L-2023-011, Response to Requests for Additional Information (Rais) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk Informed

Response to Requests for Additional Information (Rais) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk Informed

ML23052A112
Person / Time
Site:	Point Beach
Issue date:	02/21/2023
From:	Strand D Point Beach
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2023-011
Download: ML23052A112 (1)

Text

NEXTera ENERGY~

~

BEACH U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses DPR-24 and DPR-27 L-2023-011 10 CFR 50.90 February 21, 2023 Response to Requests for Additional Information (RAls) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b"

References:

1.

NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)

2.

NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -

Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times - RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)

3.

NRC electronic memorandum dated December 20, 2022, Final RAI - Point Beach 1 & 2 - License Amendment Request Regarding TSTF-505 (ADAMS Accession No. ML22354A161)

4.

NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, Response to Requests for Additional Information (RAls) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", January 11, 2023 (ADAMS Accession No. ML23011A280)

5.

NRC electronic memorandum dated January 31, 2022, Final RAI (Volume 2) - Point Beach 1 & 2 -

License Amendment Request Regarding TSTS-505 (EPID No. L-2022-LLA-0074)

In Reference 1, NextEra Energy Point Beach, LLC (NextEra) submitted license amendment request (LAR) 297 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively. The proposed license amendments would modify the Point Beach Technical Specifications (TS) to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extend Completion Times - RITSTF Initiative 4b, (ADAMS Accession No. ML18183A493).

In Reference 2, the NRC notified NextEra of its intent to conduct a regulatory audit to gain understanding, verify information, or identify information requiring docketing to support a licensing or regulatory decision.

In Reference 4, NextEra responded to the NRC's request for additional information provided in Reference

3. In Reference 5, the NRC requested additional information deemed necessary to complete its review.

The enclosure to this letter provides NextEra's response to the request for additional information (RAI) of Reference 5. Attachment 1 to the enclosure provides a revised Table E1-1, List of Revised Required Actions to Corresponding PRA Functions, which aligns with the RAI responses in this letter and in

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 2 of 2 Reference 4. Attachment 2 provides a revised Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity. Attachment 3 provides a revised Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity. The revised Tables E1-3(1) and E1-3(2) are provided in response to information request item #14 of Reference 2 and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Tables E1-1, E1-3(1) and E1-3(2) supersede and replace the corresponding Tables E1-1, E1-3(1) and E1-3(2) of Reference 1.

The supplements included in this RAI response provide additional information that clarifies the application, do not expand the scope of the application as originally noticed, and should not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.

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

Executed on the 2) day of February 2023.

Sincerely,

~L,,- S~

ianne Strand General Manager, Regulatory Affairs cc:

USNRC Regional Administrator, Region Ill Project Manager, USNRC, Point Beach Nuclear Plant Resident Inspector, USNRC, Point Beach Nuclear Plant Public Service Commission of Wisconsin Attachments (3)

1.

Table E1-1, List of Revised Required Actions to Corresponding PRA Functions (revised)

2.

Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity (revised)

3.

Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Response to Request for Additional Information (RAI)

License Amendment Request 297, Revise Technical Specifications to Adopt L-2023-011 Enclosure Page 1 of 13 Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b" Containment and Plant Systems Branch (SCPB) Audit Questions SCPB-RAl-1 (Audit Question 25)

In Enclosure 1 of the LAR, Table E1-1 indicates for TS LCO Action 3.6.2.C that there are two emergency airlocks. Specifically, it lists one equipment hatch, one personnel airlock, and two emergency airlocks.

FSAR, Chapter 5 indicates 2 personnel airlocks (one of which is emergency). FSAR Figures 5.1-4 and 5.1-5 are unreadable in the FSAR available at the NRC.

a)

Provide clear copies of the figures made available in the audit.

b)

Discuss why the LAR differs from the FSAR and confirm and correct.

NextEra Response:

a) A controlled, readable copy of UFSAR Figure 5.1-5, "Containment Structure - Equipment Hatch" was made available for NRC viewing on the NextEra Online Reference Portal. Regarding UFSAR Figure 5.1-4, "Containment Structure - Personnel Lock", NextEra identified that the controlled drawing needed to be redrawn. The discovery was entered into the Point Beach corrective action program (CAP). UFSAR Figure 5.1-4 details the containment personnel lock annulus, bulkhead panels and equalizing valves.

As an alternative, Point Beach controlled drawings D-2 JOB 18006_2 and D-3 JOB 18006_2, which combined provide similar detail of the containment personnel air locks, were made available for NRC viewing on the NextEra Online Reference Portal.

b) Table E1-1 of LAR Enclosure 1 required correction for TS LCO Action 3.6.2, Condition C. As specified in Point Beach FSAR Chapter 5.1.2.6, Penetrations, the Point Beach Unit 1 and 2 containments each include one equipment hatch and two personnel airlocks, one of which is for convenience access. The revised Table E1-1 is included as Attachment 1 to this RAI response.

The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1 to this RAI response.

SCPB-RAl-2 (Audit Question 26)

In Enclosure 1 of the LAR, Section 3, the licensee provides justification for TS LCO 3.6.2, "Containment Air Locks." However, it does not address the following issue: TSTF-505 Revision 2, for WOG LCO 3.6.2.C.2 reads "C.2 Verify a door is closed in the affected air lock." whereas the LAR's proposed Point Beach LCO 3.6.2.C.2 reads "C.2 Verify a bulkhead door and associated equalizing valve are closed in the affected air lock."

Provide additional information to explain: (1) how the equalizing valves function in relation to the bulkhead doors; and (2) why the difference in wording exists between the LCO of TSTF-505, Revision 2, and the LCO proposed in the LAR.

NextEra Response:

The personnel air lock equalizing valves connect the personnel lock with the interior and exterior of the containment vessel. The safety function is to isolate containment from the environment during design basis accident conditions. The equalizing valves are not "valves" in the traditional sense but consist of

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Enclosure Page 2of13 a disc plate that seals against a base plate with a dual 0-ring seal. The disk slides along extension bars by a lever and cam linkage working through a pivot plate attached to the ends of the extension bars.

The lever is connected to the existing linkage arm driven by the door operating mechanism. Test ports are provided in the adapter flange for leak testing the 0-ring seals on one face and the flange gasket on the other.

The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is one of nomenclature since the "bulkhead" is the actual air lock door. However, the term "bulkhead" in Point Beach LCO 3.6.2, ACTION C.2, serves to underscore that the integrity of each airlock pressure boundary relies on the closure of both the bulkhead door and the associated equalizing valve.

Of note is that Bases section 3.6.2 of NUREG 1431, Revision 4 (ADAMS Accession No. ML 121 OOA228), does not discuss air lock equalizing valves as part of the containment air lock pressure boundary and thereby it is not expected that the distinction would be addressed in LCO 3.6.2 of NU REG 1431, Revision 4 (ADAMS Accession No. ML12100A222), upon which LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is based. The plant-specific variation is acceptable since, consistent with LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, Point Beach LCO 3.6.2, ACTION C.2, assures the integrity of at least one air lock pressure boundary when in Condition C, "One or more containment air locks inoperable for reasons other than Conditions A or B".

The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is a plant-specific variation that was inadvertently omitted from and is in addition to the evaluations provided in Attachment 5, Evaluation of Plant-Specific Variations, of Reference 1.

Electrical Engineering Branch (EEEB) Audit Questions In Table E1-1 of Enclosure 1 of the LAR, the licensee lists each TS Required Action Condition proposed for the Point Beach RICT Program and documents information regarding the associated SSCs credited in plant safety analyses, the analogous PRA functions, and the results of the comparison. Questions EEEB-RAl-1 thru EEEBRAl-7 pertain to the information presented in Table E1-1.

EEEB-RAl-1 (Audit Question 27)

For each LCO proposed under TS 3.8, "Electrical Power Systems," clarify if Table E1-1 is written on a per unit basis for "SSC Function(s)" (Column 3), and "PRA Success Criteria" (Column 6), given that sharing of electrical systems is found in UFSAR.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems, required revision to clarify that Column 3, "SSC Function(s)", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" apply on a per unit basis. Specifically, for TS 3.8, Column 3 was revised to identify the SSCs associated with the LCO Condition on a per unit basis. Similarly, for TS 3.8, Columns 5 and 6 were revised to specify the minimum SSCs required to fulfill the safety function on a per unit basis. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

EEEB-RAl-2 (Audit Question 28)

The licensee stated that the "SSC Function(s)" (Column 3) for TS 3.8.1, Conditions A, B, C, D, and Fis "Power onsite safeguards buses from offsite and onsite transmission networks to support normal, safe shutdown and accident mitigation conditions." Clarify why Column 3 is inconsistent with UFSAR by not listing four Class 1 E 4.16 kV electrical buses since there are two of them per unit if this table addresses both Units 1 and 2.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 NextEra Response:

L-2023-011 Enclosure Page 3of13 Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to clarify that Column 3, "SSC Function(s)" applies on a per unit basis. The revision resolves the inconsistency with the UFSAR regarding the number of Class 1 E 4.16 kV electrical buses for one versus both Point Beach nuclear units. The revision to Column 3 for TS 3.8.1, Conditions A, B, C, D, and F are listed below and were incorporated into the revised Table E-1.1, which is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Condition SSC Description Function(s)

TS 3.8.1 Power Condition A Associated unit Class 1E 345/13.8 kV (X03) 4.16 kV safeguards transformer inoperable.

buses from OR offsite Gas turbine not in operation transmission when utilizing opposite unit's networks 345/13.8 kV (X03) transformer Power TS 3.8.1 Class 1E Condition 8 4.16 kV Associated unit's 13.8/4.16 kV safeguards (X04) transformer buses from offsite inoperable transmission networks Power TS 3.8.1 Class 1E Condition C 4.16 kV Associated unit's required safeguards buses from offsite power source to buses off site A05 and A06 inoperable.

transmission OR networks and Required offsite power source on site to buses 1A05 and 2A06 inoperable emergency power sources Power Class 1E TS 3.8.1 4.16 kV Condition D safeguards One or more required buses from offsite offsite power source(s) to one transmission or more required Class 1 E networks and 4.16 kV bus(es) on site inoperable emergency power sources

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 TS 3.8.1 Condition F One or more required offsite power source to one or more Class 1 E 4.16 kV safeguards bus(es) inoperable AND Standby emergency power inoperable to redundant equipment Power Class 1E 4.16 kV safeguards buses from offsite transmission networks and on site emergency power sources EEEB-RAl-3 (Audit Question 29, rev 1) -TS LCO 3.8.1, Conditions A and B L-2023-011 Enclosure Page 4of13 Explain why Columns 2 and 3 are inconsistent with LCO for SSCs specifically covered by the LCO (not addressing high voltage (HV) station auxiliary transformers X03s or low voltage (LV) station auxiliary transformers X04s) in associated unit for respective LCO condition.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions A and B. The revision reflects the availability of the offsite power sources to power 4.16 kV Class 1 E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E 1-1 of Reference 1.

Required Action SSC Condition Applicable SSCs Function(s)

Description TS 3.8.1 Condition A Two circuits between the Power Associated unit offsite transmission network Class 1E 345/13.8 kV (X03) via the 345/13.8 kV (X03) 4.16 kV transformer inoperable.

transformers and the safeguards OR 13.8/4.16 kV (X04) buses from Gas turbine not in operation transformers, and the offsite when utilizing opposite unit's associated unit's 4.16 kV transmission 345/13.8 kV (X03)

Class 1 E safeguards buses) networks transformer.

Two circuits between the Power TS 3.8.1 offsite transmission network Class 1E Condition B via the 345/13.8 kV (X03) 4.16 kV Associated unit's 13.8/4.16 transformers and the safeguards kV (X04) transformer 13.8/4.16 kV (X04) buses from transformers, and the offsite inoperable associated unit's 4.16 kV transmission Class 1 E safeguards buses networks EEEB-RAl-4 (Audit Question 30, rev 1) -TS LCO 3.8.1, Conditions A and B Explain why Column 6 is inconsistent with LCO by not listing minimum SSCs of those listed in Column 3 (e.g., either opposite unit's HV (X03) or LV station auxiliary transformer (X04), respectively, for Condition A or B) to achieve safe shut down for a design basis accident (OBA) in opposite unit.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 NextEra Response:

L-2023-011 Enclosure Page 5of13 Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions A and B. The revised success criteria require one circuit between the offsite transmission network and an affected unit's safeguard bus via automatic alignment with the opposite unit's X03 transformer for the condition of an inoperable X03 transformer and manual alignment with the opposite unit's X04 transformer for the condition of an inoperable X04 transformer.

Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Condition Design Success PRASuccess Description Criteria Criteria TS 3.8.1 One circuit Condition A between the offsite Associated unit transmission network 345/13.8 kV (X03) via a 345/13.8 kV transformer inoperable.

(X03) transformer Same OR and a 13.8/4.16kV Gas turbine not in operation (X04) transformer, when utilizing opposite unit's and an associated 345/13.8 kV (X03) unit's 4.16 kV Class transformer.

1 E safeguards bus One circuit between the offsite TS 3.8.1 transmission network Condition B via a 345/13.8 kV Associated unit's 13.8/4.16 (X03) transformer Same kV (X04) transformer and a 13.8/4.16kV (X04) transformer, inoperable and an associated unit's 4.16 kV Class 1 E safeguards bus EEEB-RAl-5 (Audit Question 31, rev 1)-TS LCO 3.8.1, Conditions C and D Explain why Columns 2 and 3 are inconsistent with respective LCO in that (a) HV station auxiliary transformers X03s supplying buses A05 and A06 are not shown for TS LCO 3.8.1, Condition C and (b) also for LCO 3.8.1, Condition D including EDGs based on TS Bases (page 473).

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions C and D.

The revision reflects the availability of the offsite power sources, including from the opposite unit, and the onsite emergency power sources to power 4.16 kV Class 1 E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Required Action Condition Applicable SSCs Description TS 3.8.1 Two circuits between the offsite Condition C transmission network via the Associated unit's 345/13.8 kV (X03) transformers required offsite power and the 13.8/4.16kV (X04) source to buses A05 transformers, and the associated and A06 inoperable.

unit's 4.16 kV Class 1 E safeguards buses OR AND Required offsite Two onsite emergency power power source to buses 1 A05 and sources capable of supplying the associated unit's 4.16 kV Class 1 E 2A06 inoperable safeguards buses)

Two circuits between the offsite transmission network via the TS 3.8.1 345/13.8 kV (X03) transformers Condition D and the 13.8/4.16kV (X04)

One or more required transformers, and the associated offsite power unit's 4.16 kV Class 1 E safeguards source(s) to one or buses more required Class AND 1 E 4.16 kV bus( es)

Two onsite emergency power inoperable sources capable of supplying the associated unit's 4.16 kV Class 1 E safeguards buses SSC Function(s)

Power Class 1E 4.16 kV safeguards buses from offsite transmission networks and on site emergency power sources Power Class 1E 4.16 kV safeguards buses from offsite transmission networks and on site emergency power sources EEEB-RAl-6 (Audit Question 32, rev 1) - TS LCO 3.8.1, Conditions C and D L-2023-011 Enclosure Page 6of13 Explain why Column 6 is inconsistent by not listing minimum required SSCs for respective LCO (a) like one unit's HV station auxiliary transformer (X03) supplying a singular bus A05 or A06 for TS LCO 3.8.1, Condition C and one unit's HV station auxiliary transformer (X03), or one EDG supplying that unit's bus A05 or A06 for TS LCO 3.8.1, Condition D.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions C and D. For the condition of the associated unit's offsite power source circuit inoperable, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1 E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power source circuit. For the condition of both offsite power source circuits unavailable, the revised success criteria require an onsite emergency power source capable of supplying an associated unit's Class 1E4.16 kV safeguards bus, A05 or A06.

Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Required Action Design Success Condition Description Criteria One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1 (X03) transformer Condition C and a 13.8/4.16kV Associated unit's required (X04) transformer, offsite power source to and an associated buses A05 and A06 unit's 4.16 kV Class inoperable.

1 E safeguards bus OR OR Required offsite power One onsite source to buses 1 A05 and emergency power 2A06 inoperable source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit between the offsite transmission network via a 345/13.8 kV (X03) transformer TS 3.8.1 and a 13.8/4.16kV Condition D (X04) transformer, One or more required and an associated unit's 4.16 kV Class offsite power source(s) to 1 E safeguards bus one or more required OR Class 1 E 4.16 kV bus( es)

One onsite inoperable emergency power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus PRA Success Criteria Same Same EEEB-RAl-7 (Audit Question 33, rev 1) -TS LCO 3.8.1, Condition F L-2023-011 Enclosure Page 7of13 Explain why Column 6 is inconsistent with LCO by not listing minimum required SSCs one unit's HV station auxiliary transformer OR one EOG as supplying that unit's bus A05 or A06 as minimum SSCs for TS LCO 3.8.1, Condition F.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Condition F. For the condition of an inoperable offsite power source in conjunction with an inoperable onsite emergency power source, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1 E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power circuit. For the condition of both offsite power source circuits unavailable to the associated unit in conjunction with an inoperable onsite emergency power source, the revised success criteria require one onsite emergency power

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Enclosure Page 8of13 source capable of supplying an associated unit's Class 1 E 4.16 kV safeguards bus (A05 or A06), which can be satisfied by aligning the opposite unit's onsite emergency power source associated with the affected safeguards bus. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Condition F. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Design Success PRA Success Condition Description Criteria Criteria One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1 (X03) transformer Condition F and a 13.8/4.16kV One or more required (X04) transformer, offsite power source to and an associated one or more Class 1 E unit's 4.16 kV Class Same 4.16 kV safeguards 1 E safeguards bus bus(es) inoperable OR AND Standby emergency One onsite power inoperable to emergency power redundant equipment source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-8 (Audit Question 34, rev 1) -TS LCO 3.8.4, Condition A Explain why Column 6 does not list minimum required SSCs in agreement with LCO in terms of subsystems (See TS Bases on page 504, 3rd full paragraph, 1st sentence about term "subsystem" and usage at Point Beach) and indicate if swing battery and battery chargers should be captured here.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.4, Condition A. The DC electrical power system consists of four main distribution buses configured as two redundant electrical 125 VDC trains, with each distribution bus powered by a battery charger and backed up by a station battery.

Thereby, the applicable SSCs for TS 3.8.4, Condition A, are four 125 VDC electrical subsystems each consisting of a battery charger backed by a station battery powering the associated DC distribution bus.

The revised success criteria require two 125 VDC electrical subsystems of the same electrical train, each consisting of a battery charger backed by a station battery powering the associated DC distribution bus. Just as the normally aligned batteries and battery chargers, the swing battery and charger are sized to provide 100% of required DC power, and thereby, the swing battery and charger need not be explicitly captured in the success criteria. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.4, Condition A The revised Table E1-1 is included as to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Required Action Condition Applicable SSCs Description Four 125 voe electrical subsystems TS 3.8.4 each consisting of a Condition A battery charger One DC electrical power backed by a station subsystem inoperable battery powering the associated DC distribution bus Design Success Criteria Two 125 voe electrical subsystems of the same electrical train, each consisting of a battery charger backed by a station battery powering the associated DC distribution bus EEEB-RAl-9 (Audit Question 35, rev 1) -TS LCO 3.8.7, Condition A PRASuccess Criteria Same L-2023-011 Enclosure Page 9of13 Explain why Column 6 does not list minimum number of inverters per channel per unit required for DBA and UFSAR Section 8.6.2 and TS Bases (page 520, 2nd paragraph, last 5 sentences).

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.7, Condition A. The 120 VAC instrument system consists of four 120 VAC instrument channels (red, white, blue, and yellow) configured as two redundant 120 VAC electrical trains. Each are allocated four buses of which two are dedicated to Unit 1 and two dedicated to Unit 2. Each of the four channels are equipped with three inverters of which one is dedicated to Unit 1, one dedicated to Unit 2, and a third, swing inverter which can be aligned to replace either Unit 1 or Unit 2 inverters with full capability. Thereby, the applicable SSCs for TS 3.8.7, Condition A, are four 120 VAC instrument channels each equipped with a 120 VAC instrument inverter powering its two 120 VAC electrical buses. Since the four 120 VAC instrument channels are configured as two redundant 120 VAC electrical trains, the revised design and PRA success criteria for TS 3.8. 7, Condition A, are two 120 VAC instrument channels of the same electrical train, each equipped with a 120 VAC instrument inverter powering two 120 VAC electrical buses.

Specifically, the changes below were incorporated into Columns 2, 5 and 6 of Table E-1.1 for TS 3.8.7, Condition A. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Design Success PRASuccess Condition Applicable SSCs Description Criteria Criteria Four 120 VAC Two 120 VAC instrument channels instrument channels TS 3.8.7 of the same electrical Condition A each equipped with a train, each equipped 120 VAC instrument Same One required inverter inverter powering two with a 120 VAC inoperable 120 VAC electrical instrument inverter buses powering two 120 VAC electrical buses Instrumentation & Controls Branch (EICB) Audit Questions EICB-RAl-1 (Audit Question 36)

In Enclosure 1 of the LAR, Table E1-3(1 ), indicates the following:

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 RPS Function RCP breaker position - one loop RCP breaker position - 2 loops Underfrequency Bus A01, A02 Functional Unit FU10a FU10b FU12 Channels to Trip 1 out of 1 per loop 1 out of 1 per bus L-2023-011 Enclosure Page 10of13 a) Explain why it is not a loss of function to support the application of risk-informed completion time.

b)

Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the coincidence logic presented in the LAR.

NextEra Response:

In response to information request item #14 of the NRC's audit plan (Reference 2), Table E1-3(1),

Information to Support RPS Instrumentation Redundancy and Diversity, and Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity, were revised to identify for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip or ESFAS actuation function(s) credited in plant safety analyses. Table E1-3(1) was also revised to correct the coincidence logic for FU10a, FU10b and FU12, as described below. The revised Table E1-3(1) and Table E1-3(2) are included as Attachments 2 and 3 to this RAI response, respectively, and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Table E1-3(1) and Table E1-3(2) supersede and replace the corresponding Table E1-3(1) and Table E1-3(2) of Reference 1.

a)

For Functional Units (FU) 10a, FU10b and FU12, Table E1-3(1) required correction for the coincidence trip logic column "Channels to Trip". The correct coincidence logic for these RPS functions is listed below and was incorporated into Table E1-3(1). The revised Table E1-3(1) is provided as Attachment 2 of this RAI response. The revised Table E1-3(1) supersedes and replaces the corresponding Table E1-3(1) of Reference 1.

RPS Function Functional Unit Channels to Trip RCP breaker position - one loop FU10a 1-out-of-2 per loop 1-out-of-2 per loop RCP breaker position - 2 loops FU10b taken twice Underfrequency Bus A01, A02 FU12 1 out of 2 per bus taken twice For FU10a, "RCP Breaker Position - One Loop, when above the P-8 permissive (-35% RTP), a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on either RCP. Should an FU10a channel become inoperable, the redundant FU10a channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU1 Oa channel on either or both RCP loops is not a loss of function.

For FU10b, "RCP Breaker Position - 2 Loops", when above the P-7 permissive (-10% RTP) but below P-8 permissive, a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on both RCP loops. Should an FU10b channel become inoperable, it's redundant FU 1 Ob channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU10b channel on either or both RCP loops is not a loss of function.

During an audit meeting held on November 22, 2022, the NRC staff asked whether the RCP breakers are equipped with redundant relays (i.e., channels) to the RPS system, as inferred above by the '1 out of 2 per loop' trip logic associated with RPS trip functions FU1 Oa (RCP breaker position

- one loop) and FU10b (RCP breaker position - 2 loops). The table below is derived from Point

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Enclosure Page 11of13 Beach Units 1 and 2 instrumentation & control (l&C) procedures ICP 02.029, Reactor Protection System Logic - RCP Breaker Position (RCP Loss of Power) - TADOT, which verify each train A and train B relay energize with the associated RCP breaker closed and de-energize with the RCP breaker racked-in and open. As can be seen, each RCP breaker is equipped with two, redundant matrix relays, and as such, loss of one relay does not create a loss of function. For an inoperable RCP-A-XA or RCP-A-XB relay on the 'A" RCP-breaker (or an inoperable RCP-B-XA or RCP-B-XB relay on the 'B' RCP breaker) TS 3.3.1, ACTION M would be entered for the loss of a single FU1 Oa channel when above the P-8 permissive, or ACTION N would be entered for the loss of a single FU10b channel when above P-7 but below P-8. The above discussion similarly applies to the Unit 2 'A' and 'B' RCPs. Of note is that neither ACTION M nor N address the condition of both relays associated with a single RCP breaker being inoperable, which would require LCO 3.0.3 entry for this loss of function condition. l&C procedures ICP 02.029 for Point Beach Units 1 and 2 were made available for NRC viewing on the NextEra Online Reference Portal.

RCP Train Pump Breaker Contacts Matrix Relay No.

1P-1A A

1A52-04 3-4 RCP-A-XA B

7-8 RCP-A-XB 1P-1 B A

1A52-14 3-4 RCP-B-XA B

7-8 RCP-B-XB 2P-1A A

2A52-24 3-4 RCP-A-XA B

7-8 RCP-A-XB 2P-1B A

2A52-29 3-4 RCP-B-XA B

7-8 RCP-B-XB For FU12, "Underfrequency Bus A01, A02", when above the P-7 permissive, both RCP breakers are tripped (open) upon one of the two underfrequency relays sensing an underfrequency condition on both 4160 V buses A01 and A02. Should an FU12 channel become inoperable, its redundant FU12 channel is available to fulfill the coincidence trip logic for the affected A01 or A02 bus.

Thereby, the loss of one FU12 channel on either or both A01 and A02 buses is not a loss of function.

b) The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:

883D195, Sheet 4, Rev. 23, 4160 V Bus Scheme Logic 883D195, Sheet 15, Rev. 10, RC Trip Signal Logic 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach design basis document (DBD) 27, Reactor Protection System, was made available for NRC viewing on the NextEra Online Reference Portal.

EICB-RAl-2 (Audit Question 37)

In Attachment 2a of the LAR, the licensee proposes that the COMPLETION TIME for TS 3.3.1, "Reactor Protection System (RPS) Instrumentation," CONDITION U change to "48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program." CONDITION U applies to Functional Unit (FU) 19, "Reactor Trip Breaker Undervoltage and Shunt." In Enclosure 1 of the LAR, Table E1-3(1) does not include information for FU19.

a) Why is FU19 not included in the Table E1-3(1)?

b) What is the coincidence logic for FU19?

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Enclosure Page 12 of 13 c)

If the coincidence logic is X-out-of-X (such as 1-out-of-1 or 2-out-of-2), why it is not a loss of function to support the application of risk-informed completion time?

d)

Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the trip logic for FU19.

NextEra Response:

a) Table E1-3(1) of LAR Enclosure 1 identifies for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip function(s) credited in plant safety analyses.

Table E1-3(1) specifies as one of the diverse means of achieving the primary RPS trip function, the ability to manually trip the reactor. Both the primary and diverse RPS trip functions specified in Table E1-3(1) rely on two operable logic trains of Reactor Trip Breakers (RTBs) each capable of de-energizing the associated RTB (or bypass) undervoltage coil upon receipt of an RPS signal and energizing open the associated RTB via a shunt trip device upon receipt of a manual trip signal.

Operability of both trip mechanisms on each RTB logic train ensures that no single trip mechanism failure will prevent opening any breaker on a valid RPS signal. Thereby, FU19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms, need not be explicitly listed in Table E1-3(1) since an operable FU19 is necessary to achieve both the primary and diverse means of achieving the specified RPS trip functions.

b) The coincidence logic for FU19 is 1-out-of-2, meaning only one of the two FU19 channels are needed to achieve the reactor trip upon receipt of a valid RPS signal.

c) With one FU19 channel inoperable, the redundant FU19 channel is capable of providing the reactor trip upon receipt of a valid RPS signal. Thereby, the loss of one FU19 channel does not result in a loss of function.

d) The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:

883D195, Sheet 2, Rev. 9, Reactor Trip Signal Logic 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach DBD 27, Reactor Protection System, was uploaded to the NextEra Online Reference Portal for NRC viewing in response to item #14 of the NRC's audit document request (Reference 2).

During the audit meeting held on November 22, 2022, the NRC staff asked for the plant conditions warranting entry into FU18 versus FU19 entry. FU18 addresses the operability of the RTBs exclusive of individual trip mechanisms. Two RTBs are required to ensure no single random failure can disable the RPS trip capability. FU19 addresses the operability of the RTB undervoltage and shunt trip device mechanisms. Should an RTB become inoperable independent of the corresponding trip mechanisms, TS 3.3.1, Table 3.3-1, Condition Q would be entered for an inoperable FU18-required RTB. Should either the RTB undervoltage or shunt trip device mechanism become inoperable, TS 3.3.1, Table 3.3-1, Condition U, would be entered for an inoperable FU 19-required trip mechanism. However, it would not be necessary to also enter Condition U for an inoperable FU18-required RTB since the affected RTB remains capable of tripping the unit upon receipt of a valid RPS signal. Noteworthy in both scenarios is that the redundant RTB remains available and capable of performing its function upon a valid RPS signal, and thereby entry into FU 18, FU 19 or both does not constitute a loss of function.

References:

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Enclosure Page13of13

1.

NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)

2.

NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -

Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times-RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 1 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Comments Description TS 3.3.1, RPS Instrumentation (Table 3.3-1)

Condition B The operator actions for failure to One Manual (FU1)

Reactor Trip 1of2 Not Modeled actuate a manual reactor trip will be Reactor Trip Two Manual Rx Trip channels Initiation No Manual Rx Trip

-See used as a surrogate to conservatively channel inoperable channels comments bound the risk increase associated with (Modes 1,2) this function as permitted by NEI 06-09.

(FU2a)

Reactor Trip 2 of4 Not Modeled The condition of one of two inoperable Four Power Range Neutron Initiation No Power Range Neutron

-See reactor trip breakers is used as a Flux High channels Flux-High channels comments surrogate for this condition.

(FU2b)

Reactor Trip 2 of4 Not Modeled The condition of one of two inoperable Four Power Range Neutron No Power Range Neutron

-See reactor trip breakers is used as a Flux Low channels Initiation Flux-Low channels comments surrogate for this condition.

(FU5)

Reactor Trip 2 of4 Not Modeled The condition of one of two inoperable Four Overtemperature Lff Initiation No Overtemperature t:,. T

-See reactor trip breakers is used as a channels channels comments surrogate for this condition.

(FU6)

Reactor Trip 2 of 4 Not Modeled The condition of one of two inoperable Condition D No Overpower t:,. T

-See reactor trip breakers is used as a One channel Four Overpower!::,. T channels Initiation channels comments surrogate for this condition.

inoperable (FU?b)

Reactor Trip 2 of3 Not Modeled The condition of one of two inoperable Three Pressurizer Pressure -

No Pressurizer Pressure -

-See reactor trip breakers is used as a High channels Initiation High channels comments surrogate for this condition.

(FU13) 2 of 3 Not Modeled The condition of one of two inoperable Reactor Trip SG Water Level Low-Three SG Water Level Low-Low Initiation No Low channels on any

-See reactor trip breakers is used as a channels per SG SG comments surrogate for this condition.

(FU14)

One SG Water Level Two SG Water Level Low; Reactor Trip Low coincident w/ one Not Modeled The condition of one of two inoperable Coincident w/ Steam-Flow/

No Steam-Flow/ Feed-

-See reactor trip breakers is used as a Feed-Flow Mismatch channels Initiation Flow Mismatch comments surrogate for this condition.

perSG channel on any SG

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 2 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Comments Description Condition E (FU12) 1 of 2 Not Modeled The condition of one of two inoperable Reactor Trip Underfrequency Bus One channel Two Underfrequency Bus A01, Initiation No channels on both

-See reactor trip breakers is used as a inoperable A02 channels per bus A01 and A02 comments surrogate for this condition.

(FU7a)

Reactor Trip 2 of4 Not Modeled The condition of one of two inoperable Four Pressurizer Pressure -

Initiation No Pressurizer Pressure -

-See reactor trip breakers is used as a Low channels Low channels comments surroQate for this condition.

(FU8)

Reactor Trip 2 of 3 Not Modeled The condition of one of two inoperable Three Pressurizer Water Level -

No Pressurizer Water

-See reactor trip breakers is used as a High channels Initiation Level - High channels comments surrogate for this condition.

Condition K 2 of 3 One channel (FU9b) inoperable Three Reactor Coolant Flow -

Reactor Trip Reactor Coolant Flow -

Not Modeled The condition of one of two inoperable Low (Two loops) channels per Initiation No Low channels on both

-See reactor trip breakers is used as a RCS Loops when comments surrogate for this condition.

RCS Loop above P8 (FU11) 1of2 Not Modeled The condition of one of two inoperable Reactor Trip Undervoltage Bus Two Undervoltage Bus A01, Initiation No channels on

-See reactor trip breakers is used as a A02 channels per electrical bus A01 and A02 comments surrogate for this condition.

Condition L (FU9a) 2 of3 One Reactor Reactor Coolant Flow -

Not Modeled The condition of one of two inoperable Coolant Flow-Low Three Reactor Coolant Flow -

Reactor Trip No Low channels on any

-See reactor trip breakers is used as a (Single Loop)

Low (Single Loop) channels per Initiation RCS Loop when below comments surrogate for this condition.

channel inoperable RCS Loop P8 Condition M One Reactor (FU10a)

One RCP Breaker Not Modeled The condition of one of two inoperable Coolant Pump One RCP Breaker Position Reactor Trip No Position channel on

-See reactor trip breakers is used as a Breaker Position (Single Loop) channel per RCP Initiation any RCP when below comments surrogate for this condition.

(Single Loop)

P8 channel inoperable Condition N (FU10b)

One RCP breaker Not Modeled The condition of one of two inoperable Reactor Trip Position channel on One inoperable One RCP breaker position (two Initiation No both RCPs when

-See reactor trip breakers is used as a channel loops) channel per RCP above P8 comments surrogate for this condition.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 3of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC Condition Applicable SSCs PRA Design Success PRASuccess Description Function(s)

Modeled Criteria

• criteria Comments (FU15a) 2 of2 Not Modeled Three Turbine trip - Low Auto-Reactor Trip No Turbine trip - Low

-See The condition of one of two inoperable Condition 0 Stop Oil Pressure channels Initiation Auto-Stop Oil Pressure reactor trip breakers is used as a One turbine trip channels comments surrogate for this condition.

channel inoperable (FU15b) 2 of 3 Not Modeled Two Turbine trip - Stop Valve Reactor Trip No Turbine trip - Stop

-See The condition of one of two inoperable Closure channels Initiation Valve Closure reactor trip breakers is used as a channels comments surrogate for this condition.

(FU16)

Reactor Trip 1of2 Not Modeled The condition of one of two inoperable Condition P Two SI input from ESFAS trains Initiation No SI input from ESFAS

-See reactor trip breakers is used as a One train trains comments surrogate for this condition.

inoperable (Modes 1,2)

(FU21)

Reactor Trip 1of2 Not Modeled The condition of one of two inoperable Two Automatic Trip Logic trains Initiation No Automatic Trip Logic

-See reactor trip breakers is used as a trains comments surrogate for this condition.

Condition Q One RTB (FU18)

Reactor Trip 1of2 Not Modeled This SSC is used as a surrogate for inoperable Two RTB trains Initiation No RTB trains

-See other TS 3.3.1 RPS Instrumentation (Modes 1,2) comments Conditions.

Condition U (FU19)

One trip One RTB mechanism One RTB Undervoltage and Reactor Trip Undervoltage and Not Modeled The condition of one of two inoperable inoperable for one Shunt Trip Mechanism per RTB Initiation No Shunt Trip Mechanism

-See reactor trip breakers is used as a RTB (Modes 1,2) train on any RTB train comments surrogate for this condition.

TS 3.3.2, ESFAS Instrumentation (Table 3.3-2)

The operator actions for failure to 1of2 (FU1a)

Safety Injection Not Modeled manually actuate SI will be used as a Two Manual Initiation channels Initiation No Manual Initiation

-See surrogate to conservatively bound the Condition B channels comments risk increase associated with this One channel function as permitted bv NEI 06-09.

inoperable (FU3a)

Containment 1of2 Not Modeled The condition of manual SI function Two Manual Initiation channels Isolation No Manual Initiation

-See inoperable is used as a surrogate for Initiation channels comments this condition since an SI signal aenerates a Cl sianal.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 4 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Comments Description (FU1 b) 1of2 The failure of the automatic SI signals Automatic Not Modeled will be used as a surrogate to Two Automatic Safety Injection No Actuation Logic and

-See conservatively bound the risk increase Actuation Logic and Actuation Initiation Actuation Relay trains comments associated with this function as Condition C Relay trains channels oermitted bv NEI 06-09.

One train 1of2 inoperable.

(FU3b)

Containment Automatic Not Modeled The condition of automatic SI function Two Automatic Isolation No Actuation Logic and

-See inoperable is used as a surrogate for Actuation Logic and Actuation Initiation Actuation comments this condition since an SI signal Relay trains Relay trains generates a Cl signal.

(FU1c) 2 of 3 Not Modeled The condition of automatic SI function Three Containment Pressure -

Safety Injection No Containment Pressure

-See inoperable is used as a surrogate for High channels Initiation

- High channels comments this condition since it is the same function (SI initiation).

(FU1d) 2 of 3 Not Modeled The condition of automatic SI function Three Pressurizer Pressure -

Safety Injection No Pressurizer Pressure -

-See inoperable is used as a surrogate for Low channels Initiation Low channels comments this condition since it is the same function (SI initiation).

(FU1e) 2 of 3 Not Modeled The condition of automatic SI function Three Steam Line Pressure -

Safety Injection No Steam Line Pressure -

-See inoperable is used as a surrogate for Low channels per steam line Initiation Low channels per main comments this condition since it is the same steam line function (SI initiation).

Condition D The failure of the model logic for steam One channel (FU4c)

Steam Line 2 of3 Not Modeled generator isolation will be used as a inoperable.

Three Containment Pressure -

Isolation No Containment Pressure

-See surrogate to conservatively bound the High, High channels Initiation

- High, High channels comments risk increase associated with this function as permitted bv NEI 06-09.

(FU4d) 1 of 2 High Steam Two High Steam Flow Steam Line Flow channels Not Modeled The condition of steam generator channels; Coincident with SI Isolation No coincident with SI and

-See isolation function inoperable is used as and Coincident with three T avg -

coincident with 2 of 3 Low, Low channels per RCS Initiation Tavg - Low, Low comments a surrogate for this condition.

loop channels (FU4e)

Steam Line Not Modeled The condition of steam generator Two High, High Steam Flow channels per steam line; Isolation No 1 of 2

-See isolation function inoperable is used as Coincident with SI Initiation comments a surrogate for this condition.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 5 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Comments Description High, High Steam Flow channels per steam line coincident with SI (FU5b)

Feedwater 2 of3 Not Modeled The condition of steam generator Three SG Water Level - High Isolation No SG Water Level - High

-See isolation function inoperable is used as channels per SG Initiation channels per SG comments a surrogate for this condition.

2 of3 The failure of the model logic for these (FU6b)

Auxiliary SG Water Level - Low, Not Modeled relays will be used as a surrogate to Three SG Water Level - Low, Feedwater No Low channels on any

-See conservatively bound the risk increase Low channels per SG Initiation comments associated with this function as SG permitted bv NEI 06-09.

Condition F (FU4a)

Steam Line One Manual Initiation Not Modeled The condition of steam generator One channel One Manual Initiation channel Isolation No channel per RCS loop

-See isolation function inoperable is used as inoperable per RCS loop Initiation comments a surrogate for this condition.

(FU4b)

Steam Line 1of2 Not Modeled The condition of steam generator Automatic Actuation Two Automatic Actuation Logic Isolation No Logic and Actuation

-See isolation function inoperable is used as and Actuation Relay trains Initiation Relav trains comments a surrogate for this condition.

(FU5a) 1of2 Not Modeled Condition G Feedwater Automatic Actuation The condition of AFW initiation is used One train Two Automatic Actuation Logic Isolation No Logic and Actuation

-See as a surrogate for this condition.

inoperable and Actuation Relay trains Relay trains comments 1of2 The failure of the model logic for these (FU6a)

Auxiliary Automatic Actuation Not Modeled relays will be used as a surrogate to Two Automatic Actuation Logic Feedwater No Logic and Actuation

-See conservatively bound the risk increase and Actuation Relay trains Relay trains comments associated with this function as permitted bv NEI 06-09.

1 of2 The failure of the model logic for Condition H (FU6d)

Auxiliary Undervoltage Bus Not Modeled starting all four AFW pumps will be One channel Two Undervoltage Bus A01 and Feedwater No channels on

-See used as a surrogate to conservatively inoperable A02 channels per electrical bus A01 and A02 comments bound the risk increase associated with this function as permitted bv NEI 06-09.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 6 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s}

Modeled Criteria Criteria Comments Description TS 3.4, Reactor C.oolant System TS 3.4.11 Condition B One PORV Two Power Operated Relief RCS pressure Yes 1 of2 Same inoperable and not Valves (PORVs) control PO RVs capable of being manually cycled TS 3.4.11 Condition C Two PORV Block Valves RCS integrity Yes Associated Block Same One block valve Valve closure inoperable TS 3.5, Emergency Core Cooling System (ECCS}

1 of 2 SI pumps, and Two ECCS trains each Emergency 1 of 2 RHR pumps TS 3.5.2 comprised of one SI pump, one core cooling Condition A RHR pump, one RHR heat and post-1 of 2 RHR pumps w/

One ECCS train exchanger and associated accident (long-Yes suction from Same inoperable RWST and containment sump term) core containment sump, flowpaths cooling supplying suction to 1 of 2 SI pumps for flowpath to RCS TS 3.6, Containment Systems TS 3.6.2 Condition C One of two The failure of the model logic for One or more One equipment hatch; ltwo Containment containment air lock Not Modeled containment penetrations will be used containment air personnel airlocks (one for integrity No doors closed with

-See as a surrogate to conservatively bound locks inoperable emergency use)[MJ1J acceptable comments the risk increase associated with this for reasons other containment leakage function as permitted by NEI 06-09.

Condition A or B

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2023-011 Page 7 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRA Success Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Comments Description TS 3.6.3 Condition A One or more penetration flow paths with one The failure of the model logic for containment Two isolation valves on each Containment 1 of2 Not Modeled containment penetrations will be used isolation valve containment penetration integrity No isolation valves per

-See as a surrogate to conservatively bound inoperable penetration isolate comments the risk increase associated with this (applicable to function as permitted by NEI 06-09.

penetration flow paths with two containment isolation valves)

TS 3.6.3 Condition C One or more penetration flow paths with one The failure of the model logic for containment One isolation valve and one Each Not Modeled containment penetrations will be used isolation valve Containment inoperable closed system on each integrity No isolation valve per

-See as a surrogate to conservatively bound containment penetration penetration isolates comments the risk increase associated with this (applicable to function as permitted by NEI 06-09.

penetration flow paths with one containment isolation valve and a closed system)

TS 3.7, Plant Systems TS 3.7.2 Condition A Two Main Steam Lines Steam Line One Steam equipped with one Main Steam Isolation from MSIV on affected Generator Yes Same flowpath with one Isolation Valve (MSIV) and one Faulted Steam steam line isolates or more inoperable Non-Return Check Valve Line valves in MODE 1

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Description Function(s)

Modeled Criteria Criteria TS 3.7.4 Condition A Two Atmospheric Dump Valves Facilitate Unit 1of2 One required ADV cooldown to Yes Same flowpath (AD Vs)

SOC conditions ADV flowpaths inoperable TS 3.7.5 Condition A Turbine driven AFW pump system inoperable due to One turbine-driven AFW pump Feedwater One motor driven AFW one inoperable and one motor-driven AFW supply to SGs Yes pump supplies CST Same steam supply, pump and associated CST and upon loss of feedwater to OR Turbine driven SW suction piping main feedwater both SGs AFW pump system inoperable in MODE 3 following refueling TS 3.7.5 Condition B One turbine-driven AFW pump Feedwater One turbine driven OneAFWpump system inoperable and one motor-driven AFW supply to SGs Yes AFW pump supplies Same in MODE 1, 2 or 3 pump and associated CST and upon loss of CST feedwater to both for reasons other SW suction piping main feedwater SGs than Condition A Two Component Cooling Water Heat sink for TS 3.7.7 (CCVI/) trains each consisting of removing 1 CCW pump and Condition A one CCW pump and one CCW process and 1 CCW HX provide One CC pump heat exchanger, and one operating heat Yes heat sink to Same common CCW heat exchanger from safety-safety related inoperable capable of aligning to either related equipment train components L-2023-011 Page 8 of 12 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Description Two Component Cooling Water Heat sink for TS 3.7.7 (CCW) trains each consisting of removing 1 CCW pump and Condition B one CCW pump and one CCW process and 1 CCW HX provide One required CC heat exchanger, and one operating heat Yes heat sink to Same heat exchanger common CCW heat exchanger from safety-safety related inoperable capable of aligning to either related equipment train components TS 3.7.8 Heat sink for 2 SW pumps and Condition A Six Service Water (SW) system removing 1 SW Ring Header One SW pump pumps, one common ring process and provide heat sink to inoperable AND header, non-essential flowpath operating heat Yes CCW system and Same Both units in isolation valves and associated from safety-essential loads; auto-Modes 1, 2, 3, or 4 SW intake piping related isolate non-essential components flowpaths TS 3.7.8 Heat sink for 2 SW pumps and Condition C Six Service Water (SW) system removing 1 SW Ring Header SW ring header pumps, one common ring process and provide heat sink to continuous header, non-essential flowpath operating heat Yes CCW system and Same flowpath isolation valves and associated from safety-essential loads; auto-SW intake piping related isolates non-essential interrupted components flowpaths TS 3.7.8 Condition D One or more Heat sink for 3 SW pumps and non-essential-SW-load flowpath(s)

Six Service Water (SW) system removing 1 SW Ring Header pumps, one common ring process and provide heat sink to with one required header, non-essential flowpath operating heat Yes CCW system and Same automatic isolation valve inoperable.

isolation valves and associated from safety-essential loads; auto-AND Affected non-SW intake piping related isolates non-essential essential components flowpaths flowpath(s) not isolated L-2023-011 Page 9of12 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Description TS 3.8, Electrical Power Systems TS 3.8.1 Condition A Power One circuit Associated unit Two circuits between the offsite Class 1E between the offsite 345/13.8 kV transmission network via the 4.16 kV transmission network (X03) 345/13.8 kV (X03) safeguards via a 345/13.8 kV transformer transformers and the buses from (X03) transformer inoperable.

13.8/4.16kV (X04) transformers, offsite Yes and a 13.8/4.16kV Same OR and the associated unit's 4.16 transmission (X04) transformer, and Gas turbine not in kV Class 1 E safeguards buses networks an associated unit's operation when 4.16 kV Class 1E utilizing opposite safeguards bus unit's 345/13.8 kV (X03) transformer.

Two circuits between the offsite Power One circuit Class 1E between the offsite TS 3.8.1 transmission network via the 4.16 kV transmission network Condition B 345/13.8 kV (X03) safeguards via a 345/13.8 kV transformers and the Associated unit's 13.8/4.16kV (X04) transformers, buses from Yes (X03) transformer Same 13.8/4.16kV (X04) and the associated unit's 4.16 offsite and a 13.8/4.16kV transformer kV Class 1 E safeguards buses transmission (X04) transformer, and inoperable networks an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1 Two circuits between the offsite Power One circuit Condition C transmission network via the Class 1E between the offsite Associated unit's 345/13.8 kV (X03) 4.16 kV transmission network required offsite transformers and the safeguards via a 345/13.8 kV power source to 13.8/4.16kV (X04) transformers, buses from (X03) transformer buses A05 and and the associated unit's 4.16 offsite Yes and a 13.8/4.16kV Same A06 inoperable.

kV Class 1 E safeguards buses transmission (X04) transformer, and OR AND networks and an associated unit's Required offsite Two onsite emergency power on site 4.16 kV Class 1E power source to sources capable of supplying emergency safeguards bus buses 1A05 and the associated unit's 4.16 kV power sources OR 2A06 inooerable Class 1 E safequards buses One onsite emerqencv L-2023-011 Page 10of12 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Function(s)

Modeled Criteria Criteria Description power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit Two circuits between the offsite Power between the offsite transmission network via the Class 1E transmission network TS 3.8.1 345/13.8 kV (X03) 4.16 kV via a 345/13.8 kV Condition D transformers and the safeguards (X03) transformer One or more 13.8/4.16kV (X04) transformers, buses from and a 13.8/4.16kV required and the associated unit's 4.16 offsite (X04) transformer, and offsite power kV Class 1 E safeguards buses transmission Yes an associated unit's Same source(s) to one or AND networks and 4.16 kV Class 1E more required Two onsite emergency power on site safeguards bus, OR Class 1E 4.16 kV sources capable of supplying emergency One onsite emergency bus( es) the associated unit's 4.16 kV power sources power source capable inoperable Class 1 E safeguards buses of supplying an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1 One circuit Condition F Two circuits between the offsite Power between the offsite One or more Class 1E transmission network required transmission network via the 4.16 kV via a 345/13.8 kV 345/13.8 kV (X03) offsite power transformers and the safeguards (X03) transformer source to one or 13.8/4.16kV (X04) transformers, buses from and a 13.8/4.16kV more Class 1 E and the associated unit's 4.16 offsite (X04) transformer, and 4.16 kV kV Class 1 E safeguards buses transmission Yes an associated unit's Same safeguards AND networks and 4.16 kV Class 1 E bus(es) inoperable Two onsite emergency power on site safeguards bus AND Standby sources capable of supplying emergency OR emergency power the associated unit's 4.16 kV power sources One onsite emergency inoperable to Class 1 E safeguards buses power source capable redundant of supplying an equipment associated unit's 4.16 L-2023-011 Page 11 of 12 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRA Success Condition Applicable SSCs Function{s)

Modeled Criteria Criteria Description kV Class 1E safeguards bus Supply Two 125 VDC required DC electrical subsystems TS 3.8.4 Four 125 VDC electrical motive and of the same electrical Condition A subsystems each consisting of control power train, each consisting One DC electrical a battery charger backed by a to shut down Yes of a battery charger Same power subsystem station battery powering the the reactor backed by a station inoperable associated DC distribution bus and maintain it battery powering the in a safe associated DC condition distribution bus Supply Two 120VAC Four 120 VAC instrument 120 VAC instrument channels of TS 3.8.7 channels each equipped with a battery-backed the same electrical Condition A 120 VAC instrument inverter power to Yes train, each equipped Same One required powering two 120 VAC various safety-with a 120 VAC inverter inoperable electrical buses related instrument inverter instrument powering two 120 VAC racks electrical buses L-2023-011 Page 12of12 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

FU4 Source range high neutron flux FU3 Intermediate range high Uncontrolled Rod Withdrawal Power range high neutron neutron flux 14.1.1 FU2b 2 out of 4 from Subcritical flux (low setting)

Power range high FU2a neutron flux (low setting)

FU1 Manual Trip FU6 Overpower Ll T FU2a Power range high neutron 2 out of 4 FU7b Pressurizer pressure -

Uncontrolled Rod flux (high setting)

High 14.1.2 Withdrawal at Power FU5 Overtemperature Ll T 2 out of 4 FU8 Pressurizer Level - High FU1 Manual Trip FU5 Overtemperature Ll T FU6 Overpower Ll T 14.1.3 Rod Cluster Control NA No primary Rx trip credited NA Assembly (RCCA) Drop Pressurizer Pressure -

FU7a Low FU1 Manual Trip 14.1.4 Chemical and Volume FU2a Power range high neutron 2 out of 4 FU6 Overpower Ll T Control System Malfunction flux (high setting)

L-2023-011 Page 1 of 7 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

Source range high FU4 neutron flux (during FU5 Overtemperature LlT 2 out of 4 startup)

FU1 Manual Trip FU2b Power range high Startup of an Inactive neutron flux (low setting).

14.1.5 Reactor Coolant Loop NA No primary Rx trip credited NA FU5 Overtemperature LlT FU2b Power range high neutron flux (low setting).

FU5 Overtemperature LlT 14.1.6 Reduction in Feedwater FU2b No primary Rx trip credited NA Enthalpy Incident FU6 Overpower Ll T FU1 Manual Trip Power range high FU2a neutron flux (high settino).

FU5 Overtemperature Ll T 14.1.7 Excessive Load Increase NA No primary Rx trip credited NA Incident FU6 Overpower Ll T FU? a Pressurizer Pressure -

Low L-2023-011 Page 2 of?

Comments Assuming at-power dilution with no operator action

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

FU1 Manual Trip FU10a RCP breaker position -

FU10b (single loop) (two loops) 1 out of 2 FU12 Underfrequency Bus FU9a RCS Flow - Low A01, A02 FU9b (single loop) (two loops) per loop 14.1.8 Loss of Reactor Coolant FU5 Overtemperature LlT Flow FU11 Undervoltage Bus A01, A02 1 out of 2 Pressurizer pressure -

FU?b per bus high taken twice FU1 Manual Trip FU8 Pressurizer Level - High Power range high FU? a Pressurizer pressure - High 2 out of 3 FU2a neutron flux (high 14.1.9 Loss of External Electrical settinQ).

Load SG Water Level - Low, FU5 Overtemperature.6. T 2 out of 4 FU13 Low FU15a Turbine trip on low oil pressure L-2023-011 Page 3 of 7 Comments Turbine trip causes Rx trip above P9 Assuming no PORV or Steam dump valve release

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

FU15b Turbine trip on stop valve closure SG Water Level Low; FU14 coincident w/ Steam Flow I Feed Flow Mismatch FU?b Pressurizer pressure -

high FUS Pressurizer Level - High 14.1.10 Loss of Normal Feedwater FU13 SG Water Level - Low, Low 2 out of 3 FU5 Overtemperature ti.T FU15a Turbine trip on low oil pressure FU15b Turbine trip on stop valve closure FU1 Manual Trip SG Water Level Low; 14.1.11 Loss of All AC Power to FU13 SG Water Level - Low, Low 2 out of 3 FU14 coincident w/ Steam Station Auxiliaries Flow I Feed Flow Mismatch L-2023-011 Page 4 of 7 Comments Turbine trip causes Rx trip above P9

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

FU7b Pressurizer pressure -

high FUS Pressurizer Level - High FU5 Overtemperature Lff FU15a Turbine trip on low oil pressure FU15b Turbine trip on stop valve closure FU9a RCS Flow - Low FU9b (single loop) (two loops)

FU11 Undervoltage Bus A01, A02 FU12 Underfrequency Bus A01, A02 14.1.12 Likelihood ofTurbine-NA Rx trip not credited NA NA Rx trip not credited Generator Unit Overspeed 14.2.1 Fuel Handling Accident NA Rx trip not credited NA NA Rx trip not credited 14.2.2 Accidental Release-Recycle NA Rx trip not credited NA NA Rx trip not credited or Waste Liquid 14.2.3 Accidental Release-Waste NA Rx trip not credited NA NA Rx trip not credited Gas 14.2.4 Steam Generator Tube FU? a Pressurizer Pressure - Low 2 out of 3 FU16 Safety Injection (SI) Input Rupture -

from ESFAS L-2023-011 Page 5 of 7 Comments

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s)

FU5 Overtemperature Lff 2 out of 4 FU1 Manual Trip Power range high FU2a neutron flux (high settinQ).

FU6 Overpower Lff 14.2.5 Rupture of a Steam Pipe FU7a Pressurizer Pressure - Low 2 out of 3 FU16 Safety Injection (SI) Input from ESFAS FU1 Manual Trip FU2a Power range high neutron 2 out of 4 FU6 Overpower Lff Rupture of a Control Rod flux (high setting) 14.2.6 Mechanism Housing -

RCCA Ejection FU2b Power range high neutron 2 out of 4 FU1 Manual Trip flux (low setting) 14.2.7 Inadvertent Opening of a NA NA NA NA NA SIG Relief or Safety Valve FU16 Safety Injection (SI) Input Small Break Loss-of-Coolant from ESFAS 14.3.1 Accident FU7a Pressurizer Pressure - Low 2 out of 3 FU5 Overtemperature /::,. T FU16 Safety Injection (SI) Input from ESFAS 14.3.2 Large Break Loss-of-FU7a Pressurizer Pressure - Low 2 out of 3 FU9a RCS Flow - Low Coolant Accident FU9b (single loop) (two loops)

FU1 Manual Trip L-2023-011 Page 6 of 7 Comments Bounded by 'Rupture of a Steam Pipe' event Analysis assumes beyond Charging pump capacity

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary Trip Function Channels Functional Diverse Trip Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s) 14.3.3 Core and Internals Integrity NA NA NA NA NA Analysis 14.3.4 Containment Integrity NA NA NA NA NA Evaluation 14.3.5 Radiological Consequences NA NA NA NA NA of Loss-of-Coolant Accident 14.3.6 Reactor Vessel Head Drop NA NA NA NA NA Event

(*)Functional Unit (FU)# from Point Beach TS Table 3.3.1-1 L-2023-011 Page 7 of 7 Comments See Large Break LOCA event See Large Break LOCA event See Large Break LOCA event Rx trip not credited

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Primary ESFAS Function Channels Functional Diverse ESFAS Section transient/accident Unit (FU)*

to Trip Unit (FU)*

Function(s) 14.1.1 Uncontrolled Rod Withdrawal NA NA NA NA NA from Subcritical 14.1.2 Uncontrolled Rod NA NA NA NA NA Withdrawal at Power 14.1.3 Rod Cluster Control NA NA NA NA NA Assembly (RCCA) Drop 14.1.4 Chemical and Volume NA NA NA NA NA Control System Malfunction 14.1.5 Startup of an Inactive NA NA NA NA NA Reactor Coolant Loop 14.1.6 Reduction in Feedwater NA NA NA NA NA Enthalpy Incident 14.1.7 Excessive Load Increase NA NA NA NA NA Incident 14.1.8 Loss of Reactor Coolant NA NA NA NA NA Flow 14.1.9 Loss of External Electrical NA NA NA NA NA Load FU6d AFW on Undervoltage Bus A01 and A02 FU6c AFW on Safety Injection (SI)

AFW on SG Water Level -

2-out-of-3 14.1.10 Loss of Normal Feedwater FU6b Low, Low FU1a AFW on Manual SI NA AFWonAMSAC L-2023-003 Page 1 of 3 Comments No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

FU6d AFW on Undervoltage Bus A01 and A02 Loss of All AC Power to FU6b AFW on SG Water Level -

2-out-of-3 FU6c AFW on Safety Injection (SI) 14.1.11 Station Auxiliaries Low, Low FU1a AFW on Manual SI 14.1.12 Likelihood ofTurbine-NA NA NA NA NA Generator Unit Overspeed 14.2.1 Fuel Handling Accident NA NA NA NA NA 14.2.2 Accidental Release-Recycle NA NA NA NA NA or Waste Liquid 14.2.3 Accidental Release-Waste NA NA NA NA NA Gas Steam Generator Tube FU1d SI on Pressurizer Pressure -

2-out-of-3 FU1a Manual SI 14.2.4 Rupture Low SU on SG Flow - High, FU4d coincident with SI and Low Tavq FU4c SU on Containment Pressure - High, High Steam Line Isolation (SU)

FU4e on SG Flow - High, High, 1-out-of-2 FU6c AFW on Safety Injection (SI) coincident with SI 14.2.5 Rupture of a Steam Pipe SI on Pressurizer Pressure -

FU1e SI on SG Pressure - Low 2-out-of-3 FU1d Low FU6b AFW on SG Level - Low, 2-out-of-3 SI on Containment Pressure Low FU1c

-High, High FU1a Manual SI L-2023-003 Page 2 of 3 No credited ESF actuation No credited ESF actuation No credited ESF actuation No credited ESF actuation

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

Rupture of a Control Rod 14.2.6 Mechanism Housing -

NA NA RCCA Ejection 14.2.7 Inadvertent Opening of a NA NA SIG Relief or Safety Valve Small Break Loss-of-Coolant SI on Pressurizer Pressure 14.3.1 Accident FU1d

-Low FU1d SI on Pressurizer Pressure 14.3.2 Large Break Loss-of-

-Low Coolant Accident FU2c CS on Containment Pressure - High, High 14.3.3 Core and Internals Integrity NA NA Analysis 14.3.4 Containment Integrity FU4c CS on Containment Evaluation Pressure - High, High 14.3.5 Radiological Consequences FU4c CS on Containment of Loss-of-Coolant Accident Pressure - High, High 14.3.6 Reactor Vessel Head Drop NA NA Event

(*) Functional Unit (FU)# from Point Beach TS Table 3.3.2-1

(**) 2 out of 3 taken twice; RICT not requested FU4a Manual SU NA NA NA NA NA NA FU1c SI on Containment Pressure

- High 2-out-of-3 FU1a Manual SI FU1c SI on Containment Pressure

- High 2-out-of-3 FU1a Manual SI 2-out-of-3**

FU 2a Manual CS NA NA NA NA NA NA NA NA NA NA NA NA L-2023-003 Page 3 of 3 No credited ESF actuation Bounded by 'Rupture of Steam Pipe' Event Analysis assumes beyond Charging pump capacity See Large Break LOCA event See Large Break LOCA event See Large Break LOCA event No credited ESF actuation