ML19137A118

Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome High Thermal

ML19137A118
Person / Time
Site:	Palo Verde
Issue date:	05/17/2019
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07921-MLL/MDD
Download: ML19137A118 (11)

Text

10 CFR 50.90 10 CFR 50.12 Qaps 102-07921-MLiyMDD May 17, 2019 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 MARIA L. LACAL Senior Vice President, Nuclear Regulatory A Oversight Palo Vordo Nuclear Gonaratlng Station P.O. Box 52034 Phoenix, AZ 85072 Mall Station 7605 Tal 623.393.6491

References:

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2.

3.

Arizona Public Service Company (APS) letter number 102-07727, License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel, dated July 6, 2018, [Agencywide Documents Access and Management System (ADAMS) Accession Number ML18187A417]

APS letter number 102-07807, Supplemental Information Regarding License Amendment and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel, dated October 18, 2018, (ADAMS Accession Number ML18296A466)

NRC correspondence to APS, Palo Verde 1, 2, and 3 - Official RAIs from IRAB for Framatome HTP Fuel LAR and Exemption (EPIDs L-2018-LLA-0194 and L-2018-LLE-0010), dated April 5, 2019, (ADAMS Accession Number ML19098A187)

Dear Sirs:

Subject; Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, 50-530 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Reiated to the Impiementation of Framatome High Thermai Performance Fuei By letter dated July 6, 2018 (Reference 1) and supplemented by letter dated October 18, 2018 (Reference 2), Arizona Public Service (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR) and an exemption request pursuant to the provisions of 10 CFR 50.12 for PVNGS Units 1, 2, and 3 requesting approval of changes to the PVNGS Technical Specifications (TS) related to the Implementation of Framatome High Thermal Performance (HTP') fuel.

The proposed LAR would revise the TS requirements related to using M5 as an approved fuel clad material and gadolinia as a burnable absorber and revise the topical reports in TS 5.6.5, Core Operating Limits Report (COLR). These references include analytical methods that determine core operating limits using Framatome large break and small break loss of coolant accident (LOCA) evaluation models, the Framatome COPERNIC fuel performance code, the Framatome critical heat flux (CHF) correlation, and the Electric Power Research Institute (EPRI) VIPRE-01 thermal-hydraulic code.

A member of the STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

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102-07921-MLiyMDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to NRC IRAB Branch RAIs Regarding LAR to Implement Framatome HTP' Fuel Page 2 The U.S. Nuclear Regulatory Commission (NRC) staff provided requests for additional Information (RAIs) from the Reactor Assessment and Human Factors Branch (IRAB) by NRC correspondence, dated April 5, 2019 (Reference 3). The Enclosure to this letter provides the APS response to the RAIs. The RAIs do not affect the conclusions of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the LAR.

No new commitments are being made In this ietter.

If you have any questions about this request, please contact Michael D. DiLorenzo, Licensing Department Leader, at (623) 393-3495.

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

Executed on: Mav 17. 2019 Sincerely, MLiyMDD/mg

Enclosure:

Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel cc:

S. A. Morris S. P. LIngam C. A. Peabody NRC Region IV Regional Administrator NRC NRR Project Manager for PVNGS NRC Senior Resident Inspector for PVNGS

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Impiement Framatome High Thermal Performance Fuel

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Impiement Framatome High Thermai Performance Fuel Introduction By letter dated July 6, 2018 [Agencywide Documents Access and Management System (ADAMS) Accession Number ML18187A417 (Reference 1)], and a supplemental letter dated October 18, 2018 [ADAMS Accession Number ML18296A466 (Reference 2)], Arizona Public Service (APS) submitted a License Amendment Request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), and an exemption request pursuant to the provisions of 10 CFR 50.12, for Paio Verde Nudear Generating Station (PVNGS) Units 1, 2, and 3. The proposed LAR requested approvai of changes to the PVNGS Technicai Specifications (TS) related to the implementation of Framatome High Thermal Performance (HTP^") fuel with M5 as a fuel rod cladding material and gadollnia as a burnable absorber.

The proposed TS changes included the addition of a reactor core Safety Limit (SL) for the peak fuei centerilne temperature for Framatome fuel [TS 2.1.1]; administrative changes to the description of fuel assemblies used in PVNGS reactor cores [TS 4.2.1]; and the addition of several topical reports that describe analytical methods to be used in the determination of core operating limits, Inciuding Framatome large break and small break Loss of Coolant Accident (LOCA) evaluation models, the Framatome COPERNIC fuel performance code, the Framatome BHTP Critical Heat Flux (CHF) correlation, and the Electric Power Research Institute (EPRI) VIPRE-01 thermal-hydraulic code [TS 5.6.5].

Adoption of the Framatome small break LOCA methodology requires consideration of reactor coolant pump (RCP) trip timing in accordance with a U.S. Nuclear Regulatory Commission (NRC) Safety Evaluation (SE) dated February 1, 2017 and revised SE dated March 17, 2017

[ADAMS Accession Numbers ML16356A406 (Reference 3) and ML17082A173 (Reference 4)]. Specifically, the NRC Safety Evaluation notes that continued operation of RCPs following a small break LOCA may have a detrimental effect upon core uncovery and Peak Cladding Temperature (PCT) for certain break sizes and break locations, due to redistribution of coolant Inventory within the primary system which may affect hydraulic response. The NRC accepted Framatome's evaluation procedure for determining the RCP trip timing In plant emergency operating procedures (EOPs) following a small break LOCA.

Consequently, APS proposed a time critical action (TCA) RCP trip time of 5 minutes following the loss of subcooled margin, that is, net positive suction head (NPSH), in Its LAR (Reference 1).

On April 5, 2019, the NRC staff transmitted requests for additional Information (RAIs) from the Reactor Assessment and Human Factors Branch (IRAB) to APS, requesting further Information about the proposed RCP trip TCA [ADAMS Accession Number ML19098A187 (Reference 5)]. This enclosure provides the APS response to the RAIs. The NRC staff RAIs are provided first, followed by the APS response.

lRAB-RAl-1 Section 50.34(f)(2)(iii) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 requires, in part, that the licensee or applicant provide, for Commission review, a control room design that reflects state-of-the-art human factor principles. Section 50.34(f)(3)(l) of 10 CFR 50 requires that the licensee or applicant provide administrative procedures for evaluating operating, design, and construction experience and for ensuring that applicable important industry experiences will be provided in a timely manner to those designing and constructing the plant.

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel Chapter 18, Revision 3, "Human Factors Engineering" of NUREG-0800, "Standard Review Pian for the Review of Safety Anaiysis Reports for Nudear Power Plants: LWR Edition" (ADAMS Accession No. ML16125A114), provides guidance for the review of Human Factors Engineering (HFE) considerations of plant modifications and important human actions (HAs).

NUREG-0711, Revision 3, "Human Factors Engineering Program Review Model" (ADAMS Accession No. ML12324A013), provides guidance for the NRC staff's review of HFE programs, to ensure that HFE practices and guidelines were appropriately considered and incorporated in the plant design and modifications. NUREG-1764, Revision 1, "Guidance for the Review of Changes to Human Actions" (ADAMS Accession No. ML072640413), provides guidance for reviewing changes to HAs, such as those that are credited In nuclear power plant safety analysis.

NUREG-0711, Review Element 11, "Human Factors Verification and Validation," provides guidance for the NRC staff's evaluation of the verification and validation (V&V) activities, which comprehensively determine that the HFE design conforms to HFE design principles and that It enables plant personnel to successfully perform their tasks to assure plant safety and operational goals. Section 11.4.3, "Integrated System Validation," states, in part, that the objective of the Integrated System Validation (ISV) review is to verify that the applicant validated, using performance-based tests, that the integrated system design supports the safe operation of the plant.

Section 4.4 of the Enclosure to APS letter dated July 6, 2018, states that although the TS changes do not involve any plant modifications that could affect system reliability, component performance, or the possibility of operator error, there is a new time requirement for an existing operator action. Specifically, Section 7.2 of Attachment 10 to the licensee's letter dated July 6, 2018, identifies the affected operator action as the manual action to stop all Reactor Coolant Pumps (RCPs) when pressurizer pressure drops below the RCP net positive suction head limits, during a small break loss of coolant accident.

Please provide additional information regarding the V&V activities that were conducted to provide reasonable assurance that the HAs can be accomplished within the newly established time limits. In your response, provide Information that addresses the applicable criteria described in Section 11.4.3 of NUREG-0711.

APS Response to IRAB-RAI-1 As stated In the APS LAR dated July 6, 2018 (Reference 1), tripping the RCPs following a loss of subcooled margin (i.e., NPSH) Is an existing operator action in the PVNGS EOPs.

Tripping of the RCPs is required by procedure 40EP-9E001, Standard Post Trip Actions (Reference 6), which specifies operator actions, including immediate actions, that must be accomplished following an automatic or manually initiated reactor trip, as well as diagnostic actions necessary to determine a preliminary diagnosis of an event such as a LOCA.

Tripping of the RCPs is also required by procedure 40EP-9E003, Loss of Coolant Accident (Reference 7), which specifies actions to mitigate the effects of a LOCA and which would be entered following preliminary event diagnosis pursuant to 40EP-9E001. Other EOPs that may be used during Reactor Coolant System (RCS) depressurization events also include provisions for tripping of the RCPs. Licensed control room operators receive periodic training on these procedures and thus tripping the RCPs following a loss of subcooled margin is not an unfamiliar task demand.

Prior to submitting the LAR to the NRC on July 6, 2018 (Reference 1), APS performed pilot testing to assess the adequacy of the test design, performance measures, and data

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel collection methods. Pilot testing utilized five different crews of licensed operators and involved a small break LOCA scenario of sufficient break size to cause a loss of subcooled margin while the RCPs were operating. The pilot testing concluded that, on average, participants would trip the RCPs approximately 30 seconds following loss of subcooled margin, well within the proposed five minute TCA.

Following NRC approval of the LAR, however, APS will perform verification and validation (V&V) of RCP trip timing as a TCA in accordance with the requirements of PVNGS procedure 40DP-9ZZ04, Time Critical Action (TCA) Program (Reference 8). With respect to the Integrated system validation (ISV) guidelines described in Section 11.4.3 of NUREG-0711, Human Factors Engineering Program Review Model (Reference 9), the following information is provided in response to this NRC RAI; Validation Team Validation team personnel will have independence from the personnel responsible for the actual design. V&V of RCP trip timing as a new TCA will not require any changes to the PVNGS control room design nor control room simulator hardware or software. Pursuant to 40DP-9ZZ04 (Reference 8), the PVNGS Nuclear Fuel Management (NFM) organization has design responsibility for specifying the TCA following its owner acceptance review of the Framatome small break LOCA safety analysis. Validation team members. Including the validation team leader and observers who are responsible for timing the actions of participants, are normally members of the Operations Training organization and have no responsibility for design. Participants are licensed operators. Other personnel, such as Site Procedures Standards personnel who have responsibility for procedure maintenance and revision, may also serve on a validation team for the purpose of observing or validating a new TCA.

Test Objectives Pursuant to 40DP-9ZZ04 (Reference 8), V&V test objectives are established to provide evidence that the integrated system adequately supports plant personnel in safely operating the plant. Specifically, test objectives ensure that TCAs are met as specified In the plant licensing bases. In this instance, the plant licensing bases will include RCP trip timing as a TCA upon NRC approval of the APS LAR including the Framatome small break LOCA analysis. Test objectives will demonstrate that the language, level of Information, sequencing, and number of tasks in the applicable EOPs Is compatible with minimum control room staffing levels as well as the qualifications, training, and experience of control room operators. Test objectives will also demonstrate that control room alarms, displays, and operator aids are adequate for successful completion of the TCA. Consequently, V&V will demonstrate that control room personnel can effectively transition between the control boards and procedures In accomplishing their tasks, and that display configuration and navigation are not a distraction or an undue burden.

Validation Testbeds As stated in Section 11.4.3 of NUREG-0711 (Reference 9), a validation testbed Is the Human System Interface (HSI) representation used to perform validation evaluations.

Pursuant to 40DP-9ZZ04 (Reference 8), the validation testbed for V&V of the RCP trip timing TCA will be the PVNGS control room simulators. These are dynamic simulators that are normally used for training of licensed operators and licensed operator candidates. The PVNGS control room simulators represent the actual control rooms with

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel high physical fidelity including the presentation of alarms, displays, controls, operator aids, and procedures. The information, controls, and response of the testbed during V&V is expected to accurately match that which would be presented during an actual small break LOCA.

Plant Personnel As noted In the "Validation Team" section herein, participants In V&V will be licensed control room operators. Pursuant to 40DP-9ZZ04 (Reference 8), validation of the new RCP trip timing TCA will be performed by at least 3 different crews in order to provide reasonable assurance that the TCA can be completed within the required time. Crews that participate in V&V will be selected without bias (for example, crews Identified as being more experienced).

Performance Measurement With regard to performance measurement, the primary task measure that control room operators will be required to perform involves tripping the RCPs following a loss of subcooled margin (NPSH) during a small break LOCA scenario. Pursuant to 40DP-9ZZ04 (Reference 8), "time zero" will be established when 24°F subcooling Is displayed on the Qualified Safety Parameter Display System (QSPDS) after reactor trip, and the time for completion will be when all RCPs are tripped by the participant. It is noted that PVNGS control room operators and candidates are normally trained to use QSPDS, which directly displays RCS subcooling based on RCS temperature and pressure.

Test Design Pursuant to 40DP-9ZZ04 (Reference 8), V&V of the new RCP trip timing TCA using the PVNGS control room simulators will include a detailed briefing by the validation team leader regarding validation team member responsibilities. Initial conditions for the scenario under evaluation, and expected performance of the task; performance of the validation with observers and evaluators positioned so as not to Interfere with or distract participants or inhibit traffic paths; and completion of a documented validation package.

Should difficulties occur such that the time requirement for the TCA is exceeded, the team leader may decide to continue the scenario to aid in determining whether any changes would serve to accomplish the TCA within the required time. As stated previously, prior to submitting the LAR to the NRC on July 6, 2018 (Reference 1), APS performed pilot testing to assess the adequacy of the test design, performance measures, and data collection methods. Pilot testing utilized five different crews of licensed operators and involved a small break LOCA scenario of sufficient break size to cause a loss of subcooled margin while the RCPs were operating. The pilot testing concluded that, on average, participants would trip the RCPs approximately 30 seconds following loss of subcooled margin, well within the proposed five minute TCA.

Data Analysis and Human EnQlneerino Discrepancies fHEDJ Identification As noted in the "Test Design" section herein, pilot testing performed prior to submitting the LAR to the NRC on July 6, 2018 (Reference 1), concluded that, on average, participants would trip the RCPs approximately 30 seconds following loss of subcooled margin, well within the proposed five minute TCA. Furthermore, no HEDs were identified during pilot testing. This provides some assurance that sufficient margin exists to allow for more variation In actual performance than In validation test

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel performance. Regardless, 40DP-9ZZ04 (Reference 8) provides criteria for data analysis and HED identification. Specifically, validation of a TCA is considered adequate If the TCA Is completed in a shorter duration than 80% of the TCA required time. If the TCA is completed within 80% to 100% of the required time, then additional validation of the TCA will be performed with other participants, and/or an engineering review will be performed to determine methods of reducing the actual performance time. Likewise, any identified HEDs may be addressed by remediation, retesting, performance of additional validations using other participants, and/or evaluating for degrading trends in TCA completion time, depending on the nature of the HED.

Validation Conclusions The V8iV of the new RCP trip timing TCA, as part of the implementation of the approved license amendment, will demonstrate that the performance of the Integrated system is, and will be, acceptable. Given that tripping the RCPs following a loss of subcooling is a long-standing requirement in the PVNGS EOPs, that licensed operators and candidates have trained in the control room simulators on these procedures, and that pilot testing concluded that TCA performance would be well within the proposed five minute duration, when the procedurally required V&V is performed it will demonstrate acceptable performance. Therefore, implementation of the approved license amendment will provide reasonable assurance that the HAs can be accomplished within the newly established time limits.

lRAB-RAI-2 NUREG-0711, Review Element 3, "Operating Experience Review," provides guidance for the NRC staff's evaluation of the operating experience review (OER) that would be performed by an applicant or licensee, as part of the HFE program, to identify HFE-related safety issues.

Section 3.4, "Review Criteria," states. In part, that the applicant's OER should include Information about relevant human factors Issues In the predecessor plant(s) or highly similar plants, systems, and human-system interfaces (HSIs), recognized industry HFE Issues, related HSI technology, issues identified by plant personnel, and important HAs.

Further, Section 3.4.3, "Plant Modifications," states that, in addition to other considerations, the applicant's OER should provide information on the plant's systems, HSIs, procedures, or training that are being modified, and account for the operating experience of the plant that will be modified, including experiences with the systems that will be changed.

Please provide additional Information regarding the OER that was performed by APS, as it relates to the proposed change establishing a new time requirement to stop all RCPs within five minutes following loss of subcooling margin. In your response, please describe whether the review Identified any human performance issues associated with the procedural guidance, training, and any human performance issues associated with the subject operator action, by reviewing operating experience at APS and applicable Industry experience, as appropriate.

APS ResDonse to IRAB-RAI-2 As Stated in the APS LAR dated July 6, 2018 (Reference 1), a delayed RCP trip study was performed for PVNGS commensurate with the NRC Safety Evaluation associated with Framatome topical report EMF-2328(P)(A), Revision 0, Supplement 1(P)(A), Revision 0, PWR Small Break LOCA Evaluation Model, S-RELAP5 Based (Reference 4). The NRC's approved methodology requirement to address a delayed RCP trip, and the associated TCA

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel requirement to trip the RCPs after a loss of subcooled margin, have also been implemented at the following Combustion Engineering designed plants:

Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, established a TCA to trip the RCPs within four minutes (Reference 10).

Millstone Power Station, Unit No. 2, established a TCA to trip the RCPs within two minutes (Reference 11).

St. Lucie Plant, Unit No. 2, reaffirmed TCAs to trip the RCPs within two minutes (using 10 CFR 50 Appendix K methods) and 10 minutes (using "better estimate*

Inputs) (Reference 12). These TCAs were previously established as part of an Extended Power Uprate (EPU) LAR, as supplemented by a response to an NRC RAI (References 13 and 14).

San Onofre Nuclear Generating Station, Unit Nos. 2 and 3, proposed a TCA to trip the RCPs wuthin seven minutes (Reference 15). Commercial operation ceased before the NRC Issued a Safety Evaluation that addressed the proposed TCA.

Additionally, as noted In the "APS Response to IRAB-RAI-1" section herein, pilot testing at PVNGS concluded that, on average, control room operators would trip the RCPs approximately 30 seconds following loss of subcooled margin, well within the proposed five minute TCA.

The APS review of internal and external operating experience did not identify any human performance issues associated with the proposed operator action nor associated procedure guidance or training. Additionally, there are no system changes or plant modifications required.

IRAB-RAI-3 NUREG-0711, Review Element 10, "Training Program Development," provides guidance for the NRC staff's evaluation of the licensee's training program. NUREG-1764, Section 3.9, "Training Program Design," states, in part, "The objective of this review is to verify that the licensee's training program results in adequate training for the HAs. The review should verify that appropriate training has been developed and conducted for the HAs."

Section 7.2 of Attachment 10 to the letter dated July 6, 2018, states. In part, "The commitment to enter the new time requirement into the time critical action program ensures that any needed changes to the operator training program due to the new time requirement are addressed."

Please provide additional information about the process of updating the operator training program, to clarify specifically how the commitment to enter the new time requirement Into the time critical action program results In the necessary changes to the operator training program being Implemented.

APS Response to IRAB-RAI-3 The PVNGS process to revise the TCA program procedure to add a new TCA, 40DP-9ZZ04 (Reference 8), requires that impact reviews be issued to potentially affected workgroups.

One of these impact reviews will be assigned to the PVNGS Operations Training

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel organization. Consequentiy, Operations Training personnel will prepare a needs analysis in accordance with procedure 15DP-0TR08, Systematic Approach to Training (Reference 16).

The needs analysis will establish what training is needed, and Identify whether any changes to affected training programs are required due to the addition of the new TCA to trip the RCPs following a loss of subcooled margin. APS does not anticipate that this evaluation will result in a new task or knowledge requirement, as the direction to trip RCPs following a loss of subcooled margin already exists In the PVNGS standard post-trip actions procedure (Reference 6), as well as other EOPs including the LOCA procedure (Reference 7).

Furthermore, procedure 40DP-9ZZ04 (Reference 8) requires thatTCAs be revalidated at least every five years. This ensures that plant operators will retain the knowledge and abilities to respond to TCAs within their time requirements. Periodic revalidation may also reveal whether subsequent changes in plant design or procedures have caused a change In plant operator performance, which may necessitate further modifications to operator training.

References

1.

APS Letter 102-07727, M. L. Lacal (APS) to Document Control Desk (NRC), Palo Verde Nuclear Generating Station; Units 1, 2, and 3; Docket Nos. STN 50-528,59-529, and 50-530; License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel, dated July 6, 2018 [NRC ADAMS Accession Number ML18187A417 (non-proprietary)]

2.

APS Letter 102-07807, M. L. Lacal (APS) to Document Control Desk (NRC), Palo Verde Nuclear Generating Station; Units 1, 2, and 3; Docket Nos. STN 50-528,59-529, and 50-530; Supplemental Information Regarding License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel, dated October 18, 2018 [NRC ADAMS Accession Number ML18296A466 (non-proprietary)]

3.

L. Ward (NRC) and B. Parks (NRC), Principal Contributors, Final Safety Evaluation by the Office of Nuclear Reactor Regulation; Topical Report EMF-2328(P)(A),

Revision 0, Supplement 1, Revision 0, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based"; Project No. 728, dated February 1, 2017 [NRC ADAMS Accession Number ML16356A406 (non-proprietary)]

4.

K. Hsueh (NRC) to G. Peters (AREVA Inc.), Revised Final Safety Evaluation by the Office of Nuclear Reactor Regulation for Topical Report EMF-2328(P)(A), Revision 0, Supplement 1 (NP)(A), Revision 0, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based" CAC No. MF7268, dated March 17, 2017 [NRC ADAMS Accession Number ML17082A173 (non-proprietary)]

5.

S. Ungam (NRC) to M. Cox (APS), Palo Verde 1, 2, and 3 - Official RAIs from IRAB for Framatome HTP Fuel LAR and Exemption (EPIDs L-2018-LLA-0194 and L-2018-LLE-0010), dated April 5, 2019 (NRC ADAMS Accession Number ML19098A187)

6.

Procedure 40EP-9E001, Standard Post Trip Actions, Revision 23, effective November 20, 2018

Enclosure Response to NRC Staff Requests for Additional Information Regarding License Amendment and Exemption Request to Implement Framatome High Thermal Performance Fuel

7. Procedure 40EP-9E003, Loss of Coolant Accident, Revision 44, effective October 24, 2018

8.

Procedure 40DP-9ZZ04, Time Critical Action (TCA) Program, Revision 13, effective February 16, 2017

9.

NUREG-0711, Human Factors Engineering Program Review Model, Revision 3, published November 2012 (NRC ADAMS Accession Number ML12324A013)

10. NRC Letter, D. V. Pickett (NRC) to G. H. Gellrich (Calvert Cliffs Nuclear Power Plant, LLC), Calvert Cliffs Nuclear Power Plant; Unit Nos. 1 and 2 - Amendment re:

Transition from Westinghouse Nuclear Fuel to AREVA Nuclear Fuel (TAC Nos.

ME2831 and ME2832), dated February 18, 2011 (NRC ADAMS Accession Number ML110390224)

11. NRC Letter, R. V. Guzman (NRC) to D. A. Heacock (Dominion Nuclear), Millstone Power Station, Unit No. 2 - Issuance of Amendment re: Small Break Loss of Coolant Accident Reanalysis (CAC No. MF6700), dated September 30, 2016 (NRC ADAMS Accession Number ML16249A001)

12. NRC Letter, P. H. Buckberg (NRC) to M. Nazar (NextEra Energy), St. Lucie Plant, Unit No. 2 - Issuance of Amendment Regarding Transitioning to AREVA Fuel (CAC No. MF5495), dated April 19, 2016 (NRC ADAMS Accession Number ML16063A121)

13. Florida Power & Light Company Letter L-2011-021, R. L. Anderson (FP&L) to Document Control Desk (NRC), St. Lucie Plant Unit 2; Docket No. 50-389; Renewed Facility Operating License No. NPF-16; License Amendment Request for Extended Power Uprate, dated February 25, 2011 (NRC ADAMS Accession Number ML110730116)

14. Florida Power & Light Company Letter L-2012-009, R. L. Anderson (FP&L) to Document Controi Desk (NRC), St. Lucie Plant Unit 2; Docket No. 50-389; Renewed Facility Operating License No. NPF-16; Response to NRC Reactor System Branch and Nuclear Performance Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request, dated January 21, 2012 (NRC ADAMS Accession Number ML12025A196)

15. Southern Caiifornia Edison Letter, D. R. Bauder (Southern California Edison) to Document Control Desk (NRC), San Onofre Nuclear Generating Station, Units 2 and 3; Docket Nos. 50-361 and 50-362; Proposed Permanent Exemption Request and Proposed Change Number (PCN) 600, Amendment Application Numbers 261 and 249, Request for Unrestricted Use of AREVA Fuel, dated July 29, 2011 (NRC ADAMS Accession Number ML11215A090)

16. Procedure 15DP-0TR08, Systematic Approach to Training (SAT), Revision 14, effective May 31, 2018