SR CF-A2) Develop uncertainty units FPRA. of components due to fire, both of which the results.

intervals for applied hot short probabilities and include them in would be typical circuit failure events. Altered No impact on RICT application.

the model. basic event probabilities as listed in Appendix A of the fire scenario report (16-034) would have EF data supplied by the type code data but no discussion of uncertainty is presented in this report. Additionally, nearly all fire-related HFEs do not have EFs in the .RR file.

The Turkey Point Nuclear Plant FPRA Summary report, revision 12, was reviewed.

The methodology used to perform the uncertainty analysis was described. However, the results of the uncertainty analysis was not included in this report. Appendices J - M are noted as the location of the uncertainty results. These sections are identified as Will be added in follow up revision. This F&O is considered to remain open.

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(CC) 7-3 PRM-14 NOT The current model uses the LERF model for the PTN revision 9 This F&O has been resolved. A review The Component and Cable Selection Documentation updates are needed MET model (PTN-BJFR-99-010, Rev. 1) and maps appropriate of the mapping of Level 1 sequences to notebook (PTN-BFJR-16-057) was reviewed to close this finding. The equipment impacts into the system models used to model LERF. the plant damage states in the LERF for a discussion on the impacts from fire to documentation updates will not affect No new accident progressions beyond the onset of core damage model was reviewed. No new accident LERF. There is no disposition of the events the results.

were identified for the fire PRA. However, there is no progressions that required associated with LERF impacts; containment No impact on RICT application.

documentation that a specific review of the accident progressions E146modification of the LERF model spray, containment heat removal, or leading to LERF was conducted to identify whether new were identified. containment isolation. It was noted in the considerations should be addressed in the fire PRA. In addition, Fire Scenario Report (PTN-BFJR-16-034) effects on PDS mapping due to fire-induced failures may not be that there are numerous items that are appropriately captured. For example, RWST diversion of the assumed failed and among them are the RWST to the containment sump is modeled as a failure of HHSI containment spray pumps and containment which would normally go to a dry containment PDS. However, heat removal fans. This F&O is considered to the actual PDS should be one for wet containment. While this is a remain open.

late containment failure concern rather than a concern for LERF, there may be similar fire induced failures that could affect the mapping of LERF accident progressions. (This F&O originated from SR PRM-B14) 8-3 PRM-B2 NOT Attachment U - Internal Events PRA Quality (DRAFT), This F&O has been resolved. The The current FPRA documentation was Documentation updates are needed MET document applicability of Internal Events F&Os to internal internal events PRA model F&Os that reviewed. No discussion regarding the to close this finding. The events PRA, but not to Fire PRA. There was no evidence that the have not been resolved/closed have disposition of the Internal Events F&Os documentation updates will not affect review of F&O disposition status addressed the question of been reviewed and found to have no related to their impacts on FPRA could be the results.

whether the disposition that was taken would adversely affect the negative impact on Fire PRA results or found. This F&O is considered to remain No impact on RICT application.

development of the fire PRA. This F&O is derived from 2010 this application. open.

Fire PRA peer review F&O 4-4.

(This F&O originated from SR PRM-B2) 9-6 FSS-D7 NOT The system unavailability records for the plant have not been This F&O has been resolved. The fire As documented in the Fire PRA Summary Documentation updates are needed MET reviewed in crediting fire detection and suppression systems. This protection system availability data for Report (PTN-BFJR-16-057), a review of the to close this finding. The F&O supersedes 2010 FPRA peer review F&O 2-26 (This F&O PTN has been reviewed and no outlier plant specific unavailability was done and documentation updates will not affect originated from SR FSS-D7) behavior has been identified. compensatory measures were in place for all the results.

instances. As noted in the RAI response No impact on RICT application.

documented in ML13038A310, this review was from March 2009 to January 2012 and that review would meet the requirements to close this F&O. However, as is further noted in the Summary Report, the documentation of this review has not been incorporated into

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(CC) the fire PRA and this finding is considered to remain open.

10-1 FSS-C1 NOT The 2010 peer review identified that "Fire modeling was This F&O has been resolved. The Two-point fire modeling is not used in the The existing treatment retains some FSS-G1 MET conducted via generic fire modeling from which Zones-Of- recommended resolution action in the Fire Scenario Report. This makes for a more conservatism which results in this SR Influence (ZOI) for specific initiator types was generated. The F&O was assessed in the context of the conservative identification fire damage but is meeting CC I.

ZOIs were used to define bounding fire characteristics for each dominant fire risk contributors. This only consistent with a Category I analysis. For This is adequate for the RICT fire scenario. Characteristics that are used to bound potentially assessment concluded that further the panel fraction, Section 8 of the Fire application, as this conservative bias risk contributing fire events are identified in Attachment B of the refinements such as that described in the Scenario report gives the basis of FAQ 14-would tend to overestimate the risk Fire Scenario Report, (Report 0493060006.004). Based on the use F&O would not substantively change 0009 which was 'current' at that time.

metric that is used to judge the of a bounding approach the results of the analysis. The existing However, this FAQ was revised to include acceptability of this application.

this SR is judged to be met at CC I. Significant fire scenarios treatment retains some conservatism various cable insulation materials which lead should be developed with 2-point fire modeling." Since this which results in this SR meeting CC I. to differing SFs. Section 5 of the Fire review, FP&L has stated that "The use of a panel split fraction to This is adequate for the NFPA 805 Scenario report notes that PTN is assumed to differentiate between fires impacting the panel and components application, as this conservative bias have only thermoplastic cables. From the with cables terminating at the panel versus panel fires impacting would tend to overestimate the risk revised FAQ notes a SF of 0.104 for non-cables outside of the panel provides an equivalent and more metric that is used to judge the qualified (thermoplastic) source and target useful two point fire model." The Panel Split fraction is acceptability of this application. The combinations. Therefore the use of the 0.1 developed from a supplemental report (ERIN report, issue regarding the ERIN panel split assumption is slightly non-conservative and Supplemental Fire PRA Methods, dated February 2010). This fraction is addressed in the disposition the discussion included in the Fire Scenario document was submitted to the EPRI Fire PRA Methods Review for F&O 10-3. report is now outdated compared to the FAQ Panel. This review is not complete as of the date of this peer wording. This F&O should remain open due review. Use of the split fraction method is based on industry to the panel fraction non-conservatism and events rather than site specific fire ignition sources and target the retained Category I SR.

configurations and therefore, could result in nonconservative frequency estimates of target damage. (This F&O originated from SR FSS-C1) Perform 2-point fire modeling, when applicable, for risk significant fire scenarios.

10-2 FSS-A1 NOT The 2010 review of PTN Tasks 8 and 11 Report 0493060006.004, This F&O has been resolved. The Fire PRA Scenario report (PTN-BFJR- Documentation updates are needed MET identified that 'no hydrogen fires other than turbine/generator Miscellaneous hydrogen fires have been 16-034) was for hydrogen fires and their to close this finding. The have been postulated.'(Previously F&O 5- 16) Since this Finding incorporated in the Fire PRA in the associated impacts in the fire areas that were documentation updates will not affect was identified, FP&L has determined that 'Miscellaneous charging pump room fire areas where noted in the F&O (045, 055, 082, and 087). the results.

Hydrogen piping at PTN is limited to hydrogen supply to the the hydrogen lines associated with VCT As discussed in Appendix I of the fire PRA No impact on RICT application.

VCT tanks. The associated piping is located in the charging pump cover gas are routed. Summary report (PTN-BFJR-16-057) the rooms (Fire Zones 45 and 55). Fires in these fire zones are scenarios for each of these zones are base assumed to impact all components in the fire zone. The scenarios and the entire fire ignition associated risk is low given the availability of thermal barrier frequency is apportioned to these scenarios.

cooling for RCP seals and HHSI pumps. Allocation of the IGF Reviewing the Plant Partitioning and Fire

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(CC) associated with miscellaneous hydrogen fires to these fire zones Ignition Frequency report (PTN-BFJR would result in an increase in the ignition frequency for these 027) for the development of the ignition zones by less than a factor of 3. Given the low risk significance of frequency for these areas showed that the these zones this will have a negligible impact on overall plant risk charging pump rooms (045 and 055) do not and the charging pump rooms will remain low risk contribution have any fire contribution from hydrogen fire zones. Incorporation of this ignition frequency into the fires (Bin 19). Additionally the review of the associated documentation will be incorporated in a future revision other fire areas (082 and 087) showed that the to the documentation.' Hydrogen fires are also being developed contribution to Bin 19 for both zones was for H2 piping and valves in Compartments 82 and 87 (scenarios based on an assumed factor, i.e. 0.5 per zone 82-P and 87-P). However, since these do not appear yet in the and not on the actual plant configuration.

Fire Scenario Report, action is required. This finding is currently This F&O is considered to remain open.

being addressed and appears to be resolved once the new H2 fires are included in the model and documentation is updated.

(This F&O originated from SR FSS-A1) Incorporate the hydrogen fire scenarios being developed into the model, and update documentation as necessary.

10-4 FSS-C8 NOT One situation was identified for which credit of fire wrap is taken This F&O has been resolved. A PTN-BFJR-16-034, Fire PRA Scenario Documentation updates are needed MET in Compartment 96 for ignition source 3B04, which is a 480V qualitative assessment has been Report, was reviewed. Currently the only to close this finding. The load center. This fire wrap protects PB3319, PB3813, PB7022, performed to assess the potential impact credited wrap documented in the report is in documentation updates will not affect and PB7521. The wrap appears as being credited in a HEAF of this F&O. scenario 096-E-PTB, Transient Fire Located the results.

scenario. No justification for crediting this wrap assuming next to riser 3ATF10, to protect 3A1301.

The hose stream test imposed on the No impact on RICT application.

mechanical damage and direct flame impingement from the This wrap is credited in the current FRANX fire barrier qualification subsequent to HEAF is provided. Similar issue for 3B03 also in Compartment model. However, no discussion could be fire exposure is considered to provide a

96. Thermo-lag is also seen as credited in some scenarios, which found in the documentation regarding the comparable level challenge to the would require justification due to issues with this particular type acceptability of this wrap. This finding is thermolag barrier as would the HEAF of cable barrier. (This F&O originated from SR FSS-C8) considered to remain open.

force applied at the onset of fire exposure.

10-8 FSS-D4 NOT Ambient conditions are assumed in the Generic Fire Modeling This F&O has been resolved. A An evaluation of the impact of higher Documentation updates are needed FSS-H4 MET Treatment Report (prepared by Hughes). Ambient temperature is qualitative assessment has been ambient temperatures was completed as part to close this finding. The assumed to be 68°F for all calculations. No technical discussion performed to assess the potential impact of PTN-BFJR-16-013, Generic Fire Modeling documentation updates will not affect or justification is provided in the Fire Scenario Report to of this F&O. Treatments. The evaluation shows that the the results.

substantiate that this is a reasonable value for the compartments critical heat flux is diminished by ~17% for The sensitivity of the ZOI dimensions No impact on RICT application.

where this was applied. (This F&O originated from SR FSS-D4) an increase in ambient temperature of 60 to the ambient temperature is relatively Assess areas where elevated ambient temperatures could be appear to have been used in developing the low as described in the original Hughes experienced and justify the acceptability of the models used. target damage in the BFJR-16-034 Fire PRA Generic Fire Modeling treatments Otherwise, incorporate elevated ambient temperatures into the report, in particular for IEEE-383 Scenario Report and no explanation provided

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(CC) zone of influence calculations. qualified/Thermoset cables. In the case for not using the lower critical heat flux. The of an initial ambient temperature of noted F&O closure uncertainty assessment 35°C, the expected affect on the ZOI could not be located, but is only stated as dimensions is within the measurement valid up to 95F. Is there any documentation uncertainty in the field. that all areas of PTN are not greater than this temperature? A typical higher ambient temperature assessment for NPPs will have 105F or higher depending on site-specific information. This F&O is considered to remain open.

10-11 FSS-C2 NOT The 2010 peer review identified that "fire scenario evaluation This F&O has been resolved. The F&O should remain open since the SR is The resulting categorization of the FSS-C3 MET tools were developed based on the Generic Fire Modeling recommended resolution involves the remaining at Category I (explanation as to related SR is CC 1. Since the FSS-G1 Treatments. These walkdown/evaluation tools are based on crediting of growth and decay in the why PTN is accepting this is given in the approach results in some bounding fires that are assumed to cause target damage at a modeling of the postulated fire. The F&O closure document). conservatism being retained in the height above the base fire with the fire burning at peak intensity existing analysis does not take credit for results, this CC is judged to be and without burnout times. Because these tools assume a fire these variables. A review of the adequate for the RICT applications as burning at peak intensity and without burnout, this SR is dominant fire scenarios found that the the conservative bias would tend to considered met at CC I." Since the review, FP&L has stated that risk benefit that might be gained is result in the overestimation of the "The use of a panel split fraction to differentiate between fires minimal. Therefore, this refinement was risk metrics used for this application.

impacting the panel and components with cables terminating at not performed. The resulting the panel versus panel fires impacting cables outside of the panel categorization of the related SR is CC 1.

provides an equivalent and more useful two point fire model... Since the approach results in some The application of the two point treatment to individual fire conservatism being retained in the scenarios is carried through to the MCA/HGL evaluation which results, this CC is judged to be adequate addresses the impact of each scenario on MCA." The Panel Split for the NFPA 805 applications as the fraction is developed from a supplemental report (ERIN report, conservative bias would tend to result in Supplemental Fire PRA Methods, dated February 2010). This the overestimation of the risk metrics document was submitted to the EPRI Fire PRA Methods Review used for this application.

Panel. This review is not complete as of the date of this peer review. Use of the split fraction method is based on industry events rather than site specific fire ignition sources and target configurations and therefore, could result in nonconservative frequency estimates of target damage. (This F&O originated from SR FSS-C2) Include fire growth and decay for risk significant fire scenarios.

L-2018-001 Attachment 3 Page 24 of 27 Capability Finding Supporting Category Description Resolution for Independent Review Independent Review Comments Disposition for RICT Number Requirement(s)

(CC) 10-14 FSS-A5 NOT Beyond the Generic Fire Modeling Treatments, the Fire PRA did This F&O has been resolved. The Resolution listed as consistent with Category The current analysis is consistent with MET not include additional detailed fire modeling for most fire current analysis is consistent with a I. PTN fire PRA uses mainly scoping or a Capability Category I analysis. This compartments. Note 4 (under FSS-A5 of the ASME Standard) Capability Category I analysis. This conservative modeling which is generally the provides a degree of conservatism in states that "once a fire scenario has been selected, this implies provides a degree of conservatism in the early stages of a graded modeling approach. the analysis which would also tend to that the scenario will eventually be evaluated and/or quantified at analysis which would also tend to F&O should remain open since the SR is overestimate the change in risk which a level of detail commensurate with the risk significance of the overestimate the change in risk which is remaining at Category I (explanation as to is reported for the RICT application.

scenario." (This F&O originated from SR FSS-A5) Consider reported for the NFPA 805 application. why PTN is accepting this is given in the A review of the results of the performing additional detailed fire modeling to provide A review of the results of the application F&O closure document). application analyses indicates more "reasonable assurance that the fire risk contribution of each analyses indicates more rigorous analyses rigorous analyses consistent with CC unscreened physical analysis unit can be characterized." consistent with CC II or CC III would II or CC III would not alter the not alter the conclusions of the analyses. conclusions of the analyses.

10-15 FSS-C7 NOT PTN credits multiple suppression paths for MCA/HGL This F&O is resolved. A review of the PTN-BFJR-16-008, FPRA Hot Gas Layer Documentation updates are needed FSS-G1 MET evaluation. However, the dependencies have not been evaluated credited suppression systems in the and Multi-Compartment Analysis states that to close this finding. The FSS-H7 and modeled. For example, fixed suppression and fire brigade Multi-Compartment /Hot Gas Layer the detection systems credited for notifying documentation updates will not affect response may both rely on a single detection system. (This F&O analysis has confirmed that no the fire brigade need to be independent of the the results.

originated from SR FSS-C7) When multiple suppression paths are dependency exists between the detection system that actuates the No impact on RICT application.

credited, perform a review and address any dependencies between suppression systems and detection suppression system but never documents the suppression and detection systems credited in the MCA/HGL systems. Detection in the zones with results of the closure document's verification calculation. suppression systems is associated with that the detection and suppression are on an independent detection system. independent systems. The documentation to show that only manual or automatic suppression is credited is not discernable from the tables in the MCA report. This documentation for independence of detection and suppression needs to be added to the MCA report. This F&O is considered to remain open 10-18 FSS-A1 NOT In at least two cases, transient fire scenarios have not been This F&O has been resolved. The noted zones are no longer listed as Documentation updates are needed MET included in the fire modeling for some compartments (e.g., fire Supplemental walkdowns were screened. However, several zones use a to close this finding. The compartments 67 and 68). Per discussion with FP&L the performed to re-assess the treatment of reduced transient HRR of 69 kW rather than documentation updates will not affect transients may have been excluded based on the dominance of transient fires. These walkdowns the normal 98th-percentile value of 317 kW. the results.

the frequency of fixed scenarios. However, transients should only focused on two key attributes - the Update of the zones with the reduced No impact on RICT application.

be excluded when precluded by design. Based on the size of these appropriateness of the selected HRR transient HRR has typically been done for rooms, and the presence of secondary combustibles, transient characterization and the location of the other plants using this treatment of reduced fires could lead to fire growth and eventually HGL, and therefore postulated fire scenarios. The postulated transient HRRs. Typical updates could

L-2018-001 Attachment 3 Page 25 of 27 Capability Finding Supporting Category Description Resolution for Independent Review Independent Review Comments Disposition for RICT Number Requirement(s)

(CC) should be analyzed. (This F&O originated from SR FSS-A1) location for the treatment of transient include ZOI assessments using a HRR of 317 Include transient scenarios in all compartments where fire fires was based on where a transient kW but lower transient ignition frequency modeling has been employed. ignition source might reasonably occur. distribution factors if plant-specific The results of these walkdowns were combustible control procedures are incorporated into the FPRA analysis. applicable. In addition, the Fire PRA Scenario Report (PTN-BFJR-16-034) includes transient fires as scenarios for the two specific fire compartments mentioned.

However, not all fire compartments have transient ignition source scenarios. This F&O is considered to remain open, given the need to justify any rooms that do not have transient ignition source scenarios - typically based on physical inaccessibility only.

10-19 FSS-H1 NOT For fire modeling analysis of transient fires, FP&L implements a This F&O has been resolved. The The explanation for not having physical Documentation updates are needed MET floor area weighting factor. However, the documentation does specific instance noted in the F&O was layout drawings showing the transient ignition to close this finding. The not include a graphical representation of the assumed transient corrected. In addition, supplemental sources is acceptable. There is no requirement documentation updates will not affect locations and boundaries. It is therefore not possible to review walkdowns were performed to re-assess to have drawings showing the footprint of the the results.

(or update) transient fires. Also during review of transient the overall treatment of transient fires. ignition sources. However, there still appears No impact on RICT application.

weighting factors it appears to have been double counted in some These walkdowns focused on two key to be to identical scenarios J-PTB and J-FRE compartments (e.g., compartment 63). Based on discussion with attributes - the appropriateness of the in Fire Compartment 063. Both scenarios are FP&L this was due to an error in the Excel based spreadsheet selected HRR characterization and the identified as Transient fire located in front tool for transient frequency quantification. This appears to be an location of the postulated fire scenarios. of C-281-A due to cutting& welding and isolated case and will be corrected. (This F&O originated from However, the documentation that was general transients. The data in each appears SR FSS-H1) Update documentation to include a graphical generated did not specifically produce to be the same, so it is unclear why they are representation of transient fire locations and boundaries. graphical representations. Instead, the identified as 2 scenarios. This F&O is information was incrementally enhanced considered to remain open.

to provide a spatial reference to a location with in the space. The need for special depiction of transient fire scenario locations will be addressed in conjunction with the development of procedures for post transition configuration control.

L-2018-001 Attachment 3 Page 26 of 27 Capability Finding Supporting Category Description Resolution for Independent Review Independent Review Comments Disposition for RICT Number Requirement(s)

(CC) 10-20 FSS-A1 NOT The fire modeling analysis of the Turbine Generator (T/G) fires This F&O has been resolved. The Section 6 of the Fire Scenario report notes A model change is required to add MET is performed in accordance with Appendix O to NUREG/CR- analysis documentation has been the methods used for the large turbine new scenarios to address the Turbine 6850. However, there is no discussion regarding the lack of updated to address catastrophic T/G building fires, but no valid scenarios could be Generator fires. Fires in the turbine analysis of the catastrophic T/G fire event, which should fires that may lead to building collapse easily located in the report for those sources. building have low risk significance consider blade ejection, oil line rupture, and hydrogen explosion. or other significant widespread damage. Areas such as compartment 076 and 081 due to limited impacts on equipment Per discussion with FP&L, the catastrophic fire was discounted The results of this update did not would be expected to have catastrophic related to safely shutting down the since the T/G is located outdoors. While this may not result in identify any new risk significant impacts for this methodology. Compartment plant and as such, the new scenario hot gas layer formation and structural collapse, a review of the contributors or insights. 117 does not seem to have counted turbine risk is bounded by the NUREG-2180 guidance is warranted, and inclusion of this event frequency generator ignition sources such as Bin 34 or sensitivity risk increase.

should as a minimum map to the loss of the T/G and if 35. This F&O is considered to remain open suppression fails, all equipment within the T/G structure. (This given the lack of the above noted ignition F&O originated from SR FSS-A1) Perform a review of the sources or a discussion as to why they are not catastrophic T/G fire in accordance with Appendix O to of concern for PTN.

NUREG/CR-6850, or document the justification for excluding this event at PTN.

10-21 FSS-C3 NOT The supplemental generic Fire Model Treatments: Transient This F&O has been resolved. Other NEE fire PRAs were updated to 205C Documentation updates are needed FSS-G1 MET Ignition Source Strength includes an assumption for transient Supplemental walkdowns were or 330C depending on cable material type to close this finding. The FSS-H2 burnout of 12 minutes. This burnout time is based on an assumed performed to re-assess the treatment of (see DAEC F-25), however, that was not documentation updates will not affect fire loading and the 317kW heat release rate, and appears to be transient fires. These walkdowns did not done for PTN. PTN-FPJR-16-014 justifies the results.

optimistic given the uncertainty in transient fire loading. The identify any instances where an altering the use of the 12 minute fire duration as No impact on RICT application.

burnout is then used to develop a zone of influence for of the transient fire duration had any noted in the F&O closure report, but the use thermoplastic targets, based on the thermal response tables in material impact on the HGL and MCA. of the higher 260F scoping modeling failure Appendix H to NUREG/CR-6850 for thermoplastic cable at The documentation has also been criteria is not appropriate. Duration of 260°C. Since this resultant vertical zone of influence is used to updated to address the criteria used for fire/hot gas exposure can be credited in screen transient scenarios from impacting secondary targets selecting the characteristic transient fire detailed fire modeling for specific cases, but higher than 7.3 feet from the floor, additional justification is HRR. The approach is consistent with not as done here. This F&O is considered to needed to demonstrate that a 12 minute fire, and subsequent use the recently issued guidance from the remain open pending resolution of the items of 260°C damage threshold is appropriate for screening purposes. EPRI/NRC review panel. The results of noted here.

Also noted is that Attachment B to the Fire Scenario Report zone these walkdowns were incorporated into of influence does not reflect the same values recommended by the FPRA analysis.

the Generic Fire Model Treatment. As an example, the The twelve minute fire corresponds to differentiation between transient Severe and Non-Severe the 317 kW fuel package only and categories is not based on a 317kW fire. This appears to be a represents ~ 35 lb. of Class A material.

documentation issue only. (This F&O originated from SR FSS- Additional discussion is provided in Rev.

C3) Provide additional justification for the applied transient fire 0 of Supplement 3 of the Hughes analysis as a screening approach. Consider increasing the burnout Generic Fire Modeling treatments that time and using the NUREG/CR-6850 recommended damage examines the fire durations and test

L-2018-001 Attachment 3 Page 27 of 27 Capability Finding Supporting Category Description Resolution for Independent Review Independent Review Comments Disposition for RICT Number Requirement(s)

(CC) threshold to 205°C to bound uncertainties in fuel loading for durations of all NUREG/CR 6850 tests.

transient fires. It is shown that the method used to determine a 12 minute fire predicts or overestimates the fire duration in all cases and is therefore a sound approach.