View source for L-14-064, Supplemental Information Regarding Application for License Amendment to Adopt NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

{{Adams
| number = ML14051A499
| issue date = 02/14/2014
| title = Supplemental Information Regarding Application for License Amendment to Adopt NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
| author name = Larson E
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-14-064, TAC MF3301, TAC MF3302
| document type = Graphics incl Charts and Tables, Letter type:L
| page count = 303
| project = TAC:MF3301, TAC:MF3302
| stage = Supplement
}}

=Text=
{{#Wiki_filter:FENOC-               %P.O.
Beaver Valley Power Station Box 4 FirstEnergy Nuclear OperatingCompany Eric A. Larson                                                                                  724-682-5234 Site Vice President                                                                       Fax: 724-643-8069 February 14,        2014 L-14-064 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Units No. 1 and 2 BVPS-1 Docket No. 50-334, License No. DPR-66 BVPS-2 Docket No. 50-412, License No. NPF-73 Supplemental Information Regarding Application for License Amendment to Adopt NFPA 805, "Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)" (TAC Nos. MF3301. MF3302)
By letter dated December 23, 2013 (Agencywide Documents Access and Management System Accession Number ML14002A086), FirstEnergy Nuclear Operating Company submitted an application for license amendment to adopt NFPA 805 as the licensing basis for fire protection programs at the Beaver Valley Power Station (BVPS). In support of the application for license amendment, an analysis of the adequacy of the internal events probabilistic risk assessment (PRA) for BVPS is enclosed.
There are no regulatory commitments established in this letter or its enclosure. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February ji__, 2014.
Sincerely, Eric A. Larson

==Enclosure:==
Beaver Valley Power Station Units 1 and 2 - Internal Events PRA Quality cc: Director - NRC Office of Enforcement (w/o Enclosure)
NRC Regional Administrator - Region I (w/o Enclosure)
NRC Resident Inspector (w/o Enclosure)
NRC Project Manager (w/o Enclosure)
Director - State of Pennsylvania BRP/DEP (w/o Enclosure)
Site Representative - State of Pennsylvania BRP/DEP (w/o Enclosure)
IV(

Enclosure L-14-064 Beaver Valley Power Station Units 1 and 2 Internal Events PRA Quality (301 pages follow)

Beaver Valley Power Station Units I and 2 Internal Events PRA Quality Page 1 of 301

The Level 1 and Level 2 Probabilistic Risk Assessment (PRA) analyses for Beaver Valley Power Station (BVPS) Units 1 and 2 were originally developed in response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities -
10 CFR 50.54(f).
The BVPS-1 Individual Plant Examination (IPE) and the Individual Plant Examination of External Events (IPEEE) were submitted to the Nuclear Regulatory Commission (NRC) in October 1992 and June 1995, respectively. Since the inception of these studies, the BVPS-1 PRA model has evolved and has been updated many times. The following table provides a summary of the BVPS-1 PRA model revision history.
Date     Revision   BVPS-1 PRA Model Chanae 10/1992       0      Individual Plant Examination (IPE) NRC submittal 06/1995        1      Individual Plant Examination - External Events (IPEEE) NRC submittal 06/1998        2      Integrated Level 1 and Level 2 models 09/2003        3      WOG NEI 00-02 Peer Review with Category A/B F&Os addressed 06/2006        4      HRA [Human Reliability Analysis] Calculator, replacement steam generators, atmospheric containment conversion, and extended power uprate model 12/2010        5      RG 1.200, R1 (excluding Floods) CCII Compliant Model 01/2013       5a      Interim model update to include Internal Flooding, RG 1.200, R1 (including Floods) CCII Compliant Model The BVPS-2 Individual Plant Examination (IPE) and the Individual Plant Examination of External Events (IPEEE) were submitted to the NRC under separate letters in March 1992 and September 1997, respectively. Since the inception of these studies, the BVPS-2 PRA model has evolved and has been updated many times. The following table provides a summary of the BVPS-2 PRA model revision history.
Date     Revision   BVPS-2 PRA Model Chanae 03/1992        0      Individual Plant Examination (IPE) NRC submittal 09/1997        1      Individual Plant Examination - External Events (IPEEE) NRC submittal 10/1997        2      Integrated Level 1 and Level 2 models 01/2002       3A     WOG NEI 00-02 Peer Reviewed 05/2003       3B     WOG NEI 00-02 Peer Review with Category A/B F&Os addressed 04/2007        4      HRA [Human Reliability Analysis] Calculator, atmospheric containment conversion, and extended power uprate model 12/2010        5      RG 1.200, R1 (excluding Floods) CCII Compliant Model Page 2 of 301

08/2012        5a       Interim model update to include Internal Flooding, RG 1.200, R1 (including Floods) CCII Compliant Model The BVPS-1 and BVPS-2 PRA models, PRA-BV1-AL-R05 (BVI REV5) and PRA-BV2-AL-R05a (BV2REV5A), were the starting points for the Fire PRA. The BVPS PRA models have been subjected to assessments establishing the technical adequacy of the PRA. These assessments are identified and discussed in the paragraphs below.
9   2002 - An independent PRA peer review of the BVPS PRA models (BV1 REV3 and BV2REV3A) was conducted under the auspices of the Westinghouse Owners Group (WOG) in July 2002, following the guidance provided by the Nuclear Energy Institute in NEI 00-02, "Probabilistic Risk Assessment Peer Review Process Guidance,"
Revision A3, March 2000 (NEI 00-02).
* 2007 - Following the BVPS-1 PRA model revision in 2006 (BVI REV4) and the BVPS-2 PRA model revision in 2007 (BV2REV4) which incorporated necessary updates and changes to address F&Os from the 2002 peer review, a self-assessment of the BVPS PRA models was performed against the American Society of Mechanical Engineers Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications, (ASME-RA-S-2002, and addenda, hereafter referred to as the ASME PRA Standard) using NRC Regulatory Guide (RG) 1.200, Revision 1, January 2007, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk Informed Activities.
o   2007 - As part of the resolution to several F&Os from the 2002 PRA peer review, a change in the Human Reliability Analysis (HRA) methodology was incorporated into the 2006 BVPS-1 and the 2007 BVPS-2 PRA model revisions, so a focused scope peer review of the HRA Technical Elements against the ASME PRA Standard was performed using RG 1.200, Revision 1.
* 2011 - Due to an upgrade of the internal flooding model following the revision of both BVPS PRA models in 2010 (BV1 REV5 and BV2REV5), a focused scope peer review of the Internal Flood PRA Technical Elements was performed against the applicable requirements of Part 3 of the ASME PRA standard as endorsed in RG 1.200, Revision 2.
Facts and Observations (F&Os) from the various reviews are assigned significance levels of A, B, C, D, or S for the 2002 peer review and 2007 self-assessment; or Finding, Suggestion, or Best Practice for the 2007 HRA peer review and the 2011 Internal Flooding peer review. The F&O significance levels are defined as follows.
2002 Peer Review
" A - Extremely important and necessary to address to assure the technical adequacy of the PRA or the quality of the PRA or the quality of the PRA update process
"   B - Important and necessary to address, but may be deferred until the next PRA update Page 3 of 301

 " C - Recommended, and considered desirable to maintain maximum flexibility in PRA Applications and consistency in the Industry, but not likely to significantly affect results or conclusions
 " D - Editorial or Minor Technical Item, left to the discretion of the host utility
 " S - Superior treatment, exceeding requirements for anticipated applications and exceeding what would be found in most PRAs 2007 Self-Assessment
* A and B level F&Os represent issues that have the potential to affect the risk results and/or risk insights. B level F&Os also represent documentation issues that are required to meet Capability Category I1. All A and B level F&Os need to be resolved to achieve Capability Category II or higher.
" C and D level F&Os are comments or suggestions to improve documentation or traceability of analyses, but do no impact the supporting requirement grades. A C level F&O may also provide a suggestion on an alternative approach to achieve an objective, but does not imply that the approach used is not sufficient to meet the supporting requirements at the stated grade.
* S level F&Os are considered to be superior and do not reflect any shortfall to a requirement.
2007 HRA Focused Peer Review and 2011 Internal Flooding Focused Peer Review
"   Finding - Equivalent to the old A and B levels of significance
" Suggestion - In general, equivalent to the old C and D levels of significance
* Best Practice - Equivalent to the old Strength (S) level of significance The WOG conducted the Beaver Valley PRA model peer review following the NEI 00-02 process in July 2002. This peer review focused on the Unit 2 PRA model but also provided a cursory review of the Unit 1 PRA model and methodology. The Peer Review Team noted that Unit I uses the same PRA modeling techniques as Unit 2, so when the Unit 1 PRA revision is performed in the future using the same modeling assumptions as Unit 2 (including addressing applicable peer review comments) the Unit 1 PRA model and results should have the same level of confidence and applicability as those of Unit 2.
The significant findings (Category A and B F&Os) from the BVPS PRA peer review were incorporated into the 2003 BVPS-1 Revision 3 (BV1 REV3) and the 2003 BVPS-2 Revision 3B (BV2REV3B) PRA models respectively. A long term solution to one of the PRA peer review findings was to revise the human reliability analysis methodology from the success likelihood index methodology (SLIM) to the EPRI HRA Calculator. The BVPS HRA were revised using the EPRI HRA Calculator and the results were incorporated into the 2006 BVPS-1 Revision 4 (BV1 REV4) and 2007 BVPS-2 Revision 4 (BV2REV4) PRA models respectively. The Revision 4 PRA models included the Page 4 of 301

replacement steam generators for BVPS-1, and the atmospheric containment conversion and extended power uprate to 2900 MWt for both units.
Following the BVPS-1 PRA Model Revision 4 in 2006 and the BVPS-2 PRA Model Revision 4 in 2007, a self-assessment of the BVPS PRA models was conducted in 2007 with the assistance of Westinghouse. Once again this review focused on the BVPS-2 PRA model, but to the extent that the PRA modeling methodologies are equivalent this self-assessment was also applicable to the Unit 1 PRA. This self-assessment was performed to determine if there were any gaps present between the BVPS PRA models and meeting the Capability Category II Supporting Requirements (SR) in the 2005 version of the ASME PRA Standard Addendum B, as endorsed by RG 1.200, Revision 1.
The status of the A and B level F&Os from the 2002 BVPS peer review were also checked, and were found to be resolved when considering the change in methodology to the EPRI HRA Calculator and associated reports that document the HRA inputs and considerations.
In January 2008, Westinghouse provided the final summary report of the BVPS PRA models self-assessment to demonstrate compliance with the ASME PRA Standard and RG 1.200, Revision 1. A total of 73 F&Os were identified in this review, and this assessment provided a starting point for determining where enhancements to the model, sensitivity analyses, or evaluations outside the PRA may be needed for a given application of the PRA to adequately support the integrated decision-making process.
A focused scope peer review was conducted by Westinghouse in October 2007 on the upgraded BVPS HRA methodology (EPRI HRA Calculator) to determine compliance with Addendum B of the ASME PRA Standard and RG 1.200, Revision 1. Because the methodology is the same between Units and the basic analyses differ only in minor details, the review focused on the Unit 2 HRA Report but is also applicable to Unit 1.
Seven new F&Os were prepared to document the specific issues that were identified, all of which were classified as Findings.
In 2010 the BVPS-1 and BVPS-2 Revision 5 PRA models (BV1 REV5 and BV2REV5, respectively) resolved the identified PRA self-assessment F&Os and focused HRA peer review F&Os, with the exception of the 27 F&Os associated with internal flood which required an upgrade of the internal flooding model to comply with the ASME PRA Standard internal flooding methodology.
The BVPS-1 Revision 5 and the BVPS-2 Revision 5 internal flooding PRA models were upgraded to comply with the Capability Category II Supporting Requirements of the combined ASME/ANS PRA standard (RA-Sa-2009), as endorsed by RG 1.200, Revision 2. In June 2011, these upgraded BVPS PRA models underwent a focused PRA peer review on the Internal Flooding portion of the model, which superseded the previous 27 internal flooding F&Os from the 2007 self-assessment and resulted in 17 new F&Os.
The 17 internal flooding PRA F&Os were appropriately resolved in the interim 2013 BVPS-1 Revision 5a (BV1 REV5A) PRA model and the interim 2012 BVPS-2 Revision Page 5 of 301

5a (BV2REV5A) PRA model. These Revision 5a PRA models (documented as PRA-BV1-AL-R05a and PRA-BV2-AL-R05a, respectively) are the current effective reference models at BVPS.
The BVPS-1 Revision 5a PRA model (PRA-BV1-AL-R05a) and BVPS-2 Revision 5a PRA model (PRA-BV2-AL-R05a) have resolved all of the applicable F&Os identified in the 2002 BVPS PRA Peer Review, 2007 BVPS PRA Self-Assessment, 2007 BVPS HRA Focused Peer Review, and the 2011 BVPS Internal Flood PRA Focused Peer Review. These PRA models are considered to be fundamentally compliant with RG 1.200, Revision 1 for the scope of this application, meet Capability Category II or above in the ASME PRA Standard (RA-Sb-2005), and are capable of supporting all risk-informed applications requiring Capability Category I or II.
The Fire PRA model for BVPS-1 was based on the BVPS-1 Revision 5 PRA model, in which all previous F&Os except those related to internal flooding were resolved. Interim Issued Revision 5a PRA has already addressed all internal flooding F&Os. Final Fire PRA will be integrated into the updated working PRA model prior to the implementation of NFPA-805. The Fire PRA model for BVPS-2 was based on the BVPS-2 Revision 5a PRA model in which all F&Os, including those related to internal flooding, are resolved.
Furthermore, BVPS is currently working on a regular update of 5a internal events PRA models, and the final Fire PRA model will be integrated into the latest revision of the PRA models as they are rolled out.
A brief summary of the BVPS final resolutions to the A, B, C, and D level F&Os from the 2002 WOG NEI 00-02 BVPS PRA Peer Review is provided in Table 1-1 Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions, and Table 2-1 Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions.
The resolutions to the 2007 BVPS PRA Self-Assessment F&Os are provided in Table 1-2 Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions, and Table 2-2 Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions.
The resolution to the seven F&Os from the 2007 BVPS HRA Focused Peer Review are provided in Table 1-3 Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions, and Table 2-3 Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions.
The 2011 BVPS Internal Flood PRA Focused Peer Review F&O resolutions are provided in Table 1-4 Summary of BVPS-1 Internal Flooding Focused Peer Review -
Facts and Observations Resolutions, and Table 2-4 Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions.
Page 6 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O      Supporting.       Significance       Status    Fact& Observation                         BVPS-1 Final Resolution             Impact to Fire ID       Requirement'      Level              Closed                                                                                  PRA YIN AS-I 0   AS-12             A                  Y         The BV PRA uses the WOG 2000              Additional MAAP uncertainty         No impact to Fire seal LOCA in a way that may be            cases for BVPS-1 were               PRA, because this unacceptable to the NRC for risk          performed using pessimistically     issue was based applications. MAAP runs are         biased values along with setting    addressed in the performed to find the core uncovery       input parameters to their high or   base PRA model times for various sizes of seal LOCA. low limits. These cases were run    prior to building the If the best estimate MAAP runs show       out to 48-hours or until core       Fire PRA.
the core is covered at 24 hours, the      damage occurred. The success sequence is considered success. The       state for the BV1 REV3 PRA result is that all SLOCA sizes except     model was redefined as any case the 480 gpm leak have no impact on        (including uncertainties) that did CDF, because the core is shown to         not go to core damage before 48-remain covered at 24 hours. This strict   hours. For cases that went to interpretation of the 24 hour mission     core damage before 48-hours but time results in a .01 probability of core after 24-hours, additional electric uncovery, even in sequences where         power recovery values were SW or AC power is not restored.           used, based on NUREG/CR-5496. For cases that lead to This result is significantly more         core uncovery before 24-hours, a optimistic than most other                plant specific electric power Westinghouse PRAs. The uncertainty        recovery model was used. If in the calculation [due to the possible   electric power recovery was variation in RCS pressure or seal         successful for these cases, the LOCA size from the predicted] is not      sequence was also binned to the pursued.                                  success end state.
The MAAP analysis shows time to core uncoverv of areater than 24
' The Supporting Requirement is in reference to NEI 00-02 Element - Subelement.
Page 7 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution Impact to Fire ID     Requirement 1 Level        Closed                                                                  PRA YIN hours, but the plant is not yet in a stable configuration. Declaration of success at this point, based only on MAAP results without thorough investigation of MAAP uncertainties (e.g., sensitivities) is a liberal application of the intent of the 24 hour success criteria and may be non-conservative.
Page 8 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution            Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN HR-07  HR-10         A            Y      The BV PRA uses the SLIM                   As a resolution to this PRA Peer   No impact to Fire methodology. The HEP's are grouped         Review observation all operator    PRA, because this in to 10 categories and then each          actions having a Risk              issue was category is "calibrated" in terms of 1 to  Achievement Worth (RAW)            addressed in the 5 other PRA's. The PRA's that were         greater than 2 (generally          base PRA model used were Oconee (1984), Seabrook          accepted as the risk significant   prior to building the (1983), Diablo Canyon (1987), TMI          threshold) were compared to        Fire PRA.
(1985), Fermi (not referenced), South      similar actions for all Texas (1988). The categories reflect       Westinghouse plants by using each type of error (rule, skill,           the WOG/B&WOG PSA knowledge, diagnosis, response). The       Comparison Database HRA's on which these are based are         (Revisions 2 and 3). Additionally, representative of nuclear plant            a smaller subset of these plants procedures, training and operator          was also looked at that consisted cognizance typical for mid-1980.           of 3-loop plants (since these were assumed to have similar The error rate curves should be            operation action completion updated to reflect current operator        times based on plant power to performance in the nuclear power           heatup volume ratios), plants that industry. The use of 15 year old           also used the SLIM process, and reliability data will limit the ability of Indian Point 2, which received a the PRA to support risk based              superior finding in their Human applications.                              Reliability Analysis.
The results of this comparison show that for the operator actions that were compared, the human error rates used in the BVI REV3 PRA model are all within the range of both comparison groups defined above. It is therefore believed that the basic error curves used in the calibration of Page 9 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                     BVPS-1 Final Resolution           Impact to Fire ID      RequirementI Level        Closed                                                                         PRA YIN the BV1 REV3 HRA are not grossly out of date, and that the current human error rates used in the PRA model are acceptable as is. Moreover, as a final resolution to this observation, future BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology.
This F&O was written against an obsolete HRA PRA model (BV1 REV3) and is considered to be resolved by the updated HRA PRA model incorporated in BV1 REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-1 1 HR-27        A            Y      The BV HRA does not have a process    To identify dependent human       No impact to Fire to perform a systematic search for    actions, sequences with two or    PRA, because this dependent human actions credited on   more failed split fractions that  issue was individual sequences. One case of     have a contribution from human    addressed in the dependent HEPs was identified and     actions were reviewed. Of the     base PRA model treated (OF1 and 0B2). However, it is sequences reviewed the human      prior to building the Page 10 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution            Impact to Fire ID     Requirement' Level        Closed                                                                              PRA YIN not known how this was found. Other       actions were determined to be      Fire PRA.
potential cases of dependent human        independent between split actions in SGTR. LOCAs or feed and        fractions. Human actions that are bleed sequences were not addressed.       modeled in a single top event PRAs typically have one or more of        have appropriate dependencies the dependent HEPs.                       modeled in the event tree logic and rules.
SGTR-OD*CD*WM, or RR*WM SGTR-SL*OD*CD*WM                          Moreover, as a final resolution to SLOCA -CD*MU                              this observation, future BVPS Trans- OB*MU                              PRA models will use the EPRI Trans- OF*OB*MU                           HRA Calculator, which uses a Init - Start standby CCP
* Trip RCP       more current and robust methodology to identify human There could potentially be other          action dependencies.
combinations that were not identified.
This F&O was written against an Current HRA practices generally           obsolete HRA PRA model require a systematic process to           (BV1 REV3) and is considered to identify, assess and adjust               be resolved by the updated HRA dependencies between multiple             PRA model incorporated in human errors in the same sequence,        BV1 REV4, which underwent a including those in the initiating events. focused Peer Review in accordance with the guidance in Moreover, there was no process in the     Appendix B of NRC RG 1.200, HRA to adjust HEP on the final            Rev.1, conducted during the sequences and determine                   week of October 29, 2007, by combinations of operator errors           Westinghouse. The F&Os as a credited on individual sequences. A       result from this focused Peer sensitivity study was done, but did not   Review, as well as their adjust the HEPs. The cutoff was 4E-9,     resolutions are presented in so that many other combinations were      Table 1-3.
already below the truncation. It is not Page 11 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status   Fact & Observation                        BVPS-1 Final Resolution            Impact to Fire ID      Requirement' Level        Closed                                                                                PRA Y/N clear how HEPs in the initiating events were treated in the study.
To be consistent with current HRA methods, there must be a systematic process to identify, assess and adjust dependencies between multiple human errors in the same sequence, including those in the initiating events.
AS-07   AS-1 9       B            Y        For the SGTR event tree one of the        Based on the EOP Background        No impact to Fire operator actions is to initiate Bleed     document for FR-H. 1, steam        PRA, because this and Feed (top event OB). The              generator dryout is expected to    issue was success criteria for OB indicates that    occur at 33.1 minutes if all RCP   addressed in the the basis for the success criteria        remain running during a loss of    base PRA model assumes that the operator must have       all secondary cooling. If the RCP  prior to building the stopped the RCPs prior to OB in order     are tripped 5 minutes after the    Fire PRA.
to extend the time available to initiate  reactor trip, steam generator bleed and feed (referenced EOP FR-        dryout is expected to occur at H.1). If the tripping of the RCPs is a    40.9 minutes. This difference of prerequisite for the degree of success    less than 8 minutes is not of OB where in the model is this          expected to significantly impact dependency accounted for.                 the human error rates calculated for Top Event OB, since the actions to trip the RCPs, initiate SI and open a PORV are fairly simple actions that can be accomplished within minutes.
Therefore, these actions are all assumed to be accounted for in the human action failure rate.
DA-06  DA-8         B            Y        The generic MGL data used in the BV       A summary of all of the MGL        No impact to Fire Unit 2 PRA is referenced, almost          parameters used in the top event   PRA, because this I exclusively to the PLG generic            common cause groupings is now      issue was Page 12 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                             PRA YIN database. Although the data analysis    provided in Appendix C, Table C-    addressed in the was updated recently, there is no       7 of the Data Analysis PRA          base PRA model discussion in the Data Analysis         Notebook. No further Corrective     prior to building the Notebook regarding the availability of  Actions are required.               Fire PRA.
newer data sources, e.g.,
NUREG/CR-5497. There should, at a       Updated common cause failure minimum be a discussion of the          data from WCAP-16672, based currently available data sources. It is on NUREG/CR-6819, were noted that at least one Beta factor     ultimately used in the BV2REV5 from NUREG/CR-5497 is used, but it      PRA model and appropriately is not referenced in the data notebook. documented. The methodology for the update was taken from NUREG/CR-5485.
DA-09  DA-1 0        B            Y      There is very little guidance for or    Resolutions to this F&O included    No impact to Fire documentation of the process of         adding a better reference to the    PRA, because this selecting CCF groups. The System        methodology used in retaining       issue was Analysis Overview and Guidance          the common cause groupings,         addressed in the Notebook provides some of the high      along with a listing of all of the  base PRA model level methodology, but there is no      common cause groupings used         prior to building the discussion in the Data Analysis or      in the quantification of the system Fire PRA.
System Notebooks as to the              top event models. These are development of the groups that were     provided in Section 6 "Common ultimately modeled. In general, the     Cause Modeling" and Appendix system notebooks document the CCF       A, Table A-1 of the BVPS-1 groups by referring to the Riskman      Systems Analysis Overview and output files. This is not very          Guidance PRA Notebook, informative. For example, the AC        respectively. Additionally, a Electric Power System Notebook          summary of all of the MGL provides no discussion of the CCF       parameters used in the top event model for the diesel generators. A      common cause groupings is now discussion of decoupling the Unit 2     provided in Appendix C, Table C-diesels from the Unit 1 should be       6 of the Data Analysis PRA included.                               Notebook.
Page 13 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                       BVPS-1 Final Resolution              Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA Y/N Furthermore, it is the opinion of the BVPS PRA staff that the details of the common cause groups that were retained in the PRA system models and presented in Appendix C of the BVPS Unit I PRA System Notebooks, under the common cause sections of the RISKMAN System Notebook files are adequately documented and can be found by knowledgeable personnel. Therefore, the practice of referencing this part of the notebook is deemed acceptable.
DA-O   DA-7          B            Y      The test and maintenance                Unit 2 emergency diesel              No impact to Fire unavailabilities for DG were reviewed,  generator unavailability data        PRA, because this The following were observed,            during refueling outages was         issue was collected for 3/99 through 2/02 by   addressed in the
: 1. The DG are used in a cross-tie       the system engineer. This data       base PRA model situation for either unit. Thus, it is  was used in addition to the 2.5%     prior to building the possible that the unaffected unit could assumed on-line unavailability,      Fire PRA.
be in shutdown and the DG could be      for a total Unit 2 emergency in overhaul. The outage time for the    diesel generator unavailability of DG (when used as a cross-tie) must      4.4% used in the BV1 REV3 PRA include the OOS time during             model update for the AC power shutdown.                               crosstie.
: 2. Appendix B of the data document indicates maintenance outage was collected Nov 98 through May 2000.
Page 14 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution           Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA YIN This is not long enough to capture the DG overhaul experience.
: 3. For unit 2, the unit 1 DG are used for the cross-tie. The T&M data must come from unit 1 experience. This information was not found.
DE-04  DE            B            Y      There is no discussion of some flow      In response to this observation,  No impact on the (Draft                            characteristics (e.g., spray effects,    the work that was completed for   submitted BVPS-1 IF-09)                            pipe whip) in the consideration of       the Beaver Valley Unit 1 Risk-    Fire PRA, which impacts from flood initiators.           Informed In-Service Inspection    used the (RI-ISI) Indirect (Spatial)       BV1REV5 as its Consequence Evaluation was        basis. Internal fire reviewed (8700-DMC-1333, Rev. initiators and flood 0). As a part of this evaluation  initiators are process, an assessment of the     mutually exclusive postulated indirect (spatial)     and have no effect consequences associated with      on each other.
piping failures was made in order to further distinguish the piping  Furthermore, the segments. The indirect effects     BVPS-1 Fire PRA assessment was accomplished       working model through an investigation of       uses BV1 REV5A I existing plant documentation on   as its basis, so this Page 15 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation         BVPS-1 Final Resolution              Impact to Fire ID     Requirement 1 Level        Closed                                                                 PRA Y/N pipe breaks, flooding, and plant     F&O will be layout along with a focused plant    resolved when walkthrough. The indirect effects    NFPA 805 is that were specifically looked at     implemented.
included; pipe whip, jet impingement, sprays, and flooding resulting from pipe breaks or leaks. The results of this indirect effects evaluation did not identify any viable SSC impacts due to flood induced failure mechanisms that were not already addressed in the PRA flooding analysis documentation.
No further flooding impacts were incorporated into the BV1 REV3 PRA.
This F&O was written against an obsolete Internal Flooding PRA model (BV1 REV3) and is considered to be resolved by the updated Internal Flooding PRA model incorporated in BV1 REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are Page 16 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                          BVPS-1 Final Resolution          Impact to Fire ID     Requirement' Level        Closed                                                                             PRA YIN presented in Table 1-4.
DE-05  DE           B            Y      A number of flood-specific HEPs are        To resolve this PRA Peer Review  No impact on the (Draft                           included in the analysis (e.g.,            observation at Unit 1, operator  submitted BVPS-1 IF-25,                           ZHEFL1-4). These four HEPs are             actions ZHEFL1, ZHEFL2,          Fire PRA, which IF-26)                           evaluated in the HRA Notebook in the       ZHEFL3, and ZHEFL4 were          used the calculation tables, but no discussion of   added to Table 3-1 "Beaver       BV1 REV5 as its these actions is included in the HRA       Valley Human Actions" and        basis. Internal fire documentation, and only ZHEFL1 and         discussions of the scenarios now initiators and flood ZHEFL2 appear in the flood                 appear in Appendix A"Dynamic     initiators are documentation in the Appendix C of         Action Identifier Sheets         mutually exclusive the IE Notebook.                                                            and have no effect This F&O was written against an  on each other.
obsolete Internal Flooding PRA model (BV1 REV3) and is          Furthermore, the considered to be resolved by the BVPS-1 Fire PRA updated Internal Flooding PRA    working model model incorporated in            uses BV1 REV5A BV1 REV5A, which underwent a     as its basis, so this focused Peer Review in           F&O will be accordance with the guidance in  resolved when Appendix B of NRC RG 1.200,      NFPA 805 is Rev. 1, conducted during June 6- implemented.
9 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are I presented in Table 1-4.
Page 17 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                    BVPS-1 Final Resolution            Impact to Fire ID     Requirement 1 Level        Closed                                                                          PRA YIN HR-01  HR-4          B            Y      Miscalibration errors are not         This observation is not totally    No impact to Fire considered for either independent or  correct, since the SSPS model      PRA, because this common cause pre-initiator human      did include instrument string      issue was errors. The PRA assumes that both     miscalibration errors in the fault determined to have would be captured in the equipment    tree model. Additionally,          no effect on the failure data. However, the generic    common cause miscalibration        BVPS PRA model.
common cause failure database is not  errors between trains are verified as having included           considered to be rare events miscalibration errors as well.        since the On-line Maintenance Therefore, there is a potential       Program is developed to misapplication of the generic common  alternate work between trains on cause data use since the generic data different weeks. Furthermore, a source may not include the common     search in the Corrective Action cause miscalibration.                 database and EPIX did not reveal any such miscalibration errors between trains at BVPS.
Therefore, this observation was assumed to be resolved by the instrument string miscalibration errors already accounted for in the SSPS model. No further miscalibration errors were incorporated into the BV1 REV3 PRA.
This F&O was written against an obsolete HRA PRA model (BV1 REV3) and is considered to be resolved by the updated HRA PRA model incorporated in BV1 REV4, which underwent a focused Peer Review in accordance with the guidance in Page 18 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                       BVPS-1 Final Resolution               Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN Appendix B of NRC RG 1.200, Rev. 1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-03  HR-2          B            Y      The BV PRA uses the SLIM                While it is true that the FLI is a    No impact to Fire methodology to quantify the post        linear combination of the PSF         PRA, because this initiator human actions. The HRA        rankings and weightings product,      issue was quantification currently in use was     the actual HER is logarithmic as      addressed in the completed for the IPE and has not       discussed in Section 2.1 of the       base PRA model been updated. The SLIM method can       HRA notebook. Additionally, as        prior to building the only combine the PSFs linearly to       shown in Table B-4 "Beaver            Fire PRA.
develop the overall FLI for each        Valley Unit 1 - Group 2 Human action. Current industry practice       Actions Evaluation" between contends that PSFs can have             ZHEMU1 and ZHEMU2, where significant non-linearities. For        the only major difference is in the example if a particular action is rated timing rankings, there is a poorly for a given PSF and moderately   significant difference in the HER in all the others, middle of the road   values.
HEPs tend to result even though poor performance in only one PSF may be      This PRA Peer Review indicative of poor human reliability    observation was dispositioned irrespective of what is going on with   by, the resolution of F&O HR-07 the other PSFs. Mosleh of University    above, where it was shown that of Maryland has addressed this issue    the current human error rates in a refinement of the FLIM method      used in the PRA model are (which allows assignment of             acceptable as is, and by importance to PSFs) in an update of     acknowledging the PRA Peer          I Page 19 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution         Impact to Fire ID     Requirement 1 Level        Closed                                                                         PRA YIN the Calvert Cliffs PRA. The BV PRA      Review Team comment on its uses linear compilation of PSFs. The    significance on CDF. Moreover, ability to use non-linear compilations, as a final resolution to this if desired would be an enhancement. observation, future BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology to identify human action dependencies.
This F&O was written against an obsolete HRA PRA model (BV1 REV3) and is considered to be resolved by the updated HRA PRA model incorporated in BV1 REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
Page 20 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact &Observation                       BVPS-1 Final Resolution            Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA Y/N HR-09  HR-03         B            Y      There is not enough detail in the HRA   This CA is being (was) rolled into No impact to Fire to reproduce the results. The following CA 02-09046-29 to track its        PRA, because this information was not available and       resolution.                        issue was does not appear to have been                                               addressed in the retained:                               This F&O was written against an    base PRA model obsolete HRA PRA model             prior to building the a) the time lines                       (BVI REV3) and is considered to    Fire PRA.
be resolved by the updated HRA b) discussion of the events chosen for  PRA model incorporated in "calibration" from the other PRA's and  BV1 REV4, which underwent a the reason why they are applicable,     focused Peer Review in accordance with the guidance in c) the basis for choosing 10            Appendix B of NRC RG 1.200, categories of HEP and the basis for     Rev.1, conducted during the assigning each BV HEP to a category     week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
Page 21 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O       Supporting. Significance     Status   Fact & Observation                           BVPS-1 Final Resolution            Impact to Fire ID        Requirement 1   Level            Closed                                                                                   PRA YIN HR-13     HR-19           B                Y        Some discrepancies in the timing             CAs 02-09045-18, -19, -20, 02-     No impact to Fire were observed in the PRA.                    05632-01, and 03-07552-06 are      PRA, because this All the timing calculations were based       all associated with re-evaluating  issue was on hand calculations. Although the           operator actions for Revision 4 of addressed in the times seemed reasonable compared             the BVPS-1 PRA model using         base PRA model to other PRAs, there were some               the EPRI HRA Calculator.           prior to building the observations.                                                                   Fire PRA.
This F&O was written against an
: 1) There was a calculation done for          obsolete HRA PRA model steam generator dryout, which                (BV1 REV3) and is considered to assumed all the water would be               be resolved by the updated HRA exhausted from the SG by 1.1 hours.          PRA model incorporated in Using 1.1 hours overestimates the            BV1 REV4, which underwent a time available to do F&B or restore          focused Peer Review in AFW. Effectiveness of decay heat             accordance with the guidance in removal will decrease way before all         Appendix B of NRC RG 1.200, the water is gone in the SG.                 Rev. 1, conducted during the week of October 29, 2007, by
: 2) ZHECC1 - start standby CCP                Westinghouse. The F&Os as a provides a time of 30 minutes, based         result from this focused Peer on seal failure after loss of seal           Review, as well as their cooling. But, after loss of CCW, the         resolutions are presented in RCP must be tripped with in 5-10             Table 1-3.
minutes to avoid catastrophic seal failure. The 30 minutes for seal failure after loss of cooling does not apply.
This scenario is for bearing failure after loss of CCW. The timing should be consistent.
: 3) ZHEIC1 and ZHEIC2 show 70 and 30 minutes based on seal failure after
      .1.               .1______________ 1        1 loss of seal coolina. The time should    .1.
Page 22 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution Impact to Fire ID     Requirement 1 Level        Closed                                                                 PRA YIN be consistent and should consider if the Loss of CCW to the RCP bearing must be considered.
: 4) ZHEMU1 - timing for MU indicates the operator has 1.6 hours to act, based on the time it takes to drain the RWST from minimum level "empty".
The number should be coordinated with the boron dilution calculation, which assumes boron dilution times from a RWST level of 140,000 or 360,000 gallons. time allowed for operator diagnosis on the front end must be subtracted from time allowed
: 5) ZHEOB1 provides 78 minutes for feed and bleed, based on the time for a PORV to lift after loss of AFW.
There is no analysis for this. In most PWR, F&B must be started prior to the time the PORV lifts. Start time for F&B should be based on MAAP analysis.
: 6) ZHEOCl - states there are 30 minutes to trip RCP after loss of seal cooling. The other parts of the PRA state 5 or 10 minutes. 30 min is a seal failure number, not a bearing failure number. ZHEOCl be based on 5 minutes.
: 7) ZHEOS6 - timina states 1.3 hour Page 23 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution          Impact to Fire ID      Requirement 1 Level        Closed                                                                            PRA YIN available to start AFW. 1.3 hours is the time from reactor trip to core uncovery. AFW must be started before 1.3 hours. Also, ifthere is 1.3 hours allotted to start AFW, then there is no time for MFW restoration and F&B. The time from reactor trip to core damage must be apportioned to the 3 actions in this sequence.
: 8) ZHEWA5- 30 minutes to align diesel driven SW pump after LOSP.
This time is based on seal failure due to loss of SW. The DG will fail in 8 minutes ifthere is no SW. The time to align Diesel driven pump is based on failure of the DG, which is 8 minutes.
IE-04   IE-16         B            Y      Subtier criteria requires that "The       For Unit 1, full power operation No impact to Fire initiating event frequency should not     began on May 1977. The Unit 1    PRA, because this use data from the initial year of         PRA model initiating event data  issue was commercial operation." Contrary to        collection started on Jan. 1,    determined to have this data from 1987 (Beaver Valley        1980. Therefore, no revision of  no effect on the initial year of operation) is included in data is needed based on this     BVPS PRA model.
the data update. Use of this data,        observation.
though conservative, could shift the importance of components.
Page 24 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution        Impact to Fire ID      Requirement' Level        Closed                                                                           PRA YIN IE-05   IE-13        B            Y      In appendix D of the initiating event      The interfacing system's LOCA  No impact to Fire notebook, the interfacing systems          (ISLOCA) initiating event      PRA, because this LOCA frequency is calculated               frequency was recalculated     issue was referring to two references from 1985. based on NUREG/CR-3862,        addressed in the The 2 landmark ISLOCA reports              NUREG/CR-5102, NUREG/CR-       base PRA model (NUREG/CR-5102 and NSAC-152)               5603, and NSAC-152. The new    prior to building the were written in 1992. Although the         value used in the BV1 REV3 PRA Fire PRA.
frequency calculated in the Beaver         model, with a Monte Carlo Valley PRA does not seem out of the        quantification is 1.07E-05 recognized range of values for this        events/yr.
frequency, due to the importance of this event for LERF, the compatibility of the method and data used in the PRA should be checked against the later references.
Other inconsistencies in the analysis are:
OST 2.11.16 is performed prior to startup, if it has not been performed in the previous 9 months. The PRA assumes there are 3 shutdowns per year (which is not supported by the historical performance of BV), so assigns a test frequency of 3 months.
The maximum possible test interval for OST 2.11.16 is 26 months [plant ascends to power 8 months from last test for an 18 month run]. The minimum is 9 months. The true average test interval is likely in the 13-20 month ranae. Substitutina this test Page 25 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution Impact to Fire ID     Requirement 1 Level        Closed                                                                     PRA YIN interval into the equation would have a significant affect on frequency.
The probability of MOV 8889 being inadvertently open is not considered.
The LHSI lines are interconnected such that if CV 552 and 109 fail, both 132 and 133 will be challenged. This is true for the other injection lines also.
So the valve combination is 3 times higher than shown.
The probability of pipe over pressure is assumed to be the same as pipe rupture. This is not consistent with the two 1992 references listed above.
Page 26 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                         BVPS-1 Final Resolution             Impact to Fire ID      Requirement 1 Level        Closed                                                                               PRA YIN IE-08   IE-13         B            Y      Bayesian updating is used extensively     Regarding Bayesian Update with      No impact to Fire in data analysis and also in initiating   0 failures, there are indeed        PRA, because this event frequency calculations.             situations that updating with 0     issue was Although mathematically correct, the      failures could cause the posterior  determined to have use of Bayesian updating without          mean to be significantly lower      no effect on the some limitations has been criticized,     than the prior mean. A known        BVPS PRA model.
with justification, in the past. Under    situation is the case of using certain conditions, bayesian updating     moment matching. This refers to with zero or 1 failures may reduce a      the practice of changing a prior prior mean (with a high error factor)     that is presumably a lognormal considerably. Since PRA results and       distribution, to a gamma applications depend on, and are           distribution by matching the measured mainly by point estimate         mean and the standard deviation.
(mean) results, but not by uncertainty    After the Gamma distribution is bounds, any evidence that shifts the      updated with plant data mean considerably must be rigorously      analytically, the resulting gamma justified.                                distribution is convert back to the lognormal distribution again The BV PRA uses bayesian analysis         using the moment matching for virtually all transient initiating    method. It is known that in this events. In most cases, the plant          practice, if there should be 0 specific data is 0 trips in 11 years. In  failures, the resulting posterior general the posterior is lower than the   gamma distribution has a mean prior. If the plant specific data was    value significantly lower than the used by itself, the is enough data to     prior mean.
justify a point estimate of about .05/yr.
The prior for LOSP is .027. The prior     The BVPS analysis did not use for SGTR is .0074. The posterior for      the moment matching. Instead, LOSP is .025 and for SGTR .0048. In      the Bayesian update functionality both these cases, the posterior is        provided by RISKMAN was used.
lower than the prior and lower than the  There are two classes of priors plant specific data can justify. This is  used in the BVPS analysis. The due to the use of Bayesian analysis      first class are the lognormal Page 27 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                     BVPS-1 Final Resolution             Impact to Fire ID     Requirement1 Level        Closed                                                                           PRA YIN when too little plant specific data   distribution based on parameters exists.                               from the NUREG study (for LOCA initiators, for example).
Rules for when to use Bayesian        Updating a lognormal distribution analysis and when to use generic data with 0 events in about 10 years should be developed to ensure that    does not change the mean in failure rates and initiating event    most cases (or there is a slight frequencies are not reduced below     change in the third significant both the generic values and the plant number).
specific estimates.
A more general type of priors is the industry data. The prior consists of three parts. The first and most important part is the failure and success data for a set of PWR power plants. The second part is the so-called grid, which consists of a set of values for the median (of the assumed prior curve), and a set of values for the range factor (of the assumed prior curve). The selection of median and range factor should be such that the resulting distribution should not skewed toward either end of the median or range factor in the grid (grid is the matrix of median and range factor values). The third part of a prior is the so-called lambdas, which is a set of values for the possible bin values that the distribution can locate. The Page 28 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation          BVPS-1 Final Resolution               Impact to Fire ID    Requirement 1 Level        Closed                                                                   PRA YIN lambdas do not affect the posterior mean distribution as long as has sufficient range and sufficient number of values (typically 20 bins are sufficient for a distribution). It should be pointed out that for the industrial data type of prior, updating it with zero failures typically results in a smaller mean value for the posterior then the prior.
However, the decrease is much smaller in magnitude than the moment matching approach, and it should be treated as a normal behavior of the Bayesian analysis (i.e., zero failures always provide information leading to a lower estimate).
In response to this observation, each posterior distribution that was Bayesian updated with zero failures was reexamined to assure that there was no skewing of results on the grid, and that there were no abnormally large values (excessive probabilities) in a single lambda bin. In some cases a few more lambdas were added to actually bring the probability per each lambda lower than 0.1. However, in Page 29 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution             Impact to Fire ID     Requirement' Level        Closed                                                                             PRA YIN these cases the posterior distribution changed little compared to the original set of lambdas (note, the grid was not changed in this response because these were checked in the original analysis and quality was assured). The results of the review did not identify any concerns, so confidence in the Bayesian update results using zero failures based on the discrete probabilistic distribution approach, which is a robust process, was maintained.
Based on the above discussion, no revision of the Unit 1 data are necessary in response to this observation.
L2-03  L2-18        B            Y      All early SGTR core damage              The BV1 REV3 PRA model              No impact to Fire sequences with wet SGs are classified   assumes that all steam generator    PRA, because this as SERF (small early release            tube ruptures that are faulted and  issue was frequency) vs. LERF without regard to   have a depleted RWST or have a      addressed in the break location or other sequence        loss of all secondary cooling are   base PRA model specific conditions such as SG          considered to be LERF               prior to building the isolation, primary to secondary         contributors, even if the tubes are Fire PRA.
pressure equalization, etc. The basis   wetted (i.e., no credit for for the use of small release was        scrubbing going to SERF instead scrubbing; however, there is no         of LERF). It is assumed that documentation supporting this            leakage from the RCS will classification. For example, failure to continue indefinitely through the cooldown and depressurize the RCS       faulted steam generator and the Page 30 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution            Impact to Fire ID     Requirement 1 Level        Closed                                                                             PRA YIN may result in lifting the ruptured SG    core will uncover after the RWST ASDVs or safety valves,                  depletes. This LERF definition is Radionuclides, both volatile and non-    in agreement with WCAP-1 5955, volatile, entrained in the escaping      "Steam Generator Tube Rupture steam result in a release to the         PSA Notebook".
environment. Without evaluation, the magnitude of the release to the          Subsequently after closing this environment is unknown, and may be       F&O, the ASME Standard sufficient to meet LERF classification,  recognizes scrubbing during SGTRs as a way to reduce LERF. Ultimately resolved by GAP F&O LE-CI0-01 (see Table 1-2).
MU-02  MU-06         B            Y      The computer models of the PRA           IT has placed restrictions to the  No impact to Fire (electronic files for the input and      "S:/AII/PRA Engineering"           PRA, because this output of the PRA model and its          directory. The permissions for     issue was sensitivity analyses) should be stored   this directory are limited to      addressed for the in a controlled manner. The subtier      specific design Engineering        base PRA model criteria states that "a secure offsite   personnel. This will prevent       prior to building the storage facility for computer codes,     unauthorized personnel from        Fire PRA.
inputs, outputs, and models should be    accessing PRA reports and used".                                   models. Inaddition, the network is backed up daily, making Discussions with the BV PRA staff        retrieval of lost files very easy.
indicate that the PRA model files are kept on CDs and also on a network drive (not a protected drive).
To meet the intent of the subtier criteria, the model files should be also stored with the same philosophy as the paper copies of calculation notes; namely stored by a dedicated Page 31 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review             - Facts and Observations Resolutions F&O    Supporting. 1Significance Status Fact & Observation                      BVPS-1 Final Resolution   Impact to Fire ID     Requirement1 Level        Closed                                                                   PRA YIN organization (preferably outside of the PRA group), in a protected manner and be available for long term retrieval.
Page 32 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. 1 Significance Status Fact & Observation                       BVPS-1 Final Resolution           Impact to Fire ID     Requirement   Level        Closed                                                                            PRA YIN QU-02  QU-08         B            Y      The original top ten sequences were      The BV1 REV3 PRA model now        No impact to Fire for total CDF and not just internal. Of  includes Top Event CG (LEVEL 1    PRA, because this these three were control building fire,  OR LEVEL 2 SEQUENCE               issue was one seismic, and four external. The      GROUP), in the Containment        addressed in the number 1 was ELOCA and number 2          Event Trees (CET & CETLOCA).      base PRA model was ISLOCA, both which were the          This Top Event bypasses the       prior to building the initiating event which leads to          Level 2 Top Events when it is set Fire PRA.
guaranteed failure. The remaining four   to a guaranteed failure, and will were internal sequences which meant      query the Level 2 Top Events something. The number five sequence      when it is set to a guaranteed was loss of AC bus "Purple" with         success. To quantify only the other failures that lead to core         Level 1 CDF, the Split Fraction damage. Sequences 7 and 8 were           logic rule for CG1 (1.0) uses the LOIA with loss of heat removal (high     NOT NOMELT (-NOMELT) and dry). The number 10 sequence         macro. Therefore, all core melt was ATWT (on a turbine trip) with the    sequences bypass the Level 2 failure of the operator to manually trip Top Events, and the resultant the reactor, with all subsequent         sequences have the Level 2 Spilt operator actions guaranteed failure. Fractions suppressed. When the Since this had limited internal          Level 2 Top Events need to be sequences, a larger report was           quantified for LERF, the Split reviewed with the objective to see      Fraction logic rule for CG1 (1.0) what SBO looked like. The SBO was        is changed to SS=F*SS=S, which not on this and in fact the first LOSP  can never be true, so the was very low on the list. Then a         guaranteed success Split sequence report was reviewed looking     Fraction CG2 (0.0) is used and at LOSP only. Sequence #57 was the      the Level 2 Top Events get first SBO sequence and #58 was the       queried and retained in the second SBO sequence. The only           sequences.
difference between these was in the containment tree. With this is was realized that the containment tree was splitting up ("fractionalizing") the Page 33 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                     BVPS-1 Final Resolution Impact to Fire ID     Requirement Level        Closed                                                                  PRA YIN LOSP sequences, as opposed to some other sequences (such as ELOCA) which had one path through the containment tree. It was now realized that in order to analyze the sequences in the same context as previously, there needed to be a run of the event trees where the extra details of the containment tree suppressed. The utility staff ran this and the results and insights were noticeably different than before.
The results of the top ten were significantly different. The ELOCA and VSLOCA stayed the same value but now are sequences 2 and 4 respectively. The number 1 sequence is now loss of instrument air. ATWT on PLMFWA is number three (while the previous ATWT went to 12). Two sequences are control building I flooding.
Page 34 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                     BVPS-1 Final Resolution               Impact to Fire ID     Requirement' Level        Closed                                                                              PRA YIN QU-03  QU-08        B            Y      In ATWT, if the operators fail to trip In response to this observation,      No impact to Fire the reactor as an immediate action     the BV1 REV3 PRA model was            PRA, because this (top event OT) then subsequent         revised to incorporate giving         issue was operator actions RI and OA are failed. credit for the longer term            addressed in the I suspect that this sequence has       operator action to emergency          base PRA model always been this way in the past, but  borate, even though the earlier       prior to building the with the recent enhancements in the    actions to manually trip the          Fire PRA.
model, the sequence has risen into     reactor or to insert the control the top ten. This leads to an overly   rods may have failed.
conservative results in CDF. This appears to be the number 6 in internal The BV1 REV3 PRA model was
(#10 sequence in total CDF). Of the    revised by removing the top 50 sequences, 20% are ATWS.        emergency boration (Top Event The total CDF for ATWS is a            OA) human action dependency noticeable part of the CDF, and would  on prior ATWS human actions, not support any future RI ATWS         which must be performed applications.                          immediately; i.e., manual reactor trip (Top Event OT) and manual rod insertion (Top Event RI).
This involved editing the ATWS event tree split fraction logic rules for OAF by removing OT=F +
RI=F, as shown in Table 3.5-3 "ATWS Event Tree Logic Rules" of the Event Tree Analysis Notebook.
The basis for this change was derived from WCAP -15831-P Section 5.1.1.12, where it is assumed that the operator action to emergency borate is independent of the previous Page 35 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                     BVPS-1 Final Resolution           Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA YIN operator actions since itdoes not need to be completed in the same short time period as the operator actions to trip the reactor, or manually drive in the control rods.
QU-04 AS-12          B            Y        An asymmetry discussion is provided    Asymmetries in a PRA model can    No impact to Fire in the PRA Quantification Notebook,    occur in the system fault trees,  PRA, because this section A.3. The write-up includes     maintenance alignments, or in     issue was general discussion regarding the use   the event tree modeling. All      addressed inthe of alignments to simulate the various  specific system asymmetries due   base PRA model modeling asymmetries in the systems    to plant differences are          prior to building the modeling and the effect on event trees addressed in the system fault     Fire PRA.
by partitioning some of the initiating trees. A system example is the event categories with some examples    River Water system, where only being provided. Some of these          the Aheader can supply an asymmetries are due to modeling        emergency source of water to the assumptions and some are due to        Auxiliary Feedwater system.
actual plant differences. No specific  Specific system asymmetries due discussion is provided to explain what to plant NSA differences are I system asymmetries are due to simple   addressed in the maintenance Page 36 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status Fact & Observation                 BVPS-1 Final Resolution             Impact to Fire ID     Requirement' Level          Closed                                                                        PRA I YIN modeling assumptions and which     alignment module of RISKMAN.
ones are due to plant differences. An example of this is the auxiliary feedwater system, in which the turbine driven AFW pump is normally aligned to the A header.
Actual plant data from the Maintenance Rule for train unavailabilities have been utilized when possible to account for maintenance alignment asymmetries. Whenever no specific plant data was available it was assumed that the train alignments were symmetrical.
An example of this is with the Reactor Plant Component Cooling Water system, where each pump is equally assumed to be the running pump. The only exception to this was in the River Water system maintenance alignments, where due to the limitation on RISKMAN it was assumed that the A pump was always the running pump. These differences between the trains are addressed in the BV1 REV3 PRA model top events and by the split fraction rules in the event trees.
In the event trees, potential issues with asymmetries Page 37 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                                PRA YIN associated with initiating events have been removed by partitioning some of the initiating event categories. Examples of initiating events partitioned are Large LOCAs, which now models a break in each specific loop (initiating events LLOCAA, LLOCAB, and LLOCAC) using the same probability.
QU-07  QU-15         B            Y      A review of the non-dominant               The specific sequences listed in    No impact to Fire sequences was made. The non-               the issue description only apply    PRA, because this dominant sequences are those that          to the Unit 2 BV2REV3A PRA          issue was are not normally saved when the            model. To ensure that the Unit 1    addressed in the entire model is run. It was necessary      sequences are valid, the            base PRA model to quantify one initiator at a time to get BV1 REV3 PRA model was              prior to building the the cutsets below 4E-1 0. A review of      quantified using only the Level 1   Fire PRA.
these cutsets had the following            Top Events so that a review of observations:                              the CDF sequences could be performed to verify that the split
: 1) SGTR 1.507E-12: IAF
* OD16B -           fraction logic rules made sense.
how is OD possible when IA is failed?      This included looking at non-dominate sequences 5 orders of
: 2) TTrip 7.26E-1 1:                        magnitude lower than the total AFI*OF1*OB4*CDF*RRI - ifAF, OF,            CDF value.
OB and CD are failed, how can RR be asked in a probabilistic manner. RR should be RRF.
: 3) TTrip 3.233E-1 1:
SAI *OS6*AF3A*OFF*OBF*CDF*RR1
                                         - How can RR be asked in a probabilistic fashion after failure of all Page 38 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution               Impact to Fire ID     Requirement' Level        Closed                                                                                  PRA Y/N that?
: 4) TTrip 8.34E-12 AF1*MFF*OBI*CDF*RR1 - same question about RR?
: 5) TTrip 1.1649E-12:
PR7*HH2A*OR3A*MU2: If HH2A is failed, how can MU2 succeed? Does not MU2 use the HHSI pumps?
: 6) TLMFW 1.2559E-12:
AF1*OF1*OB1*HH1: Why is OF1 in the tree for Loss MFW? Why is OB1 in the same sequence as HH1. If OB1 fails, there is no initiation of HHSI, so why is HH1 included?
QU-09  QU-31        B            Y      This element asks whether the              As a resolution to this PRA Peer      No impact to Fire sequence results by sequence,               Review observation a ballpark        PRA, because this sequence types, and total was               comparison was made utilizing        issue was reviewed and compared to similar            the WOG PSA Model and                addressed in the plants to assure reasonableness and         Results Comparison Database,         base PRA model identify any exceptions. A review of        Revision 3. Items compared           prior to building the the PRA documentation did not reveal        included; initiating event           Fire PRA.
a comparison of the current PRA             frequencies and their conditional revision results to results of similar      CDF, component failure rates, plants.                                     human error rates, and success criteria. While, this review was not detailed no outliers were identified, and the conditional CDF from LOSP initiators was comparable with North Anna, a I nearly identical plant. During the I Page 39 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution         Impact to Fire ID     Requirement' Level        Closed                                                                            PRA YIN next PRA model update a more thorough comparison will be made utilizing the most recent WOG PSA Model and Results Comparison Database, and the findings documented.
Ultimately resolved by GAP F&O F&O IE-C10-01 (see Table 1-2).
QU-10 QU-30        B            Y      The initiating event frequency for         This PRA Peer Review Fact &     No impact to Fire interfacing system LOCA (i.e., initiator   Observation was written against PRA, because this VSX) was quantified using point            the Unit 2 BV2REV3A PRA         issue was estimates (result of 2.2E-7) and using     model. For Unit 1, the BVI REV3 addressed in the Riskman's Monte Carlo algorithm            PRA model recalculated the      base PRA model (result 3.OE-7). The difference is         interfacing system's LOCA       prior to building the explainable based on data                  (ISLOCA) initiating event       Fire PRA.
dependence between valve failures.         frequency based on NUREG/CR-3862, NUREG/CR-5102, But the event tree quantification used     NUREG/CR-5603, and NSAC-the lower, point estimate result. The       152. The new initiating event 3.0E-7 Monte Carlo result should be        frequency value used in the used in the quantification.                BV1REV3 PRA model is 1.07E-05 events/yr, which was performed using a Monte Carlo I quantification.
Page 40 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution           Impact to Fire ID     Requirement' Level        Closed                                                                               PRA IYN    I ST-02  ST-1 0       B            Y        The internal flooding analysis was        In response to this observation,  No impact on the done for the IPE and has not been         the work that was completed for   submitted BVPS-1 updated since then. All flood barriers    the Beaver Valley Unit 1 Risk-    Fire PRA, which were treated deterministically and        Informed In-Service Inspection    used the assumed to succeed. The sub-criteria      (RI-ISI) Indirect (Spatial)       BV1 REV5 as its for this element suggests that flood      Consequence Evaluation (8700-     basis. Internal fire propagation pathways should include       DMC-1 333, Rev. 0), as well as,   initiators and flood failure of doors, floor drains, and other several updated flooding          initiators are flood barriers.                           analyses performed after the IPE  mutually exclusive submittal were reviewed. The      and have no effect results of this review determined on each other.
that the flooding analyses did consider the potential of flood   Furthermore, the barrier failures due to the flood BVPS-1 Fire PRA water static head on the door     working model latching mechanisms and           uses BV1 REV5A likelihood that floor drains were as its basis, so this inadequate. Itwas concluded       F&O will be that the IPE flooding analysis    resolved when assumptions regarding the         NFPA 805 is propagation of floodwaters did    implemented.
consider flood barrier failures, and therefore, they remain valid.
No further flooding impacts were incorporated into the BV1REV3 PRA..
This F&O was written against an obsolete Internal Flooding PRA model (BV1 REV3) and is considered to be resolved by the updated Internal Flooding PRA model incorporated in Page 41 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                Impact to Fire ID     Requirement Level        Closed                                                                                 PRA YIN BV1 REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-4.
SY-01  SY-12       B            Y      Loss CCP/CCR results in a loss of        With multiple high temperature         No impact to Fire seal water heat exchanger cooling        alarms coming in at more than          PRA, because this (discharges directly to the charging     100 OF prior to reaching this          issue was pump suction) as well as loss of non-    temperature, there would be            determined to have Regenerative heat exchanger cooling      plenty of time available to            no effect on the (discharges to the VCT). The result is   operators to perform mitigating        BVPS PRA model.
a potential common mode failure of all   actions. Moreover, a loss of charging pumps due to an increasing      NPSH would only impact the charging pump inlet temperature,         running charging pump, since the coupled with the loss of CCP/CCR,        standby pump does not this results in an RCP seal LOCA.        automatically start, unless a Riskman macro RWSTSO (VCT                Safety Injection Signal is present, swap-over to RWST) contains logic to     in which case the suction would include the failure of the components    automatically swap over to the required to perform this action, but the RWST. The third pump would operator action is not included. Given   only be manually aligned and the uncertainty of the time to charging  started following the failure of the pump failure, the operator action may    first two normally aligned pumps.
dominate the mechanical component        Therefore, this observation was failures.                                not considered to be a valid common cause failure mechanism of the charging/HHSI pumps, so the operator action        I Page 42 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution                Impact to Fire ID     Requirement 1 Level        Closed                                                                                   PRA Y/N was not included in the BV1 REV3 PRA model.
SY-02  SY-3          B            Y      The degree of documentation in the         Split fraction definitions were        No impact to Fire systems analysis should provide            developed by using the                 PRA, because this enough detail that the systems             dependency matrices located in         issue was analysis can be duplicated with            Appendix B of the Level 1 Event        addressed in the minimal effort. A review of the            Tree Analysis PRA Notebook.            base PRA model Auxiliary Feedwater System Notebook        Split fractions and truth tables for prior to building the (Book 2, Tab 2) and the Main               Top Events AG, AL, AM, HC, HH, Fire PRA.
Feedwater System (Book 3, Tab 6)           HL, HM, HR, LA, LB, LC, LL, LM, revealed that the Split Fraction           LO, LP, LQ, OP, OR, VA, VB, definition / truth tables are not          VC, VL and XL are found in the documented and the Common Cause            Split Fraction sections of the assumptions are not documented.            RISKMAN System Notebook files There is no discussion as to where         in Appendix C. Common cause these assumptions came from or the         failure inputs, assessment definition of the split fractions utilized methodology and data update          I Page 43 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                       BVPS-1 Final Resolution                Impact to Fire ID     Requirement' Level        Closed                                                                                   PRA YIN in the Systems Analysis. The             summaries are located in absence of this information could        Appendix C of the Data Analysis result in the inability to reproduce the Notebook. Top Events AG, AL, Systems Analysis for verification of     AM, HC, HH, HL, HM, HR, LC, results or future applications.          LL, LM, LO, LP, LQ, OR, VA, VB, VC, VL and XL Common Cause failures are found in the common cause sections of the RISKMAN System Notebook files in Appendix C.
SY-03  SY-1 5       B            Y        Some initiator dependent component       The LHSI mini-flow valves MOV-         No impact to Fire failure modes do not appear to be        1 SI-885AIB/C/D are NSA open at PRA, because this modeled. For example, the S18890         Unit 1, so a failure to open is not    issue was MOVs are included in the model for       applicable to the PRA model.           determined to have fail to open to prevent LHSI pump        The MOV transfer closed failures       no effect on the overheating during low flow              are included in the LA/LB Top          BVPS PRA model.
conditions. For this specific example,   Events. This is a slightly large LOCAs should only consider         conservative assumption for the transfer open as a flow diversion;       large LOCA, when the RCS failure to open is not applicable. For   pressure is low and mini-flow is small LOCAs, the failure to open is      not required, but is not a correctly modeled, but transfer closed   significant contributor to the should also be included. For medium      failure probability. Also, a failure LOCAs, the need to open or close the     to close is not considered to be a S18890's may require additional          valid flow diversion path for large thermal hydraulic analyses. Other        LOCAs since the 3" mini-flow system designs susceptible to initiator  lines are less than 1/3 of the specific failure modes include systems   diameter of the 10" injection with pumps which have mini-flow          lines. These valves are required which return to the pump's suction.      to close on SI recirculation, which Systems like this may require operator   is included in Top Events VANB.
action to stop these pumps if            It is concluded that the LHSI I downstream pressure prevents             mini-flow valves are properly        I Page 44 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact &Observation                       BVPS-1 Final Resolution             Impact to Fire ID     Requirement' Level        Closed                                                                             PRA YIN adequate flow to prevent pump           modeled in the BV1 REV3 PRA overheating,                            model.
The AFW mini-flow recirculation valves are controlled in auto and do not require any operator actions to open or close; therefore, this is not an issue for the Unit 1 AFW system.
SY-06  SY-6         B            Y      Assumptions concerning non-modeled      The failures of non-modeled         No impact to Fire failure modes, or support systems due   support systems are accounted       PRA, because this to low frequency sequences need to      for in the initiating event         issue was be reconsidered with respect to         frequencies. Also, as was           addressed in the specific applications. For example,     originally assumed in the           base PRA model condenser hotwell level is assumed to   previous PRA models, these          prior to building the always be adequate due to               supporting systems for Support      Fire PRA.
redundancy of sources (i.e., via steam  Systems are considered dumps, or makeup); however, some of     available for mitigating system these sources may not be available      functions (e.g., condenser is during online T/M.                      available to support the MFW system) following the initiating Also many of these done when the        event. Additionally, even though CDF was in the 2E-4 range. Now that the CDF has reduced through the CDF is in 8E-6 range many of these      years, the individual system items may no longer be insignificant in function probabilities have not the current model.                      generally changed much.
Guidance was also added to the System Analysis and Overview Notebook to include assumptions concerning non-modeled failure modes, or support systems.
Page 45 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                       BVPS-1 Final Resolution             Impact to Fire ID      Requirement 1 Level        Closed                                                                             PRA YIN SY-16   SY-13         B            Y      The sequence modeling credits           Using the BVPS-1 Cycle 16 BOL       No impact to Fire RWST refill for LOCA's and SGTR.        boron requirement of 1195 ppm       PRA, because this The RAW worths of the split fractions   for shutdown (k=0.99) with all      issue was indicate that without RWST, CDF         rods in and hot zero power from     addressed in the would be 3.8E-5. RWST refill is         WCAP-15995, Rev.1 as the            base PRA model modeled in split fractions WM and       minimum required boron              prior to building the MU.                                     concentration, the expected         Fire PRA.
RWST boron concentration after The minimum make up rate is 150         24 hours of dilution would be gpm. The actual makeup rate [if this    1208 ppm. This value assumes procedure was used] may be up to        that 400 gpm of river water is 400 gpm. The initial water source for   delivered to the spent fuel pool RWST refill is the boric acid blenders. during the first 5 hours following This system has a 7,000 gallon tank at  RWST depletion, with 120 gpm 7,000 ppm boron. This system does       makeup for the remaining hours, not have sufficient volume nor flow     as identified in the MAAP rate to match the times and volumes     success criteria calculation needed for safe shutdown in the         (FAI/03-18) for required RWST sequences modeled. The ultimate         makeup rates using the spent source of water is unborated river      fuel pool during LOCAs.
water. To provide enough input to the   Therefore, makeup to the RWST RWST, the flow path is into the Fuel    via the spent fuel pool, with river Pool and then from the fuel pool to the water makeup to the spent fuel RWST.                                    pool is considered to be successful, since minimum The Miscellaneous Notebook              shutdown boron requirements documentation states "The current       will take longer than 24 hours to BV2REV3A PRA model assumes that         achieve.
400 gpm is required for makeup to the RWST during the entire mission time."   A precaution was also added to Boron dilution of the fuel pool is       BVPS-1 OM Procedure 1OM-calculated, but not boron dilution of    7.4.Q "Makeup To The Refueling the core. The observation is that if    Water Storacje Tank," that if a Page 46 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                     BVPS-1 Final Resolution             Impact to Fire ID     Requirement' Level        Closed                                                                            PRA I
_YN unborated water was used to make-up    significant volume of river water for the times required, boron dilution is added to the Spent Fuel Pool, could occur in the core, thus negating boric acid addition to the Spent the RWST make up function. Due to      Fuel Pool may be required to the fact that RWST cause significant   maintain adequate shutdown core damage reduction, the ability to  margin.
use RWST make-up should have a more substantial analytical basis.
This observation is worse for unit 2 than unit 1, because of the smaller RWST volume. The minimum core boron concentration for hot zero power at BOL is 771 ppm. For most of the sequences where RWST make-up is used, the reactor is assumed to be depressurized and cooled down
[LOCA's and SGTR]. For the purpose of this F&O, it is assumed necessary to maintain a 1500 ppm boron concentration. The RWST switchover is 140,000 gallons for unit 1 and 360,000 gallons for unit 2. Times to boron dilution (in the RWST) is shown below:
Unit 1 dilution  to 771 ppm at 150 gpm
                                        = 15h Unit 1 dilution  to 771 ppm at 400 gpm
                                        = 5h Unit 1 dilution to 1500 ppm at 150 gpm = 4.5h Unit 1 dilution  to 1500 ppm at 400 Page 47 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA YIN gpm = 1.7h Unit 2 dilution to 771 ppm at 150 gpm
                                         = 38 h Unit 2 dilution to 771 ppm at 400 gpm
                                         = 14h Unit 2 dilution to 1500 ppm at 150 gpm = 11.5h Unit 2 dilution to 1500 ppm at 400 gpm = 4.3h Only one of these conditions can meet a 24 hour mission time.
Considering that RWST make-up is used to lower CDF and LERF to the extent it does, the technical basis should be stronger. The calculation must match the conditions of the sequences for which it is used, must use a representative flow rate, and must consider the uncertainties in the inputs and the outcome.
SY-17  SY-21         B            Y      Service Water success criteria           This concern is not applicable to   No impact to Fire appears to have no supporting            the Unit 1 River Water System.      PRA, because this analysis as to 1 service water cooling   BVPS-1 UFSAR Section 9.9.2          issue was pump could provide sufficient flow.      specially described that each       determined to have Additionally, there appears to be some   river water pump is able to         no effect on the HEP for some manual operator action      deliver approximately 9,000 gpm     BVPS PRA model.
to start standby pumps under some        and is designed to supply the circumstances. No success criteria for   quantity of water needed for the the time available for these actions     essential safety-related cooling was found.                               requirements for all unit I operating conditions.             I Page 48 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution              Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA YIN TH-02  TH-8          B            Y      The Beaver Valley Unit 2 Ventilation    Calculation 8700-DMC-3467,           No impact to Fire and Room Cooling Analysis Notebook      Rev. 1, was developed to show        PRA, because this Table 7 lists that for item 10, Control the heatup of the common             issue was Building, Operators add portable fans;  control room following a loss of     addressed in the not included in risk model. It appears  BVl HVAC due to a fire. The          base PRA model from Figure A-9 "Temperature as a       results of this calculation are also prior to building the Function of Time in Control Room with   applicable for the PRA evaluation    Fire PRA.
No Ventilation-Fan Added in 10          of a loss of all control room Minutes," that without the addition of  cooling, and are provided below.
the fans the temperature in the Main Control Room would impact               It takes longer than 24 hours to instrument qualification. Though this   reach a room ambient appears to be an important operator     temperature of 115*F, using an action that justified not adding MCR    initial room temperature of 75*F, HVAC to the model, there is no          calculated heat loads, and taking operator action to add fans for MCR     credit for the Unit 2's HVAC. This cooling within 10 minutes.              conclusion is based on the assumption that a homogenous Additional investigation into the MCR   mixture of air exists between the heatup calculation 12241-US(B)-211      control room volumes. In order revealed that two different values      to keep this assumption valid, the were used for the MCR heat load.        operators must immediately Page C-4 uses a MCR heatup value        (within 10 minutes) open all of of 156,861 BTU/hr (-46000W) and         the common doorways between page IPE-4 uses 74665W. The trend       the control rooms, following the shown on Figure C-3 is the more         loss of Unit l's HVAC. The expected MCR room heatup, rather        accomplishment of this action is than the temperature spike seen on      not considered to be unrealistic, IPE-9.                                  since human nature would drive the operators to keep cool, as they begin to feel uncomfortable.
It is also recommended that at least one portable fan be set up Page 49 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                          BVPS-1 Final Resolution            Impact to Fire ID     Requirement1 Level        Closed                                                                               PRA YIN at an open common doorway, so that it is blowing the cooler air into Unit l's control room. This would assist the natural buoyancy driven air flow between the units and provide a constant air recirculation path, which would further ensure that a homogeneous mixture exists.
The time to accomplish this action to set up a portable fan is not calculated, but it is expected that 2 hours would suffice.
Therefore, based on these results, a loss of Unit 1 control room HVAC does not need to be modeled in the Unit I PRA.
AS-01  AS-12        C            Y      Beaver Valley is using a modified          As a resolution to this PRA Peer   No impact to Fire version of the WOG 2000 seal LOCA          Review observation, sensitivity    PRA, because this model, which is derived from the BNL       analyses were performed on the     issue was "best estimate" model, with Beaver         BVPS Unit 1 MAAP RCP seal          addressed in the Valley specific MAAP runs for time to      LOCA cases to investigate the      base PRA model core uncovery. The time of the start of impact of varying the timing of       prior to building the excessive leakage is 30 minutes in         the increased RCP seal leakage     Fire PRA.
this model. The NRC has not                from 30 to 13 minutes on the accepted this from licensing               resultant time to core damage.
submittals. Since Beaver Valley is         The conclusion from these planning some extensive AOT                sensitivities was that the change submittals in the future, this will have   in onset of the increased RCP to be addressed.                           seal LOCA leakage from 30 minutes to the minimum time of 1 13 minutes would not lead to Page 50 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution               Impact to Fire ID     Requirement 1 Level        Closed                                                                                PRA YIN significantly earlier times to core damage.
Ultimately resolved based on WCAP-15603, Rev. 1-A, NRC Approved, May 2003, Seal LOCA start time is 13 min.
AS-04  AS-07         C            Y      AMSAC is a mitigation system that        In response to this PRA Peer          No impact to Fire only appears in the ATWS tree.           Review observation, the               PRA, because this Actually AMSAC is a redundant start      GENTRANS Event Tree (see              issue was of AFW and turbine trip that is useful   Figure D-4a) was modified to          addressed in the in mitigation even when SSPS has         include Top Event PL (Power           base PRA model failed but the reactor trip has been     Level <40 %) and Top Event AS         prior to building the successful. Additionally AMSAC is        (ATWS Mitigating System               Fire PRA.
only model as a system point estimate    Actuation Circuitry) before asking of 1E-2 (see F&O SY-20). This could      Auxiliary Feedwater in Top Event affect/reduce the system/equipment       AF. The split fraction logic rules importance of SSPS, AFW and              and macros were also modified Turbine Trip                             to credit the use of AMSAC for providing a diverse method of starting the AFW pumps (see Tables 3.4-3 & 3.4-4). Section 3.4 "General Transient/Small LOCA Event Trees" and Tables 3.4-1 and 3.4-2 were also revised to account for these new top events in the GENTRANS Event Tree.
With respect to the AMSAC top event being quantified using a I point estimate value instead of a   I Page 51 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation         BVPS-1 Final Resolution               Impact to Fire ID     Requirement 1 Level        Closed                                                                  PRA YIN fault tree analysis, it was not deemed necessary to pursue a detailed fault tree analysis at this time. The point estimate value of 1.OE-02/demand used in the BVPS PRA models is taken from WCAP -11993 (Reference 1) and is conservative with respect to unavailabilities of a one signal train and the design criteria applied to AMSAC by the Westinghouse Owner's Group.
Additionally, the more recent WCAP-15831-P (Reference 14) also uses this point estimate value, as has other studies, as an appropriate value to use. A detailed fault tree would probably result in a lower AMSAC unavailability value, but this is not expected to have a significant impact on the core damage frequency, due to the already low significance of SSPS failures in non-ATWS sequences.
Page 52 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. 1 Significance   Status Fact & Observation                       BVPS-1 Final Resolution             Impact to Fire ID     Requirement   Level          Closed                                                                              PRA I YIN AS-09 AS-18          C              Y      The SGTR event tree assumes that         The concerns of this PRA Peer       No impact to Fire the actuation of PORVs (should be        Review observation are              PRA, because this PORV due to definition of B&F            unfounded, since the timing of      issue was success criteria) will result in the CIB the CIB initiation following bleed- determined to have (8 psig) actuation. A review of the      and-feed scenarios during a         no effect on the MAAP runs (Success Criteria,             SGTR will not impact the NPSH       BVPS PRA model.
Attachment A, Appendix F, Table 3)       of the HHSI pumps. This CA was indicates that CIB occurs for cases in   dispositioned by examining the which OB (B&F) is successful for         MAAP SGTR accident sequence cases in which AFW is failed and it      summary files as summarized occurs in approximately 2 hours. The     below:
QSS is assumed to be actuated given the CIB signal. The water injected to    For the SGTR cases with a loss the containment sump is necessary        of secondary cooling, the HHSI for NPSH success. It isn't clear what    pumps will initially be taking will happen in the case that CIB does    suction from the RWST, either not occur until 2 hours into the         due to an SI signal being scenario and what effect this may        generated or to the bleed-and-have on the NPSH concerns.               feed initiation. After about 6 minutes following the initiating of bleed-and-feed, the containment sump would begin to fill when the PRT rupture disc blows. During this time there will be RCS mass and energy released inside of the containment from the open PORVs, which will slowly start to increase the containment pressure and also be providing inventory directly into the containment sump.
After approximately 2 hours a Page 53 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status   Fact & Observation         BVPS-1 Final Resolution            Impact to Fire ID     RequirementI Level        Closed                                                                 PRA YIN I
CIB occurs, and QS will start and also begin to add RWST inventory into the sump, so that when the RS pumps start about 210 seconds later there should be sufficient inventory in the sump to provide adequate NPSH to the RS pumps. However, if a sufficient amount of water is not collected in the containment sump after this time, the recirculating spray pumps must be manually turned off and then turned back on when NPSH is sufficient. Operator actions to first turn off and then to turn on the RS pumps are modeled in Top Events SM and OR.
Success of these actions ensures that the RS pumps will be available when the RWST reaches the low-level setpoint and SI Recirculation is initiated.
At this time the HHSI pumps could be piggybacked onto the RS pumps if the LHSI pump trains were unavailable, and adequate NPSH would be provided.
Prior to this CIB signal being generated, the QS and RS will not start. However, the HHSI Page 54 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution           Impact to Fire ID     Requirement' Level        Closed                                                                              PRA YIN pumps will continue to take suction from the RWST until the low level SI Recirculation setpoint is reached. At this time even without a CIB initiation, approximately 296,000 gallons of RWST water would have been directed into the containment sump though the opened PORVs, so that ifthe HHSI pumps are piggybacked onto the LHSI/RS pumps, adequate NPSH would also be provided.
DA-03  DA-03        C            Y      The documentation of the CCF MGL           The resolution to this F&O was to No impact to Fire parameters is presented in Appendix        put shading and bold text in      PRA, because this C of the Data Analysis Notebook. The       Table C-5 for the MGL             issue was final compilation of the MGL               distributions that were developed addressed in the parameters is presented in Table C-6.      based on a plant specific         base PRA model The results are presented as "Plant-       analysis, so that they are more   prior to building the Specific" distributions, but this table is easily identified. This table was Fire PRA.
in fact a mix of parameters developed      also renamed to Table C-5 based on plant specific event              Beaver Valley Unit 1 - Common screening, in some cases Bayesian          Cause MGL Distributions.
updating, and in other cases generic data. With some difficulty, the reviewer could trace back through the documentation to determine the actual Page 55 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution           Impact to Fire ID     Requirement 1 Level        Closed                                                                           PRA YIN source of the MGL parameter, but a naming convention that identifies the parameter as plant specific, or generic would be helpful. As a minimum, generic data could be presented in a separate table from the parameters generated based on plant specific analysis.
DA-04  DA-5          C            Y      The data notebook describes several     The BV1 REV3 PRA model does       No impact to Fire sources for the generic component       not use any automatic             PRA, because this failure distributions for the BV Unit 2 recirculation check valves in the issue was model. Column 6 provides the            model. Therefore, this is not an  determined to have disposition of the 6 sources of         issue at Unit 1.                  no effect on the information. Item f-1994 STP data                                         BVPS PRA model.
was used to derive the failure rate distribution for the automatic recirculation check valve failure to open and was cloned from ZTVCOS using PLG generic check valve database distributions. Then the data from STP of 0 in 704 demands was used. It is not clear what this database variable was used for and if it is currently being used. The discussion does not indicate why was no information used from the BV plant history in this update process.
Page 56 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact &Observation                       BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                             PRA YIN DA-05  DA-03         C            Y      Table C-6 lists the Beta factor for     The disposition of this PRA Peer     No impact to Fire battery failure fails to operate        Review observation was to            PRA, because this (ZBBCHR) as a point estimate of         include a discussion on the         issue was 1.26E-2. The source of this value is    availability of newer data sources  addressed in the not documented in the Data Analysis     and justification as to why they    base PRA model Notebook. A review of the EP System     were not used, to Section 3.6 of    prior to building the Notebook found a reference to this      this notebook. Although,             Fire PRA.
value in an assumption, stating that    Appendix C does not specifically the value was taken from NUREG/CR-      list the source document 5497. Appendix C of the Data            references, they are specifically Analysis Notebook should be self        identified in Section 3.6 contained with respect to the source    "Calculation of Common Cause of the generic MGL. Appendix C does     Factors," and are included in not reference NUREG/CR-5497. Are        Section 5 "References" in the all other generic parameters actually   Data Analysis PRA Notebook.
from the PLG database or are other      Section 3.6 also provides the sources used? Is this the only value    basis for using common cause taken from 5497? What was the basis     data sources other than the PLG for using one selected value from       common cause database.
5497?
DA-1 1 DA-05         C            Y      A statement needs to be made in the     This PRA Peer Review                 No impact to Fire assumptions to describe the method      observation was dispositioned by     PRA, because this of assembling the data. The write-up    adding a discussion in Section       issue was implies that only unit 2 data is        3.3 "Presentation of Plant-          addressed in the included in the tables but there        Specific Data" of the Data           base PRA model appears that some unit 1 pumps may      Analysis PRA Notebook to             prior to building the have been included. Ifthis is the       identify what Unit 2 equipment is    Fire PRA.
case, then the text needs to explain    included in the development of that Unit 2 equipment is included and   the Unit 1 database distributions only the Unit 1 equipment that may be   or test and maintenance needed to shutdown Unit 2 is           unavailability.
included.                            I                                    II Page 57 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting.        Significance   Status   Fact & Observation                      BVPS-1 Final Resolution               Impact to Fire ID     Requirement'       Level          Closed                                                                                 PRA
__________I______                YN       ___________________
I DE-03  DE-11              C              Y        The flooding analysis and the IPE       Since the documentation for the       No impact on the state (briefly) that a plant walkdown   flooding walkdown that was            submitted BVPS-1 YIN      was performed. But there is no          performed as part of the IPE          Fire PRA, which I          documentation of the walkdown, or       could not be located, the             used the the insights gained from the            walkdown that was completed for       BV1 REV5 as its walkdown, available for review. The     the Beaver Valley Unit 1 Risk-        basis. Internal fire walkdown "notebook" would be a          Informed In-Service Inspection        initiators and flood valuable resource for analyst in future (RI-ISI) Indirect (Spatial)           initiators are updates of the PRA.                     Consequence Evaluation was            mutually exclusive credited, as discussed in the         and have no effect response to F&O DE-04 above.          on each other.
Since this RI-ISI walkdown is documented in a BVPS                  Furthermore, the calculation and is retrievable, it is BVPS-1 Fire PRA not deemed necessary to               working model reproduce it for the PRA              uses BV1 REV5A notebooks.                            as its basis, so this F&O will be This F&O was written against an       resolved when obsolete Internal Flooding PRA        NFPA 805 is model (BV1 REV3) and is               implemented.
considered to be resolved by the updated Internal Flooding PRA model incorporated in BV1 REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are Page 58 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                   BVPS-1 Final Resolution            Impact to Fire ID     Requirement' Level        Closed                                                                         PRA YIN presented in Table 1-4.
DE-06  SY           C            Y      Some of the flood frequencies are    This F&O was written against an    No impact on the based on a document (PLG-0624) that  obsolete Internal Flooding PRA     submitted BVPS-1 is dated 1988. The next update       model (BV1 REV3) and is            Fire PRA, which should include consideration of more considered to be resolved by the   used the recent flood data sources.           updated Internal Flooding PRA      BV1 REV5 as its model incorporated in              basis. Internal fire BV1 REV5A, which underwent a       initiators and flood focused Peer Review in             initiators are accordance with the guidance in    mutually exclusive Appendix B of NRC RG 1.200,        and have no effect Rev. 1, conducted during June 6-   on each other.
9 2011, by the PWR Owners Group. The F&Os as a result        Furthermore, the from this focused Peer Review,     BVPS-1 Fire PRA as well as their resolutions are   working model presented in Table 1-4.            uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 59 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status    Fact & Observation                      BVPS-1 Final Resolution          Impact to Fire ID     Requirement' Level        Closed                                                                             PRA Y/N DE-07  SY           C            Y         The PRA documentation should            This F&O was written against an  No impact on the include a discussion of the potential   obsolete Internal Flooding PRA   submitted BVPS-1 impact of floods on systems that are    model (BV1 REV3) and is          Fire PRA, which shared between the two units.           considered to be resolved by the used the Although this impact is expected to be  updated Internal Flooding PRA    BV1 REV5 as its minimal, one example is the potential   model incorporated in            basis. Internal fire impact on the electric power crosstie   BV1 REV5A, which underwent a     initiators and flood to Unit 1 availability due to floods in focused Peer Review in           initiators are the service water intake structure. Is  accordance with the guidance in  mutually exclusive the Unit 1 diesel dependence on         Appendix B of NRC RG 1.200,      and have no effect service water correctly accounted for   Rev. 1, conducted during June 6- on each other.
when the flood impacts the availability 9 2011, by the PWR Owners of the Unit 1 service water system?     Group. The F&Os as a result      Furthermore, the from this focused Peer Review,   BVPS-1 Fire PRA as well as their resolutions are working model presented in Table 1-4.          uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is I_                                                                          implemented.
HR-02 HR-06        C            Y         A generic error of omission term from   This F&O was written against an  No impact to Fire the PLG database (ZHEO1A) was           obsolete HRA PRA model           PRA, because this used for all misalignment HEPs          (BV1 REV3) and is considered to  issue was without regard for procedural or        be resolved by the updated HRA   addressed in the operational failure barriers such as    PRA model incorporated in        base PRA model independent verification, peer checks,  BVl REV4, which underwent a      prior to building the walkdowns, etc. However, plant          focused Peer Review in           Fire PRA.
specific data was used for test and     accordance with the guidance in maintenance frequencies. Therefore,     Appendix B of NRC RG 1.200, the overall misalignment errors were a  Rev.1, conducted during the hybrid of generic and plant specific    week of October 29, 2007, by data. This was used for systems         Westinghouse. The F&Os as a Page 60 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN which are important to CDF (e.g., AF,     result from this focused Peer SI).                                      Review, as well as their resolutions are presented in Table 1-3.
HR-10  HR-18         C            Y      The number of operators interviewed       This PRA Peer Review                No impact to Fire for the performance shaping factors       observation was dispositioned by    PRA, because this was stated to be 3 operators, 3           acknowledging that, while           issue was training staff and 3 PRA staff. This is a technically only 3 operators were   addressed in the low number of operators for the FLIM      interviewed, the training staff     base PRA model method to succeed. Having the PRA         personnel were former operators     prior to building the staff fill out the PSF forms dilutes the  that still held a senior reactor    Fire PRA.
operator input to the process.            operators license at the time of the interview. Therefore, a total of six licensed personnel were used in developing the PSFs.
Additionally, as a final resolution to this observation, future BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology to identify human action dependencies.
This F&O was written against an obsolete HRA PRA model (BV1REV3) and is considered to be resolved by the updated HRA PRA model incorporated in Page 61 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution             Impact to Fire ID      Requirement' Level        Closed                                                                              PRA Y/N BV1 REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
IE-01   IE-04        C            Y      In section 3.3 of the Initiating Events  In response to this observation,    No impact to Fire Notebook, there is a discussion about    Section 3.3 of the Initiating       PRA, because this the justification for the exclusion of   Events Analysis PRA Notebook        issue was Random RCP Seal LOCAs as a               was revised to add further          addressed in the separate IE that is based on the RCP     clarification based on the floating base PRA model floating ring seals and the assumption   ring seals (per Reference 15) as    prior to building the of limited leak flow. The justification  to why random RCP seal LOCAs        Fire PRA.
provided to account for assuming this    were eliminated from the Beaver is a discussion by FENOC with            Valley PRA model. Additionally, Westinghouse. No documentation of        this Section was revised to this discussion is provided and no       provide justification as to why a further technical justification is given random RCP seal failure at as to why random seal failure should     Beaver Valley that resulted in a have the frequency and be included in    reactor trip would be captured Category GI/QG9 under RTRIP.             under the RTRIP initiating event frequency.
IE-02   IE-13        C            Y      In the discussion of the process used    In response to this observation,    No impact to Fire for Initiating Event frequency update,   Section 2.3 of the Initiating       PRA, because this BWR data and other NSSS vendor           Events Analysis PRA Notebook        issue was PWRs are excluded from the update        was revised to provide a brief      addressed in the without sufficient documentation.        explanation for why BWR and         base PRA model Page 62 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                        BVPS-1 Final Resolution              Impact to Fire ID      Requirement 1 Level        Closed                                                                               PRA YIN other PWR NSSS vendor data           prior to building the were excluded from the BVPS          Fire PRA.
initiating event frequency update.
IE-03   IE-10         C            Y      The Support System Faults that are       In response to this observation      No impact to Fire used as Initiating Events are assigned   Tables Al and Al0 in the             PRA, because this a Code Designator. The System            Initiating Events Analysis PRA       issue was Codes and Top Events for these           Notebook was revised to include      addressed in the designators are not explained. The       a cross-reference from the           base PRA model System Notebook does not clearly         initiating event "Code Designator"   prior to building the explain how the System is considered     to the applicable PRA System         Fire PRA.
to cause an Initiating Event in the      Notebook. In addition, Table A2 Model.                                   of this notebook provides a failure modes and effects analysis of the key BVPS Unit 1 support systems and why they were considered for initiating events, so it was not judged to be necessary to duplicate this information in the System Notebooks. It was not the intent of the PRA System Notebooks to be stand-alone documents, but rather to be supplemented by the I PRA analysis notebooks.            I Page 63 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution            Impact to Fire ID      Requirement' Level        Closed                                                                               PRA Y/N IE-06   IE-16        C            Y      Plant trip trends in the recent years      In response to this observation,   No impact to Fire are showing a general decrease in          Figure 3-1 was generated to        PRA, because this trips/year. A simple trend analysis        present a plan trip trend          issue was (like a histogram) showing number of       histogram and Section 3.2 of the   addressed in the trips versus  years for each   unit should Initiating Events PRA Notebook     base PRA model be considered as a subsection in the       was revised to include a           prior to building the initiating events section. This would      discussion of the plant trip trend Fire PRA.
possibly allow better estimation of        analysis performed for BVPS plant specific transient event             Unit 1.
frequency. Currently, there appears to be no analysis to show whether there is a positive or negative trend (or a lack of it). Also, a trend analysis fits well with the concept of plant-specific nature of analysis in question.
For example, consider a plant with 10 years of trip data; the first 5 years each have 5 trips/year; the last 5 years have 1 trip per year. This would result in an average of 3 events per year over a ten-year period. Now consider another plant where the two numbers are interchanged; it has 1 event per year for the first five years and 5 events per year for the next five years. The overall average is still 3 events per year. In both cases, there are definite trends; the first plant should actually use a frequency of 1 trip per year; the second plant should use 5 trips per year. In any case, neither plant should use 3 trips per year.
Page 64 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution               Impact to Fire ID      Requirement' Level        Closed                                                                                PRA Y/N IE-07   IE-03        C            Y      There was not enough information in      In response to this observation,      No impact to Fire the initiating event report to reproduce Table Al 2 was generated in           PRA, because this the results.                             Appendix A of the Initiating          issue was Events Analysis PRA Notebook          addressed in the
: 1. The prior distributions were not      to show the set of input data         base PRA model available.                               used in the creation of each first    prior to building the stage (prior) distribution identified Fire PRA.
: 2. the screening of the WCAP IE          in Table A4, as well as, the report was not available                 resultant RISKMAN distribution parameters for the mean,
: 3. The derivation of prior means was     median, 5th and the 95th not available.                           percentiles. This data was input into the RISKMAN Data Module, using the 'First Stage of Two Stage' distribution option to create the resultant prior distributions. The derivation of how RISKMAN generates these prior distributions using this option is contained in the RISKMAN Software Users Manual, and does not need to be reproduced in this notebook.
Additionally, there was no screening of the Westinghouse WCAP-1 5210 initiating event data since each individual utility performed a thorough review of their plant's trip events to ensure that the data was valid.
Page 65 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                         BVPS-1 Final Resolution            Impact to Fire ID      Requirement' Level        Closed                                                                                 PRA YIN
[2-02   [2-08        C            Y        Most containment phenomena are             Ultimately resolved by GAP F&O     No impact to Fire either excluded via generic, or plant      LE-F2-01 (see Table 1-2)           PRA, because this specific analyses, or are modeled as a                                        issue was point estimate. Other issues such as                                          addressed in the whether the containment is inerted are                                        base PRA model more directly quantified. For example,                                        prior to building the the LI/L2 interface directly quantifies                                       Fire PRA.
those end states when the sprays are operating; operation of the sprays is considered to de-inert containment.
[2-04   [2-21        C            Y        Top Event 10 - Containment Failure         Ultimately resolved by GAP F&O     No impact to Fire Prior to Vessel Breach (Cl) states that LE-D6-01 (see Table 1-2)              PRA, because this because the Beaver Valley Unit 2                                              issue was containment normally operates at                                              addressed in the subatmospheric conditions, the                                                base PRA model existence of large pre-existing leaks is                                      prior to building the believed to be negligible. Current L2                                         Fire PRA.
analysis would not support containment conversion application.
MU-01   MU-04        C            Y        Plant changes that may impact the          Ultimately resolved by procedure   No impact to Fire PRA model are documented, and              NOBP-CC-6001 and Design            PRA, because this resolved via Risk Evaluation Review        Interface Evaluation (DIE)         issue was (RER) forms. Continuing training is        process that evaluates changes     addressed in the used to educate engineering (includes for PRA impact.                         base PRA model procedure writers) on when an RER is                                          prior to building the required vs. direct procedural                                                Fire PRA.
guidance. The update process could be improved by adding a similar review process into other plant I change procedures                        I                                  I Page 66 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution          Impact to Fire ID     Requirement 1 Level        Closed                                                                          PRA YIN MU-03  MU-1 1        C            Y      When the PRA model is updated for       Ultimately resolved by procedure No impact to Fire plant modifications or for decreases in NOBP-CC-6001, Section 7 lists    PRA, because this CDF all areas of applications should    RI-applications that need        issue was be evaluated. Certain applications      updated following a new ERM      addressed in the can be adversely impacted by            (Effective Reference Model). base PRA model decreases in CDF. For example,                                           prior to building the credit taken for examining segments                                      Fire PRA.
in a RI-ISI program could decrease with a decrease in CDF (or even an unrelated CDF increase, depending on changes to the risk profile.)
Additionally more than just the change in CDF needs to be evaluated. The risk profile may change drastically without a corresponding change in the CDF. For example CDF due to one IE may go up by 30% in conjunction with another change in CDF due to a different IE decreasing by 25%. This would cause only a 5% change in CDF but significant changes to the risk profile.
Page 67 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution               Impact to Fire ID     Requirement 1 Level        Closed                                                                                   PRA Y/N QU-01  QU-07         C            Y      PRA Peer Review Subtler Criteria for        As resolution to this PRA Peer        No impact to Fire this sub-element describes the need         Review observation it should be       PRA, because this for documentation of the limitations of     noted that the RISKMAN model          issue was simplified models. This                     is used for purposes for risk         addressed in the documentation could not be found for        sensitivities (e.g., SDP findings)    base PRA model Beaver Valley Unit 2.                       and risk-informed applications,       prior to building the as such, there are no simplified      Fire PRA.
model used for these purposes and hence nothing to document.
Additionally, the intent of the PRA Notebooks was to document the development process and results of the RISKMAN PRA model, not to document the Safety Monitor model or its process that currently uses pre-solved sequence, or to document other risk-informed sensitivities and programs. Moreover, future versions of the Safety Monitor for RISKMAN users are to incorporate a full requantification of the sequences in place of pre-solved sequences.
QU-05 QU-23         C            Y       RISKMAN allows the user to apply a         In general, the BV1 REV3 PRA          No impact to Fire cutoff at the system (i.e., top event)      model update did not use any          PRA, because this level. This cutoff is applied prior to the truncation limits (i.e., a value of   issue was event tree quantification. In general,      0) for cutset generation.             addressed in the no truncation (i.e., a value of 0) is      However, when the cutsets             base PRA model used in the systems cutset generation. exceeded the quantification           prior to building the But non-zero values are used for a         limits, very low non-zero values       Fire PRA.
handful of top events. Of these most       were used. This was only            I Page 68 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact & Observation                     BVPS-1 Final Resolution              Impact to Fire ID     Requirement' Level          Closed                                                                               PRA I YIN    I use very low cutoffs (<1E-12). The     present in a handful of top one exception to this (as best this    events.
reviewer could determine) is the quantification of Top Event WC where   The one exception to this is the a cutoff of 5E-7 was used. Top Event   quantification of Top Event WC WC is an intermediate top used to      where a cutoff of 7E-7 was used.
quantify Top Event WA and WB. Split    Top Event WC is an intermediate Fraction WC1 has an unavailability of  top used to quantify Top Events about 3E-9.                            WA and WB. The 7E-7 cutoff was used for the cutset The SW system notebook discusses       generation with elevated the system level cutoff and when it is common cause failure rates for used. However, the potential           pump and fan starts and run quantitative impacts associated with   basic events. The failure rates the truncated results are not          are reset to best estimate values discussed.                             prior to the quantification of split fractions. This is done so that the cutoff is high enough to stay below the Riskman cutset limitation, but allows the cutsets to contain the higher order cutsets that will allow analysis of degraded boundary conditions (i.e., split fractions).
Split Fraction WC2B (DC Purple fails) has an unavailability of about 9.6914E-6, and only accounts for the probabilistic failure of the A header since DP=F causes a guaranteed failure of the B header. When this value is comDared to the Page 69 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                     BVPS-1 Final Resolution             Impact to Fire ID     Requirement1 Level        Closed                                                                            PRA YIN Split Fraction WA1 (all support available) value of 1.0493E-5 (generated using a 1E-1 2 truncation limit), it can be shown that only about 8% of the expected unavailability is lost due to the higher truncation limits used in Top Event WC.
Furthermore, truncation limits will not be required in RISKMAN version 6, which uses binary decision diagrams to generate Split Fractions values directly without cutsets.
Ultimately resolved by quantifying the split fractions using the BDD methodology, starting with the revision 4 PRA model.
SY-04  SY-27        C            Y      It would be desirable to reference the Ultimately resolved in Revision 5   No impact to Fire success criteria source in the system  PRA model System Notebooks,         PRA, because this notebook. Success criteria are         Section 3 "SYSTEM SUCCESS           issue was specified in the "Success Criteria"    CRITERIA"                           addressed in the notebook, and the reviewers found it                                       base PRA model difficult to flip from one source to                                       prior to building the another, especially when using the                                         Fire PRA.
electronic documentation CD.
Page 70 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                       BVPS-1 Final Resolution             Impact to Fire ID     Requirement 1 Level        Closed                                                                                PRA YIN SY-05  SY-12         C            Y        The system notebooks do not              Ultimately resolved in Revision 5   No impact to Fire specifically discuss the dependencies    PRA model System Notebooks,         PRA, because this that may be present regarding HVAC /     Section 4 "SUPPORT                  issue was room cooling. However, review of the     SYSTEMS"                            addressed in the HVAC notebook identified the various                                         base PRA model spatial locations that may require                                           prior to building the HVAC and indicated the various                                               Fire PRA.
analyses that have been completed to either require HVAC dependencies or not.
SY-07  SY-26         C            Y        The Beaver Valley Unit 2 system            Ultimately resolved by GAP F&O    No impact to Fire notebooks have no indication of          F&O SY-Cl-02 (see Table 1-2).       PRA, because this system engineering reviews. These                                            issue was reviews help ensure that systems are                                         addressed in the model in accordance with day-to-day                                          base PRA model plant operations and additionally                                            prior to building the expand the PRA knowledge of the                                              Fire PRA.
I system engineers.
SY-08  SY-01         C            Y        The guidance did not provide for more    The split fraction definitions were No impact to Fire complete description of the actual       developed using the dependency      PRA, because this boundary conditions used in the          matrices located in Appendix B of   issue was system analysis. It did talk about       the Level 1 Event Tree Analysis     addressed in the support, but the actual details are not  PRA Notebook. Split fractions       base PRA model required (i.e. what AC bus is needed     for Top Events are found in the     prior to building the for which pump for that boundary         Split Fraction sections of the      Fire PRA.
condition for the split fraction). As a  RISKMAN System Notebook files result most of the notebooks do not      in Appendix C. Common cause give a good description of what each     failure inputs, assessment split fraction means and its usage.      methodology and data update The only place this appears to be        summaries are located in actually documented is the description   Appendix C of the Data Analysis on the split fraction in the RISKMAN     Notebook.
split fraction.                         II Page 71 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution            Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA YIN SY-09  (sic SY-14)   C            Y      System Diagrams contained in              Hard copy of 11x17 with markups    No impact to Fire System Notebooks do not have              of plant drawings are provided in  PRA, because this explanation of color highlighting,        the System Notebook.               issue was Figures are difficult to read and many    Components modeled in the PRA      addressed in the component lDs are not legible.            are highlighted in PINK, while the base PRA model flow paths are highlighted in      prior to building the There also does not appear to be a        YELLOW.                            Fire PRA.
discussion of 'Operating experience for the system' required in the           Operating experience for the guidance document.                        system is subsumed in the system engineers review.
SY-10  (sic SY-14)   C            Y      The Fault Trees for IA, IC have           Resolved in Revision 5 PRA         No impact to Fire Transfer Gates and page numbering         models that have Fault Trees       PRA, because this that is confusing. IA page 6 transfers    redrawn so Top Gate is on page     issue was to page 7 but page 7 top gate             1.                                 addressed in the transfers to page 1. In IC, page 1 is a                                      base PRA model transfer from page 5 which is the Top     NOTE: The Fire PRA FTs are not     prior to building the Event IC. This is confusing and is        organized due to addition of       Fire PRA. Also, easily fixed.                             NFPA 805 basic events,             this is a documentation-only issue.
SY-12  SY-17         C            Y      The Service cooling water system          Ultimately resolved by GAP F&O     No impact to Fire notebook assumption #7 has 10             F&O SY-B7-01 (see Table 1-2).      PRA, because this minutes to trip the RCP's on loss of                                         issue was cooling. However, in the                                                     addressed in the Miscellaneous system notebook, top                                           base PRA model event OC has 5 minutes to trip the                                           prior to building the RCP's. Note, this time might be                                              Fire PRA.
important in quantifying an HEP.        I Page 72 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution              Impact to Fire ID     RequirementI Level        Closed                                                                               PRA YIN SY-13  SY-13        C            Y      Several systems appeared to be           The AFW pump macros were             No impact to Fire modeled as point estimate only,          revised in the BV1 REV3 PRA          PRA, because this AMSAC and the Switchyard. This is        model to include credit for          issue was acceptable, per the peer review          AMSAC to start the AFW pumps         addressed in the guidance, but consideration could be     (in addition to the SSPS signal),    base PRA model given to adding some detail to these     given that the signal is generated   prior to building the models.                                  during non-ATWS events.              Fire PRA.
The Switchyard (Top Event OG) was modeled as a single basic event. However, it used a lognormal distribution to quantify Monte Carlo values in addition to the point estimate value.
Furthermore, the PRA model already addressed transient induced LOSP events due to failures of the USST/SSST and Switchyard breakers in the normal bus top events.
The current methods to address the AMSAC and Switchyard failure probabilities are deemed acceptable as is.
SY-1 5 SY-1 0       C            Y      HVAC support analysis appears to         As a resolution to this PRA Peer      No impact to Fire only consider 8 hours versus 24          Review observation Table 3 in         PRA, because this hours. The analysis was extended to      the Ventilation and Room             issue was 24 hours based upon the fact that the    Cooling Analysis Notebook was        addressed in the curves were essentially flat after 8     revised to show the expected         base PRA model hours. Some of the curves are straight   area temperature at 24 hours          prior to building the and increasing and not flat and          following the loss of ventilation. Fire PRA.
constant.                              I                                    I Page 73 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution              Impact to Fire ID     RequirementI Level        Closed                                                                               PRA Y/N AS-05  AS-1 7       D            Y      The success criteria for top event TT    Ultimately resolved in Revision 5    No impact to Fire is missing from Table 3.3-2 of the       PRA model Level 1 Accident           PRA, because this Event Tree Notebook although it is       Sequence Analysis Notebooks,         issue was described on page 58 of the notebook. Table 3.3-2 & Table 3.4-2.           addressed in the base PRA model prior to building the Fire PRA.
AS-06  AS-1 7       D            Y      The success criteria for top event NM    Top Event NM is a switch to          No impact to Fire is missing from Table 3.3-6 of the       query if early core damage has       PRA, because this Event Tree Notebook although it is       occurred during the SI injection     issue was described on page 67 of the notebook. phase, and does not have any         addressed in the success criteria per se, so is not   base PRA model included in the Success Criteria     prior to building the Tables.                              Fire PRA.
DE-01  DE-01        D            Y      The guidance for including spatial       Ultimately resolved in Revision 5    No impact to Fire information in the system notebooks      PRA model Systems Analysis           PRA, because this could not be found in the system         Overview and Guidance                issue was notebook guidance document.              Notebooks, Section 5 "SPATIAL        addressed in the However, it appears that most, if not    CONSIDERATIONS"                      base PRA model all, the system notebooks did have a                                          prior to building the section on spatial considerations for                                         Fire PRA.
flooding, fire and seismic.
SY-1 1 SY-1 5       D            Y      The AC power system calculation          Ultimately resolved in Revision 5    No impact to Fire notebook, has top event OG which         PRA model Data Analysis              PRA, because this has a split fraction for generic loss of Notebooks, Tables A-1 and A-2.       issue was power after a plant trip. The basic                                           addressed in the event report for this was missing from                                        base PRA model the system notebook, but the system                                           prior to building the notebook listed a database variable                                           Fire PRA.
                                        "OG1X" used. This variable could not be found in the data notebook. It was in the RISKMAN model with no references from where it came from. It I                                    I Page 74 of 301

Table 1-1. Summary of BVPS-1 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                   BVPS-1 Final Resolution Impact to Fire ID     Requirement' Level        Closed                                                              PRA YIN was determined that it came from the PLG-0500 revision 1, 1989.
Page 75 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution                   Impact to Fire ID  Requirement   Level       Closed                                                                                   PRA YIN IE- IE-A6         B           Y      There is no documentation of interviews Documentation of interviews with A6-                                  of plant personnel (e.g., operations,   system engineering plant personnel to 01                                   maintenance, engineering, safety        determine if potential system analysis) to determine if potential     descriptions have been overlooked is      No impact to initiating events have been overlooked, located in the Unit-1 PRA Notebook        Fire PRA, This is required to meet capability     Systems Analysis Overview and             because this category II                             Guidance, Appendix B. Review of the issue was initiating events section in the system   addressed in notebooks was also included as            the base PRA review of the system description by       model prior to system engineers. System engineers        building the were asked to identify from a list of     Fire PRA.
the current initiating events if there are any top events whose failure could result in a potential initiating event (plant/reactor trip), which may have been overlooked. No additional potential initiating events were brought up. Also, review of AOPs (e.g., 1OM-53C.4.1.28.1) can be credited                                I Page 76 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                           BVPS-1 Final Resolution                 Impact to Fire ID  Requirement  Level        Closed                                                                                        PRA Y/N    I IE- IE-C8        C            Y        All the relevant combinations of events      The Initiating Events section of the    No impact to C8-                                    involving the annual frequency of one        system notebooks now contain a          Fire PRA, 01                                     component failure combined with the          description of the development of the   because this unavailability (or failure during the repair support system initiating events,       issue was time of the first component) of other        Except as noted, the mission time for   addressed in components are not available in the          normally running equipment is           the base PRA support system notebooks. The support        changed from 24 hours to 8760 hours     model prior to system notebooks list which initiators       times the plant availability factor. building the are developed from the fault trees and       Portions of the system fault tree logic Fire PRA.
provide a diagram of the fault tree,         which is not used to quantify support however there is no narrative                system initiating event frequency is explanation of how these fault trees are     also noted.
modified and what assumptions are used to develop the support system initiator frequencies. RISKMAN reports, provided as System Notebook appendices, list the details of the system IE models (i.e. cutsets, modified basic event equations, etc.), however there is no discussion of which component failures were considered, what mission time assumptions are used, or description of the development of the system IE models. Therefore it is difficult to determine if all relevant combinations of events have been considered.
Page 77 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                  Impact to Fire ID    Requirement  Level        Closed                                                                                   PRA YIN IE-   IE-C9        B            Y      Plant-specific information used in the   The Recovery Considerations section      No impact to C9-                                    assessment and quantification of         of the System Notebooks now              Fire PRA, 01                                     recovery actions included in the support documents the operator actions that      because this system initiating event analysis is not  were modified in the quantification of   issue was included in the support system           the system initiating event frequency. addressed in notebooks. Analysis of the recovery      No new recovery actions are credited     the base PRA actions should be consistent with the    in the analysis of initiating event      model prior to applicable requirements in the Human     frequency.                               building the Reliability Analysis                                                              Fire PRA.
IE- IE-Cl 0         B           Y      There is no comparison of the initiating In the Initiating Events Analysis        No impact to C1 0-                                  event analysis with generic data         Notebook, Table A6 demonstrates a        Fire PRA, 01                                     sources or explanation of differences to comparison of initiating event           because this provide a reasonableness check of the    frequencies for the Westinghouse 3-      issue was results.                                 loop PWR. The industrial events are      addressed in from WOG Rev 7 PSA comparison            the base PRA database. Comparably Beaver Valley       model prior to 1 to other Westinghouse 3-loop PWR       building the plants has most initiating events        Fire PRA.
frequencies close to order of magnitude. Some differences in plant frequency include Loss of Emergency Switchgear HVAC (BVX) with a much lower frequency then the other plants and MLOCA. The reason for difference in HVAC is due to the high detail of the ventilation and room cooling analysis, as well as several ventilation sources available in the area (i.e., normal fans, emergency     I Page 78 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact& Observation                         BVPS-1 Final Resolution                 Impact to Fire ID     Requirement   Level          Closed                                                                                     PRA I YIN    L fans, and portable fans). MLOCA initiating event frequency has been updated for PRA-BV1-AL-R05 to a new methodology based on NUREG-1829 (April 2008) and lowering the effective break size therefore lowering the frequency. The WOG Rev 7 of other Westinghouse 3-loop PWRs was developed before the methodology of NUREG-1829 was used. Blank gaps in Table A6 do not have data for that plant from the WOG database.
DA-    DA-C4         B              Y        A clear basis for the identification of   Documentation of this is now included   No impact to C4-                                          events as failures is not included in the in Section 3.3 of the Unit 1 Data       Fire PRA, 01                                           Data Analysis Notebook. This basis        Analysis Notebook.                      because this could be used to distinguish between                                              issue was those degraded states for which a                                                 addressed in failure, as modeled in the PRA, would                                             the base PRA have occurred during the mission and                                              model prior to those for which a failure would not have                                          building the occurred (e.g., slow pick-up to rated                                             Fire PRA.
speed).
It could not be determined from the Data Analysis Notebook if any failures were screened out or if the maintenance rule MPFFs are used as the data source.
DA-   DA-C5         B              Y        There is no listing or description in the For Beaver Valley Unit 1, repeated      No impact to C5-                                          Data Analysis Notebook of repeated        plant specific component failures       Fire PRA, 01                                          component failures that were counted      occurring within a short time interval  because this a             L as a single failure.                      were counted as a sinale failure V
issue was Page 79 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                    Impact to Fire ID    Requirement  Level        Closed                                                                                      PRA Y/N during implementation of the               addressed in Repeated component failures occurring     Maintenance Rule. PRA data is taken        the base PRA within a short time interval should be    from Maintenance Rule sources and          model prior to counted as a single failure if there is a therefore meets the requirements of        building the single, repetitive problem that causes    the ASME PRA standard."                    Fire PRA.
the failures. In addition only one demand should be counted.
DA-   DA-C8         B           Y      Plant records should be used and          Maintenance Rule plant specific            No impact to C8-                                    documented to determine the time that     unavailability data is incorporated into Fire PRA, 01                                     components are configured in their        the PRA model. Documentation of            because this standby status. This is required to       this can be found in the Presentation      issue was change SR DA-C8 from Capability           of Plant-Specific Data section of the      addressed in Category I to III                         Data Analysis notebook under sub-          the base PRA section Component Maintenance              model prior to Data and is evidenced by the Prior         building the Maintenance Data of Appendix B."           Fire PRA.
DA-   DA-C10        B           Y      Decompose failure modes into sub-         Component failure modes have been          No impact to C1 0-                                  elements and count demands/failures       handled appropriately to meet this         Fire PRA, 01                                     individually in the sub-elements.         Supporting Requirement at the CC-Il        because this level. Failures of sub-elements of a       issue was component that are modeled explicitly addressed in in the PRA are associated with the         the base PRA sub-element and not the component          model prior to itself. Documentation of this can be       building the found in the Presentation of Plant-        Fire PRA.
Specific Data section of the Data Analysis Notebook under sub-section Component Failure Event Allocation and is evidenced by the data in Table A-I.                                     I Page 80 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                           BVPS-1 Final Resolution               Impact to Fire ID   Requirement  Level        Closed                                                                                    PRA YIN HR-  HR-B1, HR-    B           Y      This F&O is a carry-over from the peer      As outlined in HRA Notebook Section    No impact to B1-  D2                               review (F&O HR-2).            A generic      2.2, testing and maintenance          Fire PRA, 01                                    error of omission term from the PLG          procedures were evaluated to identify because this database (ZHEO1A) was used for all           potential misalignments. These        issue was misalignment HEPs without regard for         potential misalignments were          addressed in procedural or operational failure barriers   evaluated using the EPRI HRA          the base PRA such as independent verification, peer       Calculator 4.1.1 to develop specific  model prior to checks, walkdowns, etc. However,             HEPs for each potential misalignment  building the plant specific data was used for test and    as documented in HRA Notebook         Fire PRA.
maintenance frequencies. Therefore,          Table 3.5.
the overall misalignment errors were a hybrid of generic and plant specific data. This was used for systems which are important to CDF (e.g., Auxiliary Feedwater, Safety Injection).
HR- HR-D3         B           Y      While the discussion in the system           Procedure quality has been            No impact to D3-                                  notebooks (AFW and QS/RS notebooks           incorporated into human error         Fire PRA, 01                                    were reviewed) references the                probability assessments,              because this procedures, no documentation of quality      Documentation of this can be found    issue was of those procedures or administrative        throughout the HRA Notebook,          addressed in controls was found.                          particularly the Dynamic Actions      the base PRA section and tables of Section 3."     model prior to building the I_                                     Fire PRA.
HR- HR-12         B           Y      The BV HRA does document a process           Section 2.3 of the Unit 1 HRA         No impact to 12-                                  to perform a systematic search for           notebook has been created to          Fire PRA, 01                                   dependent human actions credited on          document the process employing the    because this individual sequences. It is clear from the  EPRI HRA calculator that is used to   issue was human action identifier sheets              complete the dependency analysis      addressed in documented in the BVPS-2 HRA                evaluation. The results of the human  the base PRA Page 81 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution                  Impact to Fire ID   Requirement    Level       Closed                                                                                      PRA Y/N notebook that such an evaluation has        action dependency analysis               model prior to been performed, but there is no             presented in Appendix F show that        building the evidence of the process documented in       the dependency contributions to the      Fire PRA.
the HRA notebook.                           split fraction values are insignificant.
The largest change identified is for split fraction CDC which has a value of 1.40E-2 and a dependency contribution of 6.41 E-4 or a 4.6%
To be consistent with current HRA           increase due to dependencies. This methods, there must be a systematic         increase in the split fraction CDC process to identify, assess and adjust      value due to operator action dependencies between multiple human         dependencies would lead to a 0.34%
errors in the same sequence, including      increase in the core damage those in the initiating events.             frequency. This level of change is considered insignificant to the overall results, and did not reveal any new dependencies that were not already analyzed and accounted for.
Furthermore, these results confirm the success of using the Event Sequence Diagrams during development of the IPE to identify dependencies between operator actions, and account for these dependencies in the development of the HEPs 4.
HR- HR-I1,                            The HRA notebook sporadically               A new Assumptions section has been       No impact to 13- HR-13,                            discusses assumptions and                   added to the Unit 1 HRA notebook.        Fire PRA, 01  AS-C3,                             uncertainties. Per the Clarification to    All major assumptions and sources of     because this regulatory Guide 1.200 Revision 1,         uncertainty are listed in this location. issue was IE-D3,                             there is an increased importance in the                                             addressed in IF-F3,                             industry to identify assumptions and                                                the base PRA LE-F3,                             uncertainties in the PRA model. In                                                  model prior to LE-G4,                             reviewing the HRA notebook, it is                                                   building the L
Page 82 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                              1BVPS-1 Final Resolution               Impact to Fire ID   Requirement    Level        Closed                                                                                        PRA Y/N    I SC-C1,                               difficult to locate the assumptions and                                              Fire PRA.
SC-C3,                               uncertainties.
QU-F4 HR-  HR-I1, HR-12   C            Y        The Beaver Valley Unit 2 system and           The BVPS Units 1 & 2 PRA and           No impact to I1-                                       data notebooks have been updated and          System notebooks were formally         Fire PRA, 01                                        exist in draft form, but there is no record   reviewed and signed off as part of the because this of formal review and approval,                update process.                        issue was Furthermore, only a subset of the total                                              addressed in PRA notebooks have been updated for                                                  the base PRA this revision of the PRA.                                                            model prior to building the Fire PRA.
HR-  HR-12          C            Y        There is no evidence in the HRA or            During the Extended Power Uprate       No impact to 12-                                       Success Criteria notebooks that an            evaluation, plant operations did       Fire PRA, 02                                        operator review of the HRA has been           review the operator actions and        because this performed.                                    timings. These reviews are             issue was documented in FENOC Letters L      addressed in 003 and L-06-018. Furthermore,         the base PRA several operator action scenarios      model prior to were evaluated using the plant         building the simulator.                             Fire PRA.
IF- IF-Ala         B            Y         It is not clear from the documentation       This F&O was written against an        No impact on Ala-                                      that a comprehensive assessment has           obsolete Internal Flooding PRA model   the submitted 01                                        been conducted to finalize the               (BV1 REV4) and is considered to be     BVPS-1 Fire combined rooms including propagation,         resolved by the updated Internal       PRA, which barriers, etc. The IF assessment is          Flooding PRA model incorporated in     used the based on large flood areas but there is      BV1 REV5A, which underwent a           BV1REV5 as no description of the process used to        focused Peer Review in accordance      its basis.
define those areas with respect to flood     with the guidance in Appendix B of     Internal fire propagation and barriers.                    NRC RG 1.200, Rev.1, conducted         initiators and during June 6-9, 2011, by the PWR      flood initiators I Owners Group. The F&Os as a result     are mutually Page 83 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                           BVPS-1 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                        PRA Y/N from this focused Peer Review, as         exclusive and well as their resolutions are presented   have no effect in Table 1-4.                             on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-A3         B           Y      There is no evidence in the IF Notebook      This F&O was written against an           No impact on A3-                                  that it represents the current as-built-as   obsolete Internal Flooding PRA model      the submitted 01                                   operated plant (circa 2007). Rev4            (BV1 REV4) and is considered to be        BVPS-1 Fire documentation in another document            resolved by the updated Internal          PRA, which may include the information to show          Flooding PRA model incorporated in        used the that the IF assessment is current, but it    BV1 REV5A, which underwent a              BV1REV5 as is not in this Notebook, IF-A3-01 was        focused Peer Review in accordance         its basis.
written as a B level F&O to provide          with the guidance in Appendix B of        Internal fire documentation that the IF assessment         NRC RG 1.200, Rev.1, conducted            initiators and still represents the as-built as operated    during June 6-9, 2011, by the PWR         flood initiators plant in 2007, This probably also            Owners Group. The F&Os as a result        are mutually applies to other PRA elements from the       from this focused Peer Review, as         exclusive and ASME PRA Standard (e.g., SY, SC,             well as their resolutions are presented   have no effect HR, etc.) and should be addressed            in Table 1-4.                             on each other.
generically for the BVPS PRA. This would facilitate future reviews and                                                    Furthermore, development of PRA applications,                                                       the BVPS-1 I                                         I_Fire PRA Page 84 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                           BVPS-1 Final Resolution                   Impact to Fire ID  Requirement   Level        Closed                                                                                        PRA Y/N working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-B1         B            Y      The ASME PRA Standard states "for            This F&O was written against an           No impact on B1-                                   each flood area, identify the potential      obsolete Internal Flooding PRA model      the submitted 01                                    sources of flooding." Section C3.1           (BV1 REV4) and is considered to be        BVPS-1 Fire identifies flood sources in each area but    resolved by the updated Internal          PRA, which clear documentation of each source in        Flooding PRA model incorporated in        used the an area is lacking. The Standard             BV1 REV5A, which underwent a              BV1REV5 as expects a more systematic approach for       focused Peer Review in accordance         its basis.
identifying potential flood sources and      with the guidance in Appendix B of        Internal fire then later screening them. The IF            NRC RG 1.200, Rev.1, conducted            initiators and assessment here includes initial             during June 6-9, 2011, by the PWR         flood initiators screening without written justification. It  Owners Group. The F&Os as a result        are mutually is suggested that a complete discussion      from this focused Peer Review, as         exclusive and of potential sources be documented and       well as their resolutions are presented   have no effect the basis for screening potential            in Table 1-4.                             on each other.
sources.
Furthermore, I_                                       I_the BVPS-1 Page 85 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions on                        BVPS-1 Final Resolution                    Impact to Fire PRA Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
I                                          4.
Section C3.1 states that major flood         This F&O was written against an            No impact on sources were reviewed to identify            obsolete Internal Flooding PRA model       the submitted potential flood locations. The ASME          (BV1 REV4) and is considered to be         BVPS-1 Fire standard suggests that first you identify    resolved by the updated Internal           PRA, which flooding areas then identified all           Flooding PRA model incorporated in         used the flooding sources in that area. This          BV1 REV5A, which underwent a               BV1REV5 as method used for BVPS may have lead           focused Peer Review in accordance          its basis.
to overlooking other sources of flooding     with the guidance in Appendix B of         Internal fire within each area.                            NRC RG 1.200, Rev.1, conducted             initiators and during June 6-9, 2011, by the PWR          flood initiators Owners Group. The F&Os as a result         are mutually from this focused Peer Review, as          exclusive and well as their resolutions are presented    have no effect in Table 1-4.                              on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so I          I      I                                            I                                         I-this F&O will be Page 86 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                 Impact to Fire ID   Requirement   Level        Closed                                                                                   PRA Y/N resolved when NFPA 805 is implemented.
IF- IF-B2,         B           Y      The SR B-2 of the PRA Standard            This F&O was written against an         No impact on B2- IF-B3                             requires "For each source of flooding,    obsolete Internal Flooding PRA model    the submitted 01                                     identify the flooding mechanisms that     (BV1 REV4) and is considered to be      BVPS-1 Fire would result in a fluid release including resolved by the updated Internal        PRA, which failure models, human-induced             Flooding PRA model incorporated in      used the mechanisms, and other events resulting    BV1 REV5A, which underwent a            BV1REV5 as in a release into the flood area." In     focused Peer Review in accordance       its basis.
addition, SR B-3 requires "For each       with the guidance in Appendix B of      Internal fire source and its identified failure         NRC RG 1.200, Rev.1, conducted          initiators and mechanism, identify the characteristic of during June 6-9, 2011, by the PWR       flood initiators release and the capacity of the source."  Owners Group. The F&Os as a result      are mutually Section C3.1 of the IF Notebook does      from this focused Peer Review, as       exclusive and not provide enough detail to judge        well as their resolutions are presented have no effect whether these requirement is met. One     in Table 1-4.                           on each other.
example is that although a few human error induced floods (e.g., testing or                                            Furthermore, maintenance errors) were considered,                                              the BVPS-1 there is no evidence of a systematic                                              Fire PRA assessment of potential test and                                                  working model maintenance errors.                                                               uses BV1REV5A as Page 87 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                 Impact to Fire ID    Requirement   Level       Closed                                                                                  PRA W/N its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF-  IF-C2b        B           Y      Section C3.1 does not have enough        This F&O was written against an         No impact on C2b-                                  detail to show that the capacity of the  obsolete Internal Flooding PRA model    the submitted 01                                    drains and the amount of water retained  (BV1 REV4) and is considered to be      BVPS-1 Fire by the sumps, berms, dikes, and curbs    resolved by the updated Internal        PRA, which was estimated. The reviewer notes that   Flooding PRA model incorporated in      used the it is likely that this was performed but BV1 REV5A, which underwent a            BV1REV5 as there is no record of the assessment. focused Peer Review in accordance       its basis.
The capacity of drains and the amount    with the guidance in Appendix B of      Internal fire of water retained by sumps, etc. should  NRC RG 1.200, Rev.1, conducted          initiators and be documented in the IF Notebook.        during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model Page 88 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation            BVPS-1 Final Resolution     Impact to Fire ID  Requirement  Level        Closed                                                           PRA YIN uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
Page 89 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation ID  Requirement   Level       Closed YIN
=
IF- IF-C3        B            Y      The PRA Standard states "for each        This F&O was written against an         No impact on C3-                                  SSCs identified in IF-C2c identify the   obsolete Internal Flooding PRA model    the submitted 01                                   susceptibility of each SSC in the flood  (BV1 REV4) and is considered to be      BVPS-1 Fire area to flood-induced failure            resolved by the updated Internal        PRA, which mechanism". Also, the SR-C3a states,     Flooding PRA model incorporated in      used the "to determine susceptibility of SSC to   BV1 REV5A, which underwent a            BV1REV5 as flood-induced failure mechanism, take    focused Peer Review in accordance       its basis.
credit for the operability of SSC        with the guidance in Appendix B of      Internal fire identified in IF-C2c with respect to     NRC RG 1.200, Rev.1, conducted          initiators and internal flood impact only if supported  during June 6-9, 2011, by the PWR       flood initiators by an appropriate combination of: 1)     Owners Group. The F&Os as a result      are mutually test or operational data, 2) engineering from this focused Peer Review, as       exclusive and analysis, and 3) expert judgment." It is well as their resolutions are presented have no effect likely that flood-induced failure        in Table 1-4.                           on each other.
mechanisms were considered in the IF assessment but are not identified in the                                         Furthermore, IF Notebook. Section C3.1 does not                                               the BVPS-1 provide enough detail on the impact of                                           Fire PRA the flood on SSCs.                                                               working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
Page 90 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution                 Impact to Fire ID   Requirement   Level       Closed                                                                                     PRA Y/NIA IF-  IF-C3a, IF-   B           Y      The IF-C3b SR requires that all             This F&O was written against an         No impact on C3b- C3b                              potential mechanisms that can create        obsolete Internal Flooding PRA model    the submitted 01                                    interconnections between flooding           (BV1 REV4) and is considered to be      BVPS-1 Fire areas be considered for CCII and that       resolved by the updated Internal        PRA, which barrier unavailability also be considered   Flooding PRA model incorporated in      used the for CCIII. There is no evidence in the      BV1 REV5A, which underwent a            BV1REV5 as Appendix C of the Initiating Events         focused Peer Review in accordance       its basis.
Notebook that any mechanism other           with the guidance in Appendix B of      Internal fire than open obvious pathways (e.g.,           NRC RG 1.200, Rev.1, conducted          initiators and vents in doors, tunnels, etc.) were         during June 6-9, 2011, by the PWR       flood initiators considered. This may be just a              Owners Group. The F&Os as a result      are mutually documentation issue for CCII.               from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect Also, the RI-ISI program did a              in Table 1-4.                           on each other.
comprehensive assessment of flooding potential for various break locations. A                                            Furthermore, comparison should be performed                                                      the BVPS-1 between the RI-ISI flooding assessment                                              Fire PRA and the PRA IF assessment to ensure                                                 working model consistency.                                                                        uses BV1 REV5A as its basis, so this F&O will be Note that upgrading to CCIII requires                                               resolved when the additional consideration of barrier NFPA 805 is unavailability, for example due to implemented.
maintenance activities or maintenance implemented.
unavailability.
IF- IF-C3c        B           Y      Develop engineering calculations for        This F&O was written against an          No impact on C3c-                                  ALL flooding scenarios, not just the        obsolete Internal Flooding PRA model    the submitted 01                                    "worst case" scenarios. This is likely just (BVI REV4) and is considered to be      BVPS-1 Fire a documentation issue, but since it is       resolved by the updated Internal       PRA, which missing from the IF Notebook, SR IF-         Flooding PRA model incorporated in     used the C3c is not met.                              BV1 REV5A, which underwent a            BV1REV5 as Page 91 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution                 Impact to Fire ID  Requirement    Level        Closed                                                                                 PRA W/N focused Peer Review in accordance       its basis.
with the guidance in Appendix B of      Internal fire NRC RG 1.200, Rev.1, conducted          initiators and during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-C4,         B            Y      The operator actions credited in the IF This F&O was written against an         No impact on C4- IF-C6,                             flooding assessment are based on        obsolete Internal Flooding PRA model    the submitted 01  IF-C8                              detailed HRA assessments for two        (BV1 REV4) and is considered to be      BVPS-1 Fire Page 92 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution                 Impact to Fire ID   Requirement  Level        Closed                                                                                    PRA Y/N operator actions. Cues, procedures,        resolved by the updated Internal        PRA, which etc. are detailed in the HRA               Flooding PRA model incorporated in      used the assessment. It is not clear if these       BV1 REV5A, which underwent a            BV1REV5 as actions are also applied to scenarios      focused Peer Review in accordance       its basis.
other than those used to quantify the      with the guidance in Appendix B of      Internal fire HEP in the HRA Notebook. In addition,      NRC RG 1.200, Rev.1, conducted          initiators and there are a number of other instances in   during June 6-9, 2011, by the PWR       flood initiators which the operators are assumed to be      Owners Group. The F&Os as a result      are mutually highly reliable. There is also no          from this focused Peer Review, as       exclusive and indication that these are validated by     well as their resolutions are presented have no effect operator interviews. Cleaner               in Table 1-4.                           on each other.
documentation of the operator actions that are credited (as well as those not                                            Furthermore, credited), and their basis, should be                                              the BVPS-1 completed to assist in future reviews                                              Fire PRA and for risk applications in which the                                             working model performance of operators is important.                                             uses Also a clear linkage between the IF and                                            BVIREV5A as HRA Notebooks should be documented                                                 its basis, so for the basis of the important HRA input                                           this F&O will be and some of the operator actions to                                                resolved when screen scenarios is based on highly                                                NFPA 805 is reliable operator actions.                                                         implemented.
IF- IF-C4         B           Y      SR-IF-C4 requires the development of       This F&O was written against an         No impact on C4-                                   flood scenarios by examining the           obsolete Internal Flooding PRA model    the submitted 02                                    equipment and relevant plant features      (BV1 REV4) and is considered to be      BVPS-1 Fire in the flood area and area in potential    resolved by the updated Internal        PRA, which propagation paths, taking credit for      Flooding PRA model incorporated in      used the appropriate flood mitigation systems or    BV1 REV5A, which underwent a            BV1REV5 as operator actions, and identifying          focused Peer Review in accordance       its basis.
susceptible SSCs. No flood scenarios       with the guidance in Appendix B of      Internal fire are developed in the IF Notebook.          NRC RG 1.200, Rev.1, conducted          initiators and I during June 6-9, 2011, by the PWR       flood initiators Page 93 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                    Impact to Fire ID  Requirement   Level        Closed                                                                                      PRA YIN Owners Group. The F&Os as a result         are mutually from this focused Peer Review, as          exclusive and well as their resolutions are presented    have no effect in Table 1-4.                              on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-C5,         B           Y      The screening methodology                 This F&O was written against an            No impact on C5- IF-C5a,                           documented in Section C3.1 does not       obsolete Internal Flooding PRA model       the submitted 01  IF-C7,                            follow the systematic methodology          (BV1 REV4) and is considered to be        BVPS-1 Fire IF-D7                             described inthe Standard. For the IF       resolved by the updated Internal          PRA, which assessment, the screening is performed     Flooding PRA model incorporated in        used the at the source and location level and, in   BV1 REV5A, which underwent a              BV1REV5 as some cases, without adequate basis as      focused Peer Review in accordance         its basis.
discussed in a previous F&O (IF-B1-        with the guidance in Appendix Bof         Internal fire 01). The method used in the IFflooding     NRC RG 1.200, Rev.1, conducted            initiators and assessment may be technically              during June 6-9, 2011, by the PWR         flood initiators adequate, ifthe basis is better            Owners Group. The F&Os as a result        are mutually documented, even though it does not        from this focused Peer Review, as         exclusive and meet the Standard SRs for C-5, C5a        well as their resolutions are presented   have no effect and C7.                                    in Table 1-4.                             on each other.
Furthermore, I_                                        I the BVPS-1 Page 94 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                   BVPS-1 Final Resolution                 Impact to Fire ID  Requirement  Level        Closed                                                                              PRA Y/N Fire PRA working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-D1         B           Y      The FENOC response to DE-06 from     This F&O was written against an         No impact on D1-                                  the OG Peer Review is incomplete. obsolete Internal Flooding PRA model    the submitted 01                                   The F&O is concerned about the       (BV1 REV4) and is considered to be      BVPS-1 Fire vintage of the data used to estimate resolved by the updated Internal        PRA, which pipe break frequencies and the FENOC Flooding PRA model incorporated in      used the response talks about walkdowns.      BV1 REV5A, which underwent a            BV1REV5 as focused Peer Review in accordance       its basis.
with the guidance in Appendix B of      Internal fire NRC RG 1.200, Rev.1, conducted          initiators and during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when Page 95 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                     BVPS-1 Final Resolution                   Impact to Fire ID  Requirement    Level       Closed                                                                                  PRA YIN NFPA 805 is implemented.
IF- IF-D5,         B           Y      The IF pipe and tank break frequencies This F&O was written against an           No impact on D5- IF-D5a                            used in the IF assessment are based on obsolete Internal Flooding PRA model      the submitted 01                                    1988 and 1990 data. The prior pipe     (BV1REV4) and is considered to be         BVPS-1 Fire break frequencies should be updated to resolved by the updated Internal          PRA, which reflect more recent experience and     Flooding PRA model incorporated in        used the should include plant specific          BV1 REV5A, which underwent a              BV1REV5 as experience. In estimating pipe break   focused Peer Review in accordance         its basis.
frequencies, it is recommended that    with the guidance in Appendix B of        Internal fire experience with safety related vs. BOP NRC RG 1.200, Rev.1, conducted            initiators and piping be considered along with active during June 6-9, 2011, by the PWR         flood initiators pipe degradation mechanisms. Credit    Owners Group. The F&Os as a result        are mutually for condition monitoring programs      from this focused Peer Review, as         exclusive and should also be applied where           well as their resolutions are presented   have no effect applicable,                            in Table 1-4.                             on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 96 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                    BVPS-1 Final Resolution                 Impact to Fire ID  Requirement   Level       Closed                                                                               PRA Y/N IF- IF-El         B           Y      The Standard states "for each flood   This F&O was written against an         No impact on El-                                  scenario, review the accident         obsolete Internal Flooding PRA model    the submitted 01                                   sequences for the associated plant-   (BV1 REV4) and is considered to be      BVPS-1 Fire initiating event group to confirm     resolved by the updated Internal        PRA, which applicability of other accident       Flooding PRA model incorporated in      used the sequences model." A spot check was    BV1 REV5A, which underwent a            BV1 REV5 as made to provide reasonable confidence focused Peer Review in accordance       its basis.
that the overall results are correct. with the guidance in Appendix B of      Internal fire However, there is no record that EACH NRC RG 1.200, Rev.1, conducted          initiators and scenario was reviewed.                during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
Page 97 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution                   Impact to Fire ID  Requirement    Level       Closed                                                                                   PRA YIN IF- IF-Fl,         B           Y      The Internal Flooding documentation     This F&O was written against an           No impact on Fl- SY-A4                             does not include the results of the     obsolete Internal Flooding PRA model      the submitted 01                                    walkdowns performed during the          (BV1 REV4) and is considered to be        BVPS-1 Fire original assessment. FENOC response     resolved by the updated Internal          PRA, which to OG Peer Review F&O DE-4 indicates    Flooding PRA model incorporated in        used the that the RI-ISI walkdowns are           BV1 REV5A, which underwent a              BV1REV5 as documented and cover the issues         focused Peer Review in accordance         its basis.
required for an Internal Flooding       with the guidance in Appendix B of        Internal fire walkdown. To facilitate future          NRC RG 1.200, Rev.1, conducted            initiators and maintenance and reviews of the internal during June 6-9, 2011, by the PWR         flood initiators flooding assessments, the use of the    Owners Group. The F&Os as a result        are mutually RI-ISI walkdowns for internal flooding  from this focused Peer Review, as         exclusive and should be documented in the Internal    well as their resolutions are presented   have no effect Flooding Notebook and a direct          in Table 1-4.                             on each other.
reference to a retrievable copy the RI-ISI walkdowns should also be included.                                            Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 98 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                     PRA IF- IF-F2         B           Y      The documentation of the processes to     This F&O was written against an           No impact on F2-                                  identify flood areas, sources, pathways,  obsolete Internal Flooding PRA model      the submitted 01                                   scenarios, etc. are not clearly           (BV1 REV4) and is considered to be        BVPS-1 Fire documented. For example, the rules        resolved by the updated Internal          PRA, which used to screen out sources and areas      Flooding PRA model incorporated in        used the are not defined and the bases for         BV1 REV5A, which underwent a              BV1REV5 as eliminating or justifying propagation     focused Peer Review in accordance         its basis.
pathways is either not clearly defined or with the guidance in Appendix B of        Internal fire not provided at all.                      NRC RG 1.200, Rev.1, conducted            initiators and during June 6-9, 2011, by the PWR         flood initiators Owners Group. The F&Os as a result        are mutually from this focused Peer Review, as         exclusive and well as their resolutions are presented   have no effect in Table 1-4.                             on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 99 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                     PRA Y/N IF- IF-F2         B           Y      The IF Notebook states that the annual    This F&O was written against an           No impact on F2-                                  frequency of a flood scenario in location obsolete Internal Flooding PRA model      the submitted 02                                   X is Rx = Fi*fx,i*fs,x*fp,x and the       (BV1 REV4) and is considered to be        BVPS-1 Fire quantify scenarios in which recover       resolved by the updated Internal          PRA, which actions can be included is Sx=Rx (Dx +    Flooding PRA model incorporated in        used the lx). However, the frequency is never      BV1 REV5A, which underwent a              BV1 REV5 as quantified using these equations. This    focused Peer Review in accordance         its basis.
is confusing for a reviewer - what is the with the guidance in Appendix B of        Internal fire purpose of these statements if they are   NRC RG 1.200, Rev.1, conducted            initiators and not used? or if they are used, an         during June 6-9, 2011, by the PWR         flood initiators explanation is needed.                    Owners Group. The F&Os as a result        are mutually from this focused Peer Review, as         exclusive and well as their resolutions are presented   have no effect in Table 1-4.                             on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 100 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance    Status Fact & Observation                        BVPS-1 Final Resolution                 Impact to Fire ID   Requirement    Level           Closed                                                                                   PRA Y/N IF-  IF-Alb, IF-    C               Y      Although it is apparent that dual unit    This F&O was written against an         No impact on Al-  Bla, IF-C4a,                          impacts for internal flooding were        obsolete Internal Flooding PRA model    the submitted 01   IF-D4                                 considered, the details are buried in the (BV1 REV4) and is considered to be      BVPS-1 Fire individual assessments. To assist         resolved by the updated Internal        PRA, which future reviews and the development of     Flooding PRA model incorporated in      used the risk informed applications, it is         BV1 REV5A, which underwent a            BV1 REV5 as recommended that a separate section       focused Peer Review in accordance       its basis.
of the Internal Flooding documentation    with the guidance in Appendix B of      Internal fire be created to summarize the search for    NRC RG 1.200, Rev.1, conducted          initiators and and results of an assessment of dual      during June 6-9, 2011, by the PWR       flood initiators unit internal flooding impacts.           Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-A4,         B               Y      The OG Peer Review F&O DE-3               This F&O was written against an         No impact on A4-                                        documented the lack of documentation      obsolete Internal Flooding PRA model    the submitted 01                                        of a walkdown for internal flooding and   (BV1 REV4) and is considered to be      BVPS-1 Fire other PRA purposes. The F&O               resolved by the updated Internal        PRA, which response by FENOC is incorrect and        Flooding PRA model incorporated in      used the does not address the F&O. As a result,    BV1 REV5A, which underwent a            BV1REV5 as A.
the walkdown documentation is still not   focused Peer Review in accordance       its basis.
Page 101 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance   Status   Fact & Observation                           BVPS-1 Final Resolution                   Impact to Fire ID  Requirement   Level          Closed                                                                                          PRA Y/N    I identified. The walkdown needs to be         with the guidance in Appendix B of        Internal fire documented and reviewed from the             NRC RG 1.200, Rev.1, conducted            initiators and perspective of internal floods in order to   during June 6-9, 2011, by the PWR         flood initiators assign a CC to several of the SRs for        Owners Group. The F&Os as a result        are mutually Internal Flooding,                           from this focused Peer Review, as         exclusive and IF-C9,                                                                             well as their resolutions are presented   have no effect IF-D4                                 It is noted that in response to OG F&O       in Table 1-4.                             on each other.
DE-04, FENOC used the RI-ISI                                                           Furthermore, documentation in place of the original                                                 the BVPS-1 walkdown documentation. Based on the                                                   Fire PRA scope of the RI-ISI walkdowns, this is                                                 Fing  P       oA considered to be an acceptable                                                         working model substitute for the Internal Flooding                                                   uses assessment since the same                                                              BV1 REV5A as considerations are being investigated                                                  its basis, so (e.g., drain locations, equipment                                                      this F&O will be elevations, etc.). However, a                                                          resolved when retrievable walkdown document needs                                                    NFPA 805 is to be identified in the IF Notebook.                                                   implemented.
IF- IF-D1,         C             Y        The IF assessment does not rely on           This F&O was written against an           No impact on D1- IF-D3,                                grouping of lEs, sources, locations, etc. obsolete Internal Flooding PRA model      the submitted a        a                                            -                                         a Page 102 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution                 Impact to Fire ID  Requirement   Level       Closed                                                                                    PRA Y/N 02  IFD3a                            The screening methodology discussed        (BVI REV4) and is considered to be      BVPS-1 Fire in the IFNotebook and assessed under       resolved by the updated Internal        PRA, which the IF-C-xx SRs methodology resulted       Flooding PRA model incorporated in      used the in only a handful of flooding events to    BV1 REV5A, which underwent a            BV1REV5 as be considered. These were individually     focused Peer Review in accordance       its basis.
assessed in the overall PRA                with the guidance in Appendix B of      Internal fire quantification using RISKMAN. The          NRC RG 1.200, Rev.1, conducted          initiators and methodology used may be technically        during June 6-9, 2011, by the PWR       flood initiators adequate in spite of not meeting the       Owners Group. The F&Os as a result      are mutually ASME Standard SRs for grouping ifit        from this focused Peer Review, as       exclusive and can be justified that only a handful of    well as their resolutions are presented have no effect events are important.                      in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-D4         C           Y      The PRA documentation should include       This F&O was written against an         No impact on D4-                                  a discussion of the potential impact of    obsolete Internal Flooding PRA model    the submitted 01                                   floods on systems that are shared          (BVI REV4) and is considered to be      BVPS-1 Fire between the two units. This impact is      resolved by the updated Internal       PRA, which expected to be minimal. One example         Flooding PRA model incorporated in     used the is the potential impact on the electric    BV1 REV5A, which underwent a            BV1REV5 as power crosstie to Unit 1 availability due focused Peer Review in accordance       its basis.
to floods in the service water intake      with the guidance in Appendix B of       Internal fire structure. Is the Unit 1 diesel            NRC RG 1.200, Rev.1, conducted          initiators and Page 103 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                   Impact to Fire ID  Requirement   Level        Closed                                                                                    PRA Y/N dependence on service water correctly    during June 6-9, 2011, by the PWR        flood initiators accounted for when the flood impacts     Owners Group. The F&Os as a result        are mutually the availability of the Unit 1 service   from this focused Peer Review, as         exclusive and water system?                            well as their resolutions are presented   have no effect in Table 1-4.                             on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-D5         C            Y      The IEF for pipe breaks is based on a    This F&O was written against an           No impact on D5-                                   generic 80% capacity factor. There are   obsolete Internal Flooding PRA model      the submitted 02                                    two issues with this method: a) current  (BV1 REV4) and is considered to be        BVPS-1 Fire capacity factors are typically greater   resolved by the updated Internal          PRA, which than 80% so that the IEFs are slightly   Flooding PRA model incorporated in        used the lower, and b) the method is inconsistent BV1 REV5A, which underwent a              BV1REV5 as with the method used to calculate other  focused Peer Review in accordance         its basis.
IEFs. It is recommended that the         with the guidance in Appendix B of        Internal fire calculation for IF IEF be revised to be  NRC RG 1.200, Rev.1, conducted            initiators and consistent with the method used for      during June 6-9, 2011, by the PWR         flood initiators other IEFs.                              Owners Group. The F&Os as a result        are mutually from this focused Peer Review, as         exclusive and well as their resolutions are presented   have no effect in Table 1-4.                             on each other.
I Furthermore, Page 104 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status     Fact & Observation                        BVPS-1 Final Resolution                 Impact to Fire ID  Requirement   Level        Closed                                                                                       PRA YIN the BVPS-1 Fire PRA working model uses BVI REV5A as its basis, so this F&O will be resolved when NFPA 805 is I             _implemented.
IF- IF-D6         C            Y          The IF flooding assessment uses           This F&O was written against an         No impact on D6-                                       screening criteria to limit the operator  obsolete Internal Flooding PRA model    the submitted 01                                        induced floods during maintenance         (BV1 REV4) and is considered to be      BVPS-1 Fire (e.g., due to operator errors such as     resolved by the updated Intemal         PRA, which inadvertently opening isolation valves    Flooding PRA model incorporated in      used the which maintenance is occurring). One      BV1 REV5A, which underwent a            BV1REV5 as of the screening criteria is whether the  focused Peer Review in accordance       its basis.
maintenance activity is performed         with the guidance in Appendix B of      Internal fire during power operation or at shutdown. NRC RG 1.200, Rev.1, conducted          initiators and The application of these criteria to      during June 6-9, 2011, by the PWR       flood initiators potential floods should be re-assessed    Owners Group. The F&Os as a result      are mutually in light of recent practices to perform   from this focused Peer Review, as       exclusive and more maintenance at power to shorten      well as their resolutions are presented have no effect the shutdown periods. It is expected      in Table 1-4.                           on each other.
that this will have a small to negligible impact on the IF assessment and is                                                Furthermore, therefore assigned a Level C.                                                     the BVPS-1 Fire PRA working model uses BV1REV5A as its basis, so this F&O will be Page 105 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                 Impact to Fire ID  Requirement  Level        Closed                                                                                   PRA Y/N resolved when NFPA 805 is implemented.
IF- IF-E5         C           Y      There are a number of operator actions    This F&O was written against an         No impact on E5-                                  credited in the IF assessment that are    obsolete Internal Flooding PRA model    the submitted 01                                   used to screen potential flooding events  (BV1 REV4) and is considered to be      BVPS-1 Fire based on the operators ability to         resolved by the updated Internal        PRA, which diagnose the pipe break and isolate the   Flooding PRA model incorporated in      used the leak thereby preventing the flood.        BV1 REV5A, which underwent a            BV1REV5 as However, these operator actions are       focused Peer Review in accordance       its basis.
based on judgment. For others, one of     with the guidance in Appendix B of      Internal fire the two HEPs that are analyzed is used    NRC RG 1.200, Rev.1, conducted          initiators and based on judgment. Examples include:      during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect
: 1) In Section C4.3.6 it is stated that    in Table 1-4.                           on each other, operator will receive sump alarms and be alert to the loss of RWST tank level                                           Furthermore,
                                     ... the possibility that the operators do                                         the BVPS-1 not locally isolate the tank ... is                                               Fire PRA estimated as 6.7E-03 from ZHEFL2.                                                 working model Page 106 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                 Impact to Fire ID   Requirement   Level       Closed                                                                                   PRA Y/N
: 2) In Section C3.2.1 it is stated that a                                          uses flood from the fan room should be                                                 BV1 REV5A as detected quickly since this room is next                                          its basis, so to the control room. The control                                                  this F&O will be building sump high-level alarm would                                              resolved when alert operators. Failure of the air                                               NFPA 805 is conditioning would also alert operators.                                          implemented.
It is recommended that a better basis for these operator actions be developed to ensure consistency with the remainder of the PRA.\
IF-  IF-E5a        C           Y      Several operator actions in the IF        This F&O was written against an         No impact on E5a-                                  assessment use the HEPs documented        obsolete Internal Flooding PRA model    the submitted 01                                    by detailed analysis for ZHEFL1 and 2.    (BV1 REV4) and is considered to be      BVPS-1 Fire These assume that the cues,               resolved by the updated Internal        PRA, which procedures steps, action, timing, etc. Flooding PRA model incorporated in      used the are similar enough to that for ZHEFL1     BV1 REV5A, which underwent a            BV1REV5 as or 2 but this is not documented in the IF focused Peer Review in accordance       its basis.
Notebook or the HR Notebook. To be        with the guidance in Appendix B of      Internal fire consistent with the operator action       NRC RG 1.200, Rev.1, conducted          initiators and assessments for the remainder of the      during June 6-9, 2011, by the PWR       flood initiators PRA, it is recommended that better       Owners Group. The F&Os as a result      are mutually documentation be developed to support     from this focused Peer Review, as       exclusive and the use of ZHEFL1 or 2 for these          well as their resolutions are presented have no effect operator actions, or new HEPs be          in Table 1-4.                           on each other.
developed as appropriate.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as Page 107 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance   Status Fact& Observation                     BVPS-1 Final Resolution                 Impact to Fire ID  Requirement  Level          Closed                                                                               PRA I Y/N its basis, so this F&O will be resolved when NFPA 805 is implemented.
IF- IF-F1         C             Y      If the current IF methodology is      This F&O was written against an         No impact on Fl-                                    retained, a comparison of the current obsolete Internal Flooding PRA model    the submitted 02                                     methodology to the ASME Standard is   (BV1 REV4) and is considered to be      BVPS-1 Fire recommended to facilitate future      resolved by the updated Internal        PRA, which reviews.                              Flooding PRA model incorporated in      used the BVl REV5A, which underwent a            BV1 REV5 as focused Peer Review in accordance       its basis.
with the guidance in Appendix B of      Internal fire NRC RG 1.200, Rev.1, conducted          initiators and during June 6-9, 2011, by the PWR       flood initiators Owners Group. The F&Os as a result      are mutually from this focused Peer Review, as       exclusive and well as their resolutions are presented have no effect in Table 1-4.                           on each other.
Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so Page 108 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact& Observation                         BVPS-1 Final Resolution                  Impact to Fire ID    Requirement  Level        Closed                                                                                    PRA YIN this F&O will be resolved when NFPA 805 is implemented.
LE-   LE-C2a, LE-   B           Y      SR LE-C2a is assigned a capability        The Level 2 LERF Analysis Notebook       No impact to C2a-  C2b, LE-C3,                      category I because BVPS 2 does not        Section 2.5 "General Discussion of       Fire PRA, 01    LE-C6                            use operator actions post core damage. Level 2 Operator Actions" discusses      because this This is considered conservative           operator actions considered for this     issue was treatment of operator actions following   model.                                   addressed in the onset of core damage. To meet                                                  the base PRA capability category III for this SR, BVPS WCAP-16657-P suggests seven              model prior to 2 level 2 analysis must contain realistic potential operator actions (OA) for      building the operator actions, based on SAMGs,         inclusion in a Level 2 PRA model.        Fire PRA.
EOPs, etc. such as WCAP-16657-P.          Each of these actions along with two others were reviewed specifically for Beaver Valley Unit 1. The Level 2 OA to restore feedwater to a dry steam generator was added to the PRA model.
LE-  LE-C2b        B           Y      Only recovery of AC power after UTAF      Section 2.5 of the Level 2 LERF          No impact to C2b-                                  is discussed in the Level 2 notebook. It  Analysis Notebook discusses the use      Fire PRA, 01                                    is concluded that not enough time exists  of Level 2 Operator Actions for          because this to assign a high success probability,     recovery; specifically recovery of       issue was No other recoveries are discussed.        feedwater to a dry steam generator is    addressed in included in the CET Top Event OL.        the base PRA AC electric power recovery is included   model prior to in the Level 1 Top Event RE              building the I Fire PRA.
Page 109 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance   Status Fact & Observation                         BVPS-1 Final Resolution                Impact to Fire ID    Requirement    Level         Closed                                                                                   PRA Y/N LE-   LE-C9a, LE-    B             Y      Level 2 and LERF analysis stopped at       A discussion has been added to         No impact to C9a-  C9b                                 containment failure and continued          Section "General Modeling              Fire PRA, 01                                        operation of equipment and operator        Assumptions and Criteria for Level 2   because this actions were not modeled. Operation of     Analysis" in the Level 2 LERF          issue was mitigating systems after containment       Analysis Notebook to justify the       addressed in failure is not modeled either. Justify the significance of the containment spray  the base PRA lack of credit of equipment survivability, system operability on LERF mitigation  model prior to following containment failure. Details building the of equipment survivability can also be Fire PRA.
found in Appendix A, Sections A. 1.7 and A.1.10.
LE-   LE-Cl0         B             Y      SGTR and containment bypass did not        A discussion has been added to the     No impact to C10-                                      take credit for scrubbing. WCAP-16657      Level 2 LERF Analysis Notebook         Fire PRA, 01                                        suggests that scrubbing for tube rupture   Section 3.3 "Containment Event         because this events can be credited by an operator      Tree," Top Event OL to credit SGTR     issue was action restart auxiliary feedwater to the  scrubbing and the basis for the        addressed in ruptured steam generator.                  decontamination factor.                the base PRA model prior to building the I         _                                                                                                            Fire PRA.
LE-   LE-D5         B             Y      Beaver Valley Thermal Induced SGTR         The PI-SGTR and TI-SGTR methods        No impact to D5-                                      is based on a 1995 Fauske and              are included in Appendix F of the      Fire PRA, 01                                        Associates report and Westinghouse         Level 2 LERF Analysis Notebook.        because this Calculation CN-RRA-02-38. Recent                                                  issue was investigations suggest that these results                                         addressed in may be too optimistic. A more                                                     the base PRA reasonable approach may be                                                        model prior to implementing WCAP 16341, "Simplified                                              building the LERF Model," and characterizing the                                               Fire PRA.
uncertainties based on that latest EPRI, I__I   _     IIPWROG,             and NRC interactions.
LE-   LE-D5         B             Y      The Cl analysis for BV2REV3b is based      Following the Beaver Valley Unit 1     No impact to D6-                                      on a sub-atmospheric containment.          Atmospheric Containment Conversion     Fire PRA, Page 110 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                 Impact to Fire ID   Requirement   Level        Closed                                                                                  PRA Y/N 01                                     BV2 has been converted to atmospheric    modification, the containment still     because this so this analysis must be revisited,      normally operates at slightly sub-      issue was BV1REV4 does account for the             atmospheric conditions. A discussion    addressed in atmospheric containment conversion in    has been added in Section               the base PRA the Containment Isolation notebook.      "Condensed Plant Damage State           model prior to The results of a similar assessment for  Matrix for Beaver Valley Unit 1" to     building the BV-2 need to be incorporated in the      outline the Beaver Valley Unit 1        Fire PRA.
LERF notebook.                           containment change from sub-atmospheric to atmospheric and the impact on the Level 2 analysis.
LE-  LE-E4         B            Y      The BV2 LERF model is quantified         The Level 2 phenomena split fraction    No impact to E4-                                    using RISKMAN. Only point-estimates      distributions are included in Table 3-  Fire PRA, 01                                     for each top event are used and there    26 of the Level 2 LERF Analysis         because this are no uncertainty estimates or          Notebook. This table contains Beaver    issue was uncertainty propagation.                 Valley Unit 1 plant specific Level 2    addressed in phenomena distributions along with      the base PRA the mean, median, 5th%ile, and the      model prior to 95th%ile. A discussion on how these     building the distributions were developed is         Fire PRA.
provided in Section 3.4 of this notebook.
LE- LE-F2         B            Y      The PRA Peer Review Team suggested       The LERF uncertainty analysis was       No impact to F2-                                    in F&O L2-02 using uncertainty analysis performed as part of the quantification Fire PRA, 01                                    for the LERF top events to ensure that   process using Monte Carlo sampling      because this future applications are not affected by  of the Level 2 split fraction           issue was use of point estimates.                 distributions. The result of this       addressed in analysis is provided in the BVPS-1      the base PRA Page 111 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                        1BVPS-1 Final Resolution                 Impact to Fire ID   Requirement  Level        Closed                                                                                    PRA This F&O was entered into the BVPS        Quantification Notebook, Revision 5,     model prior to Corrective Action Program as CA 02-       Section 1.5.6 "Results of Containment    building the 09043-26 (Reference 16) to track and      Performance Analysis."                   Fire PRA.
resolve the issues. The suggested PRA Peer Review Team resolution to this observation was not addressed in the BV2REV3B PRA model update, but will be evaluated sometime later in a future PRA model update.
This update has not yet been completed. At the time, it was a "C" level F&O but the PRA standard raises the requirements for PRA quality and this F&O is now a "B" level.
LE-  LE-G5         B           Y      Limitations of the LERF analysis are      Section "Limitations of the Level 2      No impact to G5-                                   identified throughout the BV2 Level 2     Model" has been added to the Level 2     Fire PRA, 01                                    notebook. However, they need to be        LERF Analysis Notebook to include        because this gathered into a single location to        limitations of the Level 2 analysis. issue was facilitate future usage.                                                           addressed in the base PRA model prior to building the Fire PRA.
LE- LE-B3         C           Y      In Section 2.1 of the LERF Notebook, it   Level 2 LERF Analysis Notebook           No impact to B3-                                  is stated that MAAP, STCP, and            Section 2.1 "Guidelines on Grouping      Fire PRA, 01                                   MELCOR are used to characterize the       Core Damage Sequences into Plant         because this timing of important events. There is no   Damage States Based on Their             issue was evidence that STCP and MELCOR are         Accident Progression Attributes" has     addressed in ever used.                                been updated to include a discussion     the base PRA of the codes used and their applicable   model prior to analyses.                                building the I                                        I_Fire PRA.
Page 112 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                Impact to Fire ID  Requirement  Level        Closed                                                                                 PRA YIN LE- LE-D3        C            Y      The LERF assessment for ISLOCA is        The ISLOCA analysis is reported in     No impact to D3-                                  self contained in the Appendix D of the  the Initiating Event Notebook. The     Fire PRA, 02                                   Initiating Event Analysis notebook.      Level 2 LERF Analysis notebook         because this There is no reference to the ISLOCA      contains a pointer to the ISLOCA       issue was assessment in the LERF notebook. It is   analysis in Section 1.2                addressed in not readily apparent from reading the    "Interrelationship with Other Parts of the base PRA LERF notebook that an ISLOCA             PRA."                                  model prior to assessment was done.                                                            building the Fire PRA.
Qu- QU-F4, QU-   A            Y      The Revision 3B Quantification           Documentation of a more rigorous       No impact to F4- E4, IE-D3                        notebook Section 5 states that the PRA   uncertainty analysis for the Beaver    Fire PRA, 01                                   notebooks..."include an estimation of    Valley Unit 1 PRA model is presented   because this the uncertainty introduced by the data   in Section 5 of the Quantification     issue was used to quantify the PRA model...This    Notebook                               addressed in uncertainty estimation does not,                                                the base PRA however, reflect possible effects on the Westinghouse has provided support      model prior to results from other sources of            for the BVPS-1 Revision 5 uncertainty  building the uncertainty. Such sources may include    analysis that is documented in         Fire PRA.
such things as: optimism or pessimism    "Transmittal of the Beaver Valley in definitions of sequence, component,   Power Station Unit 1 PRA Notebook or human action success criteria;        Uncertainty Analysis," LTR-RAM-II-limitations in sequence models due to     10-052, December 21, 2010.
simplifications (for example, not modeling available systems or equipment) made to facilitate quantification; uncertainty in defining human response within the emergency procedures...; degree of completeness in selection of initiating events; assumptions regarding phenomenology or structures, systems, and components (SSC) behavior under accident conditions... While it is difficult to Page 113 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance   Status Fact & Observation                         BVPS-1 Final Resolution Impact to Fire ID  Requirement  Level          Closed                                                                    PRA I YIN quantify the effects of such sources of uncertainty, it is important to recognize and evaluate them because there may be specific PRA applications where their effects may have a significant influence on the results.
QU-F4 requires that these sources of uncertainty be characterized regardless of the difficulty of the evaluation. By Beaver Valley's own admission (above),
it is important to recognize and evaluate them because there may be specific PRA applications where their effects may have a significant influence on the results.
Furthermore, the documentation provided in Chapter 5 of the Quantification notebook makes a start at identifying the sources of model uncertainty. PWROG guidance suggests the number of identified sources of uncertainty typically is on the order of 50 items. it is also suggested the BVPS perform a more rigorous search to complete a fairly complete list of sources of uncertainty.
Page 114 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                          BVPS-1 Final Resolution                   Impact to Fire ID    Requirement   Level       Closed                                                                                       PRA Y/N QU-   QU-B9         B           Y      Component boundary conditions are not       A table of component boundaries was       No impact to B9-                                    well defined. The Data Analysis             added to section A.4 of the Unit 1        Fire PRA, 01                                     Notebook, as well as several system         PRA Data Analysis Notebook.               because this notebooks (AFW & SWS) were                                                            issue was reviewed and there is no discussion of                                                addressed in component boundary (a pump fail to                                                    the base PRA start, for example.. .does the component                                              model prior to boundary include the local circuitry?).                                               building the There are assumptions made regarding                                                  Fire PRA.
system boundaries, but no discussion of component boundaries. As a result, module definitions can not be determined.
QU-   QU-F4, QU-    B           Y      A detailed description of the RISKMAN       Documentation of the RISKMAN              No impact to F4-   F5                               quantification process is provided.         software quantification limitations are   Fire PRA, 02                                     However, the Revision 3B                    presented in Appendix A, Section          because this Quantification notebook does not            A.1.1 "RISKMAN Software                   issue was discuss limitations in the methodology. Limitations" of the Quantification        addressed in Notebook                                  the base PRA model prior to building the Fire PRA.
QU-   QU-D5a        B           Y      Significant contributors to CDF have        Documentation of the significant          No impact to D5a-                                  been identified, but there is no            contributors to CDF, including            Fire PRA, 01                                     identification of SSCs and operator         initiating events, accident sequences,    because this actions that contribute to initiating event basic events (containing common           issue was frequencies and event mitigation            cause failures), components,              addressed in systems, and operator actions are         the base PRA included in Section 3 "Results" of the    model prior to Quantification notebook. The System building the Notebooks also provide information        Fire PRA.
on SSC and operator action (i.e.,       I Page 115 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                          BVPS-1 Final Resolution                    Impact to Fire ID  Requirement   Level        Closed                                                                                          PRA Y/N basic event) contribution to initiating event frequencies and event mitigation, in the cutset listing reports.
QU- QU-F6         B            Y        Beaver Valley does list important           The definition of significant accident     No impact to F6-                                     operator action basic events; however,      sequences is provided in Section 3.1       Fire PRA, 01                                      there is no documented definition of        of the Quantification Notebook.            because this "significant". The Revision 3B              Section 3.1.4 provides the definition of   issue was Quantification notebook lists top           significant systems. The top 10 basic      addressed in accident sequences but provides no          events, components, and operator           the base PRA definition of whether they are              actions ranked by Birnbaum                 model prior to "significant" or not. The only discussion   importance are also considered             building the is that there is "no single sequence        significant.                               Fire PRA.
makes up a large fraction of the CDF".
The Revision 3B Quantification notebook states the following definition for important systems: "The system rankings for determining High Importance is based on having an F-V Importance greater than 5.OE-02 or a RAW greater than 10, while the Low Importance is based on having an F V Importance less than 5.OE-03 and a RAW less than 2. Medium Importance systems are comprised of everything else in between these importance measures." This definition agrees with the Regulatory Guide 1.200 definition I for "significant contributors." However,  I Page 116 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                         1BVPS-1 Final Resolution                  Impact to Fire ID   Requirement Level        Closed                                                                                      PRA YIN there is no documented justification (no reference to a standard definition, such as R.G. 1.200 or the EPRI PRA Applications Guide).
QU-  QU-D5b       C           Y      The BVPS-2 system importance               Documentation of the basic event and No impact to D5-                                  rankings are based on component            component importances are provided        Fire PRA, 02                                   importances; however there is no           in Section 3.1.3 "Basic Event and         because this specific discussion of component or        Component Importance Rankings," of issue was basic event importances (excluding         the Quantification Notebook. A            addressed in operator actions).                         complete listing of CDF importance        the base PRA measures for all basic events and         model prior to components is provided in the linked      building the files "CDF Basic Event                    Fire PRA.
Importance.xls" and "BV1REV5 CDF I Component Importance.xls."              I SC- SC-A5        B           Y      This SR requires that for sequences in     A discussion has been added in the        No impact to A5-                                  which stable plant conditions would not    medium LOCA Top Event MU to               Fire PRA, 01                                   be achieved by 24 hr using the modeled address containment flooding and             because this plant equipment and human actions,        supply of make water. Containment         issue was PERFORM additional evaluation or          flooding is a severe accident             addressed in modeling by using an appropriate          mitigating strategy used to flood up to the base PRA technique.                                the lower head of the RPV to              model prior to significantly delay, and possibly         building the prevent vessel failure. The               Fire PRA.
Page 117 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance   Status  Fact & Observation                         BVPS-1 Final Resolution                  Impact to Fire ID  Requirement   Level          Closed                                                                                      PRA I YIN    _
consequences of containment flooding have been addressed in BVPS-1 SAMG CA-5, "Containment Water Level and Volume," to determine when water levels are jeopardizing vital equipment and monitoring capabilities. A review of Figures 1 & 2 and Table 6 of this document reveals that no significant core damage mitigating equipment or instrumentation would be impacted, even if 3 RWST volumes are injected.
There is an unlimited supply of makeup water via the Ohio River.
The MU top event for medium LOCA           Furthermore, if a significant volume of and Small LOCA/General Transient           river water is added to the Spent Fuel uses RWST makeup as part of the            Pool, makeup procedure 1OM-7.4.Q success path when recirculation has        recommends the addition of boric acid failed. While a mission time of 24 hours   to the Spent Fuel Pool to maintain is assumed, the plant is not at a safe     adequate shutdown margin.
stable state because another action is     Therefore, at BVPS actions to add required for long term success. The        makeup to the RWST and use the RWST refill results in additional water to  HHSI pumps in SI injection mode for the containment which eventually will      continued RCS makeup are result in the design basis flooding level  determined to result in a safe stable being exceeded and the potential for        plant condition. This would be true for subsequent loss of instrumentation and     all accidents identified in the F&O control. The impact of continued RWST       (i.e., medium LOCA, small LOCA, makeup and injection into containment      General Transient, SGTR, and needs to be discussed in relation to the    ISLOCA).
achievement of a safe stable state I              I where no additional operator actions Page 118 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance    Status Fact & Observation                            BVPS-1 Final Resolution              Impact to Fire ID  Requirement    Level           Closed                                                                                    PRA IY/N    I are required.
A similar situation exists for SGTR and ISLOCA where RWST refill is being used to maintain core cooling, but the justification for mission time of only 24 hours is not apparent given that the plant is not in a safe stable state by traditional definitions.
~4.              .t              I SC- SC-C2          B               Y        No discussion of the limitations of the     Section "MAAP-DBA Limitations" has   No impact to C2-                                         MAAP code for Success Criteria are          been added to the Success Criteria   Fire PRA, 01                                          provided in the Success Criteria            Analysis Notebook to identify the    because this Notebook. Two known limitations are         limitations of the MAAP-DBA code. issue was the use of MAAP for early phase large                                            addressed in LOCAs and the use of MAAP for SG                                                 the base PRA dryout assessments without                                                       model prior to benchmarking to design basis codes                                               building the (e.g., bleed and feed initiation). It was                                        Fire PRA.
observed in the Success Criteria Notebook that MAAP runs were made to justify only 1 accumulator (but that 2 of 2 intact accumulators appear to have been actually used as stated to be used in Section 3.1 of the Notebook). It is recommended that a discussion of MAAP limitations (similar to that provided in the EPRI assessment for MAAP 3) be documented or referenced I              A.        I in the Success Criteria Notebook.        I                                    =
Page 119 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                         BVPS-1 Final Resolution               Impact to Fire ID    Requirement  Level        Closed                                                                                  PRA Y/N                                              _
SC-   SC-A5        C            Y      The success criteria for top event WM      A discussion has been added to the    No impact to A5-                                    for the SGTR states that 400 gpm           Success Criteria Analysis Notebook in Fire PRA, 02                                     makeup to the RWST is sufficient to        Section 3.5 "Steam Generator Tube     because this maintain HHSI for RCS inventory            Rupture" Top Event WM to address      issue was control at full RCS pressure despite       RWST makeup.                          addressed in leakage through a ruptured SG tube.                                              the base PRA model prior to The maximum RCS inventory loss                                                   building the through a single SGTR is on the order                                            Fire PRA.
of 600 gpm if the primary side is at normal operating pressure and the secondary side of the SG is not depressurized. This is in excess of the 400 gpm makeup and therefore appears to invalidate the success criteria as stated. Also, ifcontinued HHSI at full system pressure is required, SG overfill is likely to occur and the SG will be depressurized and the leakage through the ruptured tube I                                  will even be higher.
SC-   SC-B1         C           Y      Reviewer Note R7 for TH states that        Section "MAAP-DBA Limitations" has    No impact to B1-                                    MAAP limitations were observed and         been added to the Success Criteria    Fire PRA, 01                                     MAAP was not used for Large LOCA           Analysis Notebook to identify the     because this early success criteria such as             limitations of the MAAP-DBA code. issue was accumulators. It was observed in the                                             addressed in Success Criteria Notebook that MAAP                                              the base PRA runs were made to justify only 1                                                 model prior to accumulator but that 2 of 2 intact                                               building the accumulators was stated to be used in                                            Fire PRA.
Section 3.1 of the Notebook. This may be confusing for future use because no discussion of MAAP limitations is        I Page 120 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution               Impact to Fire ID  Requirement  Level        Closed                                                                                 PRA YIN presented in the Appendix containing the MAAP analyses (e.g., at page C-8 of the U2 Success Criteria Notebook).
SC- SC-B5        C            Y      The ASME PRA requirement for SC-B5        Attachment D has been added to the    No impact to B5-                                  includes the possibility of comparison to Success Criteria Analysis Notebook to Fire PRA, 01                                   check the reasonableness of the           compare the Beaver Valley Unit 1      because this success criteria. It is recommended       results with North Anna Unit 1.       issue was that such as effort be undertaken,        Furthermore, the Beaver Valley PRA    addressed in possibly as a PWROG or EPRI effort.       model success criteria developed      the base PRA using MAAP were compared with the     model prior to NUREG-1953 Surry success criteria     building the (a similar plant), which used the     Fire PRA.
MELCOR computer code and were found to be in  good agreement.
SC- SC-Cl, SY-    C           Y      The ASME PRA Standard for SC-Cl           Section "System Success Criteria"     No impact to C1- C1                               requires that Success Criteria be         has been added to the Success         Fire PRA, 02                                   documented in a manner that facilitates   Criteria Analysis Notebook to show    because this applications, upgrades, and peer          where the system specific success     issue was reviews. The current state of the BVPS    criteria are contained in each system addressed in PRA Success Criteria is that the         notebook.                             the base PRA accident sequence success criteria are                                          model prior to Page 121 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                             BVPS-1 Final Resolution                 Impact to Fire ID   Require m en t Level        Closed                                                                                        PRA Y/N gathered in the Success Criteria              This was believed to be the best place   building the Notebook, but other success     criteria are  to locate support system success         Fire PRA.
scattered about though the PRA.               criteria.
Examples include the SW success criteria and ISLOCA success criteria for U1. It is recommended that FENOC consider gathering all success criteria in the Success Criteria Notebook to facilitate future usage.
SC-  SC-B1          S            Y      CCIII of the standard requires that plant      No response required for F&O SC-B1-     No impact to B1-                                     specific analyses be used to determine         02.                                     Fire PRA, 02                                      success criteria with plant specific                                                   because this analyses. The large number of MAAP                                                     was identified analyses for success criteria meet this                                                as a strength of requirement and the BVPS U1 and U2                                                     the model.
PRAs are considered to be exemplary in this respect.
SY- SY-A14, SY-     B            Y      The DRAFT Revision 4 System                    Instances of excluded failure modes     No impact to A14- A12, SY-Cl                         notebooks (AFW, SWS, CCS, CCP,                 and contributors to unavailability for  Fire PRA, 01                                      MFW were reviewed) discuss failure             the applicable systems were reviewed    because this modes and contributors to system               and compiled into a single location in  issue was unavailability and unreliability that are      their respective System Notebooks.      addressed in excluded from the systems analysis.            When warranted, justification for the   the base PRA However, the SY-A14 criteria does not          excluded failure mode or unavailability model prior to appear to have been applied                    contributor was made more thorough. building the consistently throughout the analysis.          This information is located in the      Fire PRA.
The only exceptions found where the            Excluded Failure Modes and SY-A14 criteria are explicitly met is in       Unavailability Contributors section of the CCS notebook, Section 14, c,               the notebooks.
Assumption #2, and the AFW notebook Section 14, c, Assumption #3. Insome instances, such as the CCP notebook Section 14, c, Assumption #1, there          II Page 122 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance  Status Fact & Observation                       BVPS-1 Final Resolution              Impact to Fire ID  Requirement  Level         Closed                                                                               PRA was no explanation given for why the contributor was not modeled.
SY- SY-Ci         B           IY      In providing the response to peer review The Common Cause section of the      No impact to Cl-                                   F&O DA-09, which deals with providing    System Notebooks now reference the   Fire PRA, 01                                    documentation of the CCF groupings,      Common Cause Modeling section,       because this Beaver Valley noted that the Systems     Table A-I, and Table 1 of the        issue was Analysis Overview and Guidance           Systems Analysis Overview and        addressed in notebook provides the process used to    Guidance Notebook to thoroughly      the base PRA identify CCF groupings. The response     document the methodology and         model prior to further suggests details of the common   grouping of the common cause         building the cause groups that were retained in the   modeled in the PRA.                  Fire PRA.
PRA system models and presented in Appendix C of the BVPS Unit 2 PRA System Notebooks, under the common cause sections of the RISKMAN System Notebook files are adequately documented and can be found by knowledgeable personnel.
S Page 123 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance   Status   Fact & Observation                            BVPS-1 Final Resolution Impact to Fire ID  Requirement Level          Closed                                                                         PRA I Y/N    I The reviewer agrees that one can review Appendix C of the Systems notebooks and see what the CCF groupings are and how the CCF probabilities were generated. The reviewer also agrees that high level guidance is provided in the Systems Analysis Overview and Guidance notebook. However, it appears a link between the two documents is missing.
For example, the guidance states
                                        'When identical, nondiverse, and active components are used to provide redundancy, they should be considered for assignment to common cause groups, one group for each identical redundant component". When the Systems notebook Appendix C is reviewed, the components contained in the CCF group is clearly identified, but there is no documentation that states that those components are "identical, and/or non-diverse" or used to provide redundancy.
Further examination of other sections System notebooks (such as Section 3 "System Success Criteria", or Section 6 "Operating Features" would lead a reviewer to find this type of information.
But this documentation is not always       I Page 124 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                Impact to Fire ID   Requirement  Level        Closed                                                                                  PRA Y/N intuitively obvious and makes peer review difficult at times.
SY-  SY-Al 1      C            Y      The system notebooks do not              An additional response has been         No impact to All-                                  specifically discuss the dependencies     added to the evaluations of the areas  Fire PRA, 01                                    that may be present regarding HVAC /      that are represented by the actual top because this room cooling. However, review of the      event equipment whether the HVAC       issue was HVAC notebook identified the various      dependency is required or not and is   addressed in spatial locations that may require HVAC   located in Support Systems section in  the base PRA and indicated the various analyses that   the system notebooks.                  model prior to have been completed to either require                                            building the HVAC dependencies or not.                                                        Fire PRA.
SY-  SY-B1        C            Y      At the time of the BVPS Unit 2 common     Up-to-date generic MGL CCF data        No impact to B1-                                   cause MGL data update during              has been updated in PRA-BV1-AL-        Fire PRA, 01                                    Revision 3, the NRC update to             R05 using WCAP-16672-P (Section        because this NUREG/CR-5497 was still not               3.6 and Table C-5 in the Data          issue was available. As such, a decision was        Analysis Notebook). In June 2008,      addressed in made during the update process to         Westinghouse issued WCAP-16672-P       the base PRA keep the existing generic MGL data,       which covers 1980 - 2003 in order to   model prior to which is almost exclusively based on      provide guidance to address the        building the the PLG generic database dated circa      concerns that were raised regarding    Fire PRA.
1989. There is no documentation to       the consistency and correctness of illustrate that the Beaver Valley         the CCF events included in the NRC considered NUREG/CR-5497 during the       CCF database. The WCAP data Revision 4 PRA update.                    source contains CCF parameter estimates for the majority of risk-significant components whose performance are potentially applicable to PWROG utilities only in the U.S.
1 designed by either Westinghouse or Page 125 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution                  Impact to Fire ID  Require m en t Level        Closed                                                                                    PRA YIN Combustion Engineering. The parameter estimates for failure modes of significant components that are generally included in the PRA are provided for the Alpha factors that are converted to the Multiple Greek Letter approach (MGL) by the method in NUREG/CR-5485 and to allow for quantifying CCF probabilities.
Sy- SY-B7          C            Y      The Service cooling water system          The Miscellaneous Top Events             No impact to B7-                                    notebook assumption #7 lists 10           Notebook, Top Event OC models the        Fire PRA, 01                                     minutes to trip the RCPs on loss of       operator actions to trip the RCPs        because this cooling. However, in the Miscellaneous    during situations that exist for greater issue was system notebook, top event OC has 5       than 5 minutes, in which either CCR is   addressed in minutes to trip the RCPs. Note, this time lost to the RCPs and seal injection is   the base PRA might be important in quantifying HEP     maintained, or both RCP seal             model prior to for RCP trip.                             injection and thermal barrier cooling    building the are lost. Both of these conditions       Fire PRA.
would be covered in the abnormal operating procedure 1OM-53C.4.1.6.8 "Abnormal RCP Operation", and RCP parameters would be monitored to identify situations that warrant an immediate RCP shutdown.
Page 126 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting.      Significance     Status    Fact & Observation                        BVPS-1 Final Resolution                   Impact to Fire ID    Requirement       Level           Closed                                                                                        PRA YIN If either of these conditions exist for greater than 5 minutes, the human reliability analysis for operator actions OPROC1 (loss of CCR) and OPROC2 (Loss of RCP seal Cooling) assume that the operators would trip the RCPs at 5 minutes, and that the RCPs seals would be damaged in 13 minutes if they were not tripped, leading to a 480 gpm per RCP seal LOCA. These timing assumptions and consequences are based on BVPS AOPs and WCAP-16141.
SY-   SY-Cl             C               Y         The Beaver Valley Unit 2 system           System Engineers reviewed the             No impact to Cl-                                               notebooks have no indication of system system notebooks for PRA-BV1 -AL-            Fire PRA, 02                                                engineering reviews. These reviews        R05, in which they had to present         because this help ensure that systems are model in     comments and provide input for the        issue was accordance with day-to-day plant          top event system review. System           addressed in operations and additionally expand the    Engineering comments have been            the base PRA PSA knowledge of the system               incorporated into BVPS-1 PRA              model prior to engineers,                                corresponding system notebooks. A         building the table that contains the comments is       Fire PRA.
located in Appendix B in the System 1 Analysis Overview for BVPS-1.
SY-  SY-B5, SY-        D               Y         The system notebooks do not               An additional response has been           No impact to B5-  B6, SY-B10,                                 specifically discuss the dependencies     added to the evaluations of the areas     Fire PRA, 01   SY-B11                                      that may be present regarding HVAC I      that are represented by the actual top    because this room cooling. However, review of the      event equipment whether the HVAC          issue was HVAC notebook identified the various      dependency is required or not and is      addressed in spatial locations that may require HVAC located in Support Systems section in       the base PRA and indicated the various analyses that   the system notebooks.                     model prior to have been completed to either require                                               building the
______________    _____________ A.        A.
Page 127 of 301

Table 1-2. Summary of BVPS-1 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance   Status   Fact & Observation            BVPS-1 Final Resolution             Impact to Fire ID   Requirement   Level         Closed                                                                     PRA HVAC dependencies or not. Since this &O is essentially the    Fire PRA.
same as F&O SY-Al 1-01, it was also I_                         I        I                               resolved by it Page 128 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                       BVPS-1 Final Resolution                 Impact to Fire ID   Requirement   Level        Closed                                                                                  PRA Y/N HR-  HR-D5,        Finding      Y      BVPS does not have a written             Section 2.2 of the HRA Notebook         No impact to Fire PR-                                    process for evaluating dependencies      documents the methodology and           PRA, because 001                                    between multiple HEPs occurring in a     evaluation of the pre-initiator HEPs. A this issue was single accident and does not provide     summary of the EPRI HRA Calculator      addressed in the a summary of HEPs that were              results can be found in Table 3.5       base PRA model explicitly evaluated for dependencies    which supplements the detailed          prior to building and the associated levels of             calculations documented in Appendix     the Fire PRA.
dependencies and joint HEPS. The         E. Section 2.3 documents the BVPS HRA notebooks do not have a         methodology developed to evaluate single summary table of the              the dependency between multiple preinitiator human actions and the       HEPs.
HR-G7,                            documentation of the evaluation of HR-H3,                            pre-initiator human actions in the       Section 2.3 of the HRA notebook has system notebooks, which make it          been created to document the difficult to identify which actions were process employing the EPRI HRA actually evaluated,                      calculator that is used to complete the dependency analysis evaluation (See F&O HR-12-01 in Section 6).
HR-I1, HR-12(d)3 HR- HR-G6, HR-    Finding      Y      BVPS does not appear to have             An internal consistency check for pre-  No impact to Fire PR- 12                                evaluated their HEPs for internal        initiator HEPs is documented in         PRA, because 002                                   consistency consistent with the          Section 3.4 of the Unit 1 HRA           this issue was requirements of HR-G6 and does not       notebook.                               addressed in the have a documented process to do so.                                              base PRA model The original post-initiator HRA was     prior to building developed using the SLIM/FLIM           the Fire PRA.
process, and as such were grouped with respect to similar performance shaping factors and weights (e.g.,
actions where time and preceding actions are most important were Page 129 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact& Observation             BVPS-1 Final Resolution                Impact to Fire ID  Requirement  Level        Closed                                                                      PRA YIN grouped together) to have internal consistency during the HEP development. As a final check of overall consistency, the HEPs from each group were then compared with those of other groups to determine if the differences in the HEPs were warranted by the differences in the scenarios and PSF ratings.
The BV1 REV4 PRA model revised the HRA methodology from the SLIM/FLIM process to the EPRI HRA Calculator. The HRA Calculator is a software program that is designed to implement consistency within the field of human action analysis by creating a standard methodology for quantification and documentation of HEPs in the context of the PRA. After this conversion was complete, the resulting HEP values were then compared to the previous BV1 REV3 SLIM/FLIM HRA model (see Table 3-4 of the HRA Notebook, Revision 1 drafted for BV1 REV4), to verify consistency in overall trends between events.
Since these BV1 REV3 PRA Model SLIM/FLIM HEPs were compared to the BV1REV4 PRA Model HRA Calculator HEPs to check their Page 130 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact& Observation                       BVPS-1 Final Resolution                 Impact to Fire ID  Requirement   Level        Closed                                                                                 PRA reasonableness, there is a de facto consistency check in the HEPs.
HR- HR-D2, HR-    Finding      Y      The method for quantifying pre-         Pre-initiators are now quantified using No impact to Fire PR- D3, HR-D4,                        initiator misalignment errors as        the THERP methodology as                PRA, because 003 HR-I1, HR-12                      described on page 8 of the "Beaver      presented in the EPRI HRA               this issue was Valley Power Station Unit 2 PRA         Calculator. This is documented in       addressed in the Notebook - Human Reliability            Sections 2.2 & 3.4 and Table 3-5 of     base PRA model Analysis," Revision 2, dated 10/01/07,  the HRA Notebook. The pre-initiator     prior to building relies on the use of a generic Error of human error probabilities were          the Fire PRA.
Omission rate that does not reflect     determined using BVPS operator any detailed assessment of the HEPs. input and BVPS specific procedures The process also does not consider      and processes. The process now the quality of plant-specific written   considers the plant specific written procedures, administrative controls or  procedures, administration controls, the man-machine interface and does      and man-machine interface.
not include an explicit assessment of the potential for recovery that         A list of the pre-initiator HFEs and specifically delineates which           their probabilities was added to procedures and processes influence      Section 3 in Table 3 5.
the potential for identification and recovery. Furthermore, the method for quantifying post-maintenance miscalibrations relies on a single generic error of omission rate.
A complication in reviewing the pre-initiator Human Failure Events (HFEs)
Page 131 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting.             Significance   Status   Fact& Observation                        BVPS-1 Final Resolution Impact to Fire ID  Requirement             Level          Closed                                                                    PRA I Y/N    I was that the HRA notebook does not include a list of the pre-initiator HFEs or their probabilities. The system notebooks provide evidence of the search for and identification of misalignments but they do not present a list of such events or their probabilities.
_____________________ &              I Page 132 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                        BVPS-1 Final Resolution              Impact to Fire ID   Requirement   Level        Closed                                                                                PRA W/N HR-  HR-C2         Finding      Y      Post-maintenance misalignments            Section 2.2 and Appendix C of the    No impact to Fire PR-                                    were excluded for normally operating      HRA Notebook document the review     PRA, because 004                                    system based on the assumption       that of BVPS procedures (OSTs, BVTs,      this issue was misalignments on normally operating       and MSPs) to identify potential      addressed in the systems would be quickly detected         misalignments. Section 2.2 and       base PRA model and corrected. Post-maintenance           Appendix D of the HRA Notebook       prior to building unavailabilities were included for        documents the review of historical   the Fire PRA.
standby systems as appropriate,           event data for misalignment However, nowhere in the HRA               identification. A search of the BVPS notebook or the system notebooks          1&2 Corrective Action Program (CAP) that were reviewed was there any          was performed to identify pre-indication that BVPS had performed a initiators that have occurred at BVPS.
review of their operating/maintenance     A review was also performed with the data to look for post-maintenance         BVPS operator.
misalignments.
HR-  HR-13         Finding      Y      The BVPS HRA is documented in the         Section 7 of the Unit 1 HRA notebook No impact to Fire PR-                                   "Beaver Valley Power Station Unit 2       was added to document HRA            PRA, because 005                                    PRA Notebook - Human Reliability          assumptions.                         this issue was Analysis", Revision 2, dated 10/01/07.                                         addressed in the This notebook does not have an                                                 base PRA model explicit assumptions section to identify                                       prior to building and characterize assumptions. A                                                the Fire PRA.
review of this notebook revealed assumptions scattered throughout the text.
HR- HR-F2         Finding      Y      In reviewing the set of post-initiator    The present BV1 REV5 value for HFE   No impact to Fire PR-                                   HFEs in Table 3-1, It was noted that      ZHEMA2 is 258 minutes = 4.3 hours    PRA, because 006                                   for the HFE ZHEMA2, the specified         (based on MAAP Run Ul_SB02)          this issue was time window, 13.26 hours, was not         which is consistently stated in both addressed in the consistent with the information           Table 3-1 and Appendix B of this     base PRA model provided in the "Success Criteria/        notebook.                            prior to building Basis of Timing" for that HFE. A                                               the Fire PRA.
review of the referenced MAAP case II Page 133 of 301

Table 1-3. Summary of BVPS-1 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-1 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                   PRA YIN indicates that the 13.26 hours is the appropriate timing. Furthermore, continued review of table 3-1 indicated that this seemed to be an isolated event.
HR- HR-B1        Finding      Y      In general, BVPS excludes virtually all ASME/CNRM Inquiry 09-56 states            No impact to Fire PR-                                  miscalibration events based on the      that miscalibrations are included in      PRA, because 007                                  assumption that events related to       the Common Cause Failure (CCF)            this issue was instrument miscalibrations are          events for the NRC CCF Database.          addressed in the captured in the equipment failure rate  Since BVPS includes miscalibrations       base PRA model data and the On-line Maintenance        in the CCF events, it would be double     prior to building program precludes common-cause          counting to also include them as pre-     the Fire PRA.
miscalibration by scheduling work on    initiators. As a result, it is believed opposite trains in different weeks. that BVPS's current treatment of Post-maintenance misalignments          miscalibrations as part of the CCF were excluded for normally operating    events and not pre-initiators meets system based on the assumption that     Capability Category II (instead of misalignments on normally operating     Capability Category I).
systems would be quickly detected and corrected. While these rules        An exception to this is the SSPS seem reasonable, they are applied to    model, which did include instrument classes of maintenance and test         string miscalibration errors in the fault activities to screen them from further  tree model.
consideration. This is sufficient for Capability Category I but not for       A search of the Corrective Action Capability Category 1I.                 database in April 2010 did not reveal any such miscalibration errors between trains at Beaver Valley Unit 1 to date.
Page 134 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact &Observation               BVPS-1 Final Resolution                     Impact to Fire PRA ID      Requirement Level        Closed YIN IFPP-   IFPP-B1,    Finding      Y      The documentation               This F&O was entered into the BVPS          This issue remains Bl-01   IFSO-B1,                        generally does not facilitate   Notification System as BV1 Notification     open in the BVPS-1 IFSN-B1,                        peer review. The technical      #600689090, Task 17, to track and           Fire PRA model which IFEV-B1,                        aspects of the analysis are     resolve the issues. As a resolution to      uses the BVI REV5 IFQU-B1                         documented in a manner          this IFPRA Peer Review finding, Section     model as its basis; that cannot be readily          2 of the documentation was revised in       however there is no understood by individuals       order to facilitate the Peer Review         impact to the Fire PRA outside the staff. The          process. Figure 2-1 provides an             because internal fire ordering of the                 overview of the ASME/ANS PRA                initiators and flood documentation is                Standard requirements and their             initiators are mutually significantly different from    relationships to the analysis and           exclusive and have no the standard; a detailed        information contained in the various        effect on each other.
graphical roadmap of the        sections/appendices/tables of the report.
analysis process would          This documentation mapping is               Furthermore, the enable peer reviewers to        consistent with that presented in the       BVPS-1 Fire PRA relate the order of the         EPRI Final Report 1019194, Guidelines       working model uses documentation to the            for Performance of Internal Flooding        BV1 REV5A as its standard.                       Probabilistic Risk Assessment               basis, so this F&O will be resolved when NFPA 805 is I_                                                                                                          implemented.
IFPP-  IFPP-B2     Finding      Y      The process described the       This F&O was entered into the BVPS          This issue remains B2-01                                  identification of site          Notification System as BV1 Notification     open in the BVPS-1 buildings and flood areas,      #600689090, Task 6, to track and            Fire PRA model which but the documentation does      resolve the issues. As a resolution to      uses the BV1 REV5 not clearly establish the       this IFPRA Peer Review finding, the         model as its basis; basis for the set of buildings   intent of Table 3-1 was clarified prior to however there is no considered in the analysis. Section 3.1 (Identify Flood Areas) to       impact to the Fire PRA The references to source        plainly indicate the table represents a     because internal fire material are not sufficiently   complete list of plant                      initiators and flood specific to allow replication    buildings/structures based on              initiators are mutually of the process. The              referenced materials and that it includes  exclusive and have no documentation will be           the preliminary building screening.         effect on each other.
Page 135 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review- Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation             BVPS-1 Final Resolution                    Impact to Fire PRA ID      Requirement Level        Closed Y/N easier to follow if the basis for the selection of buildings                                            Furthermore, the considered in the analysis is                                             BVPS-1 Fire PRA enhanced. There is                                                        working model uses reference to review of plant                                              BV1 REV5A as its documentation including the                                               basis, so this F&O will fire analysis, but no                                                     be resolved when statement that the list of                                                NFPA 805 is buildings in Table 3-1 is the                                             implemented.
complete list of buildings.
IFPP-  IFPP-B3     Finding      Y      The process used to            This F&O was entered into the BVPS         This issue remains B3-01                                  determine the plant             Notification System as BV1 Notification   open in the BVPS-1 partitioning requires some     #600689090, Task 7, to track and           Fire PRA model which level of assumptions            resolve the issues. As a resolution to    uses the BV1 REV5 concerning how the plant       this IFPRA Peer Review finding, plant      model as its basis; partitions are established,     partitioning assumptions were             however there is no The current plant               documented in Section 3.5.                impact to the Fire PRA partitioning has no                                                      because internal fire discussion of the                                                         initiators and flood uncertainties and                                                        initiators are mutually assumptions associated                                                   exclusive and have no with the plant design                                                     effect on each other.
features used to create flood areas.                                                              Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is I implemented.
Page 136 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation               BVPS-1 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed Y/N IFSO-  IFSO-A4     Finding      Y      The potential flooding           This F&O was entered into the BVPS        This issue remains A4-01                                  effects is not listed within     Notification System as BV1 Notification   open in the BVPS-1 any of the tables                #600689090, Task 3, to track and          Fire PRA model which documenting the potential        resolve the issues. As a resolution to    uses the BV1 REV5 flooding sources. The            this IFPRA Peer Review finding, Section model as its basis; ASME/ANS standard                4.2 (Flood Source Failure Mechanisms      however there is no requires the inclusion of the    and Failure Modes Summary) was            impact to the Fire PRA potential flooding               added to specifically address: a) a       because internal fire mechanisms when                  discussion of failure modes and           initiators and flood describing the flood sources     mechanisms associated with each flood     initiators are mutually used in the model.               source with direct reference to latter    exclusive and have no documentation sections for further        effect on each other.
discussion, and b) the EPRI methodology which embeds failures of      Furthermore, the all piping system components as part of BVPS-1 Fire PRA the piping segment failures averaged on working model uses a per linear foot basis. Furthermore,     BV1 REV5A as its Section 4.3 was added to address any      basis, so this F&O will flood source identification assumptions   be resolved when with direct reference to latter           NFPA 805 is documentation sections for further        implemented.
discussion.                             I Page 137 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation              BVPS-1 Final Resolution                   Impact to Fire PRA ID      Requirement Level        Closed YIN IFSO-   IFSO-A5     Finding      Y      This supporting requirement     This F&O was entered into the BVPS        This issue remains A5-01                                   identifies information used     Notification System as BV1 Notification   open in the BVPS-1 to characterize the flooding    #600689090, Task 5, to track and          Fire PRA model which sources. Most of the            resolve the issues. As a resolution to    uses the BV1 REV5 information is provided in      this IFPRA Peer Review finding, all       model as its basis; Sections 4 and 7 of the         normal operating flooding sources         however there is no internal flooding PRA           documented in the analysis (Table 4-1. impact to the Fire PRA reports. The information        Water Sources) have updated system        because internal fire identified by this SR was not   flow information (including normal        initiators and flood provided in its entirety. For   operating temperatures) based on          initiators are mutually example, system                 available information provided in the     exclusive and have no temperatures are not            references noted in the table.            effect on each other.
captured in the documentation and some                                                    Furthermore, the systems (primarily oil) pump                                              BVPS-1 Fire PRA HP and RPM are captured                                                   working model uses but not the flow rates.                                                   BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IFSO-  IFSO-B3     Finding      Y      No clear documentation          This F&O was entered into the BVPS        This issue remains B3-01                                  was provided of related         Notification System as BV1 Notification   open in the BVPS-1 assumptions for the             #600689090, Task 4, to track and          Fire PRA model which identification of flood         resolve the issues. As a resolution to    uses the BV1 REV5 sources. The sources of         this IFPRA Peer Review finding, Section   model as its basis; model uncertainty are           12.4.5 contains a review of the impact of however there is no documented in Section 12        all assumptions mapped to uncertainty     impact to the Fire PRA of the internal flooding PRA    along with sensitivity analysis that was  because internal fire reports, 2294706-R-001,         evaluated. Table 12-7 contains a cross    initiators and flood Rev. 0 and 2294706-R-002,       reference of all the assumptions in the   initiators are mutually Rev. 0, but it could not be     development of the BVPS-1 internal        exclusive and have no determined how these            flooding notebook related to the          effect on each other.
Page 138 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O       Supporting.      Significance    Status Fact & Observation              BVPS-1 Final Resolution                   Impact to Fire PRA ID        Requirement      Level           Closed sources of model                frequency uncertainties in Table 12-2.
uncertainty were connected                                                Furthermore, the to the various assumptions.                                               BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IFSN-      IFSN-A1         Finding         Y      The description of the          This F&O was entered into the BVPS        This issue remains Al-01                                             propagation paths is not        Notification System as BV1 Notification   open in the BVPS-1 complete. Table E-1             #600689090, Task 14, to track and         Fire PRA model which identifies the "source"         resolve the issues. As a resolution to    uses the BV1 REV5 location and the next           this IFPRA Peer Review finding, Section   model as its basis; locations to which it water     7.3 was augmented to clearly explain      however there is no can propagate. To               with an example, the differences in       impact to the Fire PRA determine the complete          Table E-1 and E-2 due to subsuming of     because internal fire propagation path, these         flood propagation paths, and a separate   initiators and flood source/next pairs can be        column was added to Table E-2 to          initiators are mutually combined until the water        indicate all of the flood propagation     exclusive and have no reaches the accumulation        pathways that were subsumed for each      effect on each other.
point (no "next" location). documented flooding scenario so that it However, the scenario           will be clear that all pathways have been Furthermore, the descriptions in Table E-2 do    accounted.                                BVPS-1 Fire PRA not consistently account for                                              working model uses the propagation paths                                                     BV1 REV5A as its identified in Table E-1. For                                              basis, so this F&O will example, scenario PA3C                                                    be resolved when FWLP-3 propagates to                                                     NFPA 805 is
_______  & ______________ I              A.
several locations per Table                                               imDlemented.
Page 139 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation               BVPS-1 Final Resolution                 Impact to Fire PRA ID     Requirement Level        Closed Y/N E-2 (PA-3C, PA-3, PA-31, PA-3H) but Table E-1 indicates that PA-3 can propagate to PA-S2, PA-S6, PA-3G, PA-3A, PA-3B, PA-3C, PA-3H, PA-31; several of these are not accounted for in the propagate path in Table E-2. If the missing locations are not possible due to plant features, that should be stated to complete the accounting.
Other examples of this deficiency were observed (PA4-FWLP-1, PT1-FWLP-1 from Unit 2, and PA1A-FWLP-1, FA1A-FWMP-1 from Unit 1). The propagation paths must account for the various possible flow paths.
Combinations presented in the documentation that are not considered bring into question the completeness of the analysis.
IFSN-  IFSN-B2,    Finding      Y      The process to identify         This F&O was entered into the BVPS      This issue remains B2-01  IFSN-A5,                        scenarios lacks several of      Notification System as BV1 Notification open in the BVPS-1 Page 140 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions BVPS-1 Final Resolution                  Impact to Fire PRA IYN F&O    Supporting. Significance Status Fact & Observation ID     Requirement Level        Closed IFSN-A6                         the suggested areas that        #600689090, Task 15, to track and        Fire PRA model which should be included              resolve the issues. As a resolution to   uses the BV1 REV5 (recognizing that the SR list   this IFPRA Peer Review finding, a        model as its basis; is NOT a required set). The     graphical depiction of the overall flood however there is no propagation pathways            scenario development was provided as     impact to the Fire PRA description is not complete     Figure 7-1 in Section 7.                 because internal fire in that it does not include all                                          initiators and flood potential propagation paths                                              initiators are mutually identified in Table E-1 of the                                           exclusive and have no PRA reports. The impacted                                                effect on each other.
(failed) SSCs for each scenario are not clearly                                                 Furthermore, the referenced (identified as                                                BVPS-1 Fire PRA needing to be "addressed"                                                working model uses in a REMARKS column in                                                   BV1 REV5A as its Table E-2). Assumptions                                                  basis, so this F&O will used in the scenario                                                     be resolved when discussions are incomplete.                                              NFPA 805 is Scenario screening is not                                                implemented.
clearly documented. The documentation has many weaknesses in capturing the suggested types of information to adequately document this topic.
Page 141 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation               BVPS-1 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed Y/N IFSN-  IFSN-B3,    Finding      Y      The use of the Excel VBA         This F&O was entered into the BVPS        This issue remains B3-01  IFSN-A4                         code to predict flow rates       Notification System as BV1 Notification   open in the BVPS-1 and failures of equipment        #600689090, Task 8, to track and          Fire PRA model which has provided a great deal of     resolve the issues. As a resolution to    uses the BV1 REV5 realistic insight to plant flood this IFPRA Peer Review finding, Section   model as its basis; response. Section 9.0 of the     9.5 (Summary of Assumptions) was          however there is no internal flooding PRA            expanded to include Microsoft EXCEL       impact to the Fire PRA reports does not explicitly      VBA program specific assumptions and      because internal fire discuss all assumptions          documentation pointers to flooding        initiators and flood regarding the use of             scenario specific assumptions.            initiators are mutually equations to predict flood                                                 exclusive and have no heights, and the scenarios                                                 effect on each other.
modeled in Appendix Hof the PRA reports have some                                                  Furthermore, the assumptions applied to                                                     BVPS-1 Fire PRA each analysis.                                                             working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is 1 implemented.
Page 142 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review- Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation              BVPS-1 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed YIN I
IFEV-  IFEV-A7     Suggestion   Y        Maintenance and human-          This F&O was entered into the BVPS        This issue remains A7-01                                    induced errors causing a        Notification System as BV1 Notification   open in the BVPS-1 flooding event can be           #600689090, Task 9, to track and          Fire PRA model which important to the overall        resolve the issues. As a resolution to    uses the BV1 REV5 plant risk. A more detailed     this IFPRA Peer Review suggestion, an     model as its basis; analysis of those activities    Operating Manual (OM) procedure           however there is no within the plant that could     review of at-power open maintenance       impact to the Fire PRA lead to a system breach         was produced as Table 7-4 that            because internal fire potential should be             evaluates systems 15, 26, 28, 29, 30,     initiators and flood analyzed. Maintenance           31, and 33 for potential actions on       initiators are mutually activities which could          equipment that could cause human-         exclusive and have no potentially breach              induced flooding scenarios. Some of       effect on each other.
pressurized systems could       the systems are indirectly reviewed lead to internal flooding       based on other systems. The OM            Furthermore, the events. By not evaluating all procedures for the condenser waterbox,      BVPS-1 Fire PRA potential online                CCR heat exchangers, and CCT heat         working model uses maintenance activities for      exchangers are based on a frequency       BV1 REV5A as its the potential breaches, the     that is based on SAP work order record    basis, so this F&O will flood-induced risk              queries. The screening categories for     be resolved when associated with these           the open maintenance and human-           NFPA 805 is activities could be             induced review are shown in Table 7-5. implemented.
underestimated.               I                                         I Page 143 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance    Status Fact & Observation               BVPS-1 Final Resolution                   Impact to Fire PRA ID       Requirement   Level           Closed YIN IFEV-   IFEV-B2       Suggestion      Y      Documentation of the             This F&O was entered into the BVPS        This issue remains B2-01                                        process that identifies          Notification System as BV1 Notification   open in the BVPS-1 applicable flood-induced         #600689090, Task 18, to track and         Fire PRA model which initiating events is required    resolve the issues. As a resolution to    uses the BV1 REV5 to satisfy this SR. The flood    this IFPRA Peer Review suggestion and     model as its basis; scenario frequencies are         as part of an expanded analysis to        however there is no provided in Tables 8-10, F-      address probabilistic pipe failure during impact to the Fire PRA 1, and J-1 of the intemal        the 24 Hours after an initiator and       because internal fire flooding analysis reports        system-based initiators, Section 8.1.3    initiators and flood (2294706-R-001, Rev. 0           and Tables 8-11 and 8-12 illustrate the   initiators are mutually and 2294706-R-002, Rev.          scope of flooding elements (pipe,         exclusive and have no 0). The associated HEPs for expansion joints) contained within the         effect on each other.
isolating the flood and          existing internal events model.
adjustment factors used to                                                 Furthermore, the refine the flood frequencies                                               BVPS-1 Fire PRA are also provided in Table                                                 working model uses F-i. A qualitative screening                                               BV1 REV5A as its value of 1.OE-12 was used.                                                 basis, so this F&O will The process does not                                                       be resolved when clearly identify the                                                       NFPA 805 is relationship of the                                                        implemented.
information provided in the various tables.                I IFEV-    IFEV-B3      Finding         Y      The different values that go     This F&O was entered into the BVPS        This issue remains B3-01                                         into the calculation of the      Notification System as BV1 Notification  open in the BVPS-1 internal flooding initiating    #600689090, Task 10, to track and         Fire PRA model which event frequency are subject       resolve the issues. As a resolution to   uses the BV1 REV5 to uncertainties. These          this IFPRA Peer Review finding, Section   model as its basis; uncertainties need to be         12.4.5 contains a summary of the review  however there is no well documented to address of the impact of all assumptions mapped         impact to the Fire PRA all of the model impacts.        to uncertainty along with sensitivity     because internal fire analysis that was evaluated. Table 12-7   initiators and flood
~.I.                 I              .1 Page 144 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation               BVPS-1 Final Resolution                   Impact to Fire PRA ID     Require m en t Level        Closed Y/N The current flooding             contains a cross reference of all the     initiators are mutually frequency calculations use       assumptions in the development of the     exclusive and have no factors to determine the         BVPS-1 internal flooding notebook         effect on each other.
actual initiating event          related to the frequency uncertainties in frequency used within the        Table 12-2.                               Furthermore, the model. The pipe lengths,                                                   BVPS-1 Fire PRA location factors, directional                                              working model uses factors, and operator action                                               BV1 REV5A as its failures all have some levels                                              basis, so this F&O will of assumptions and                                                         be resolved when uncertainties associated                                                   NFPA 805 is with them. These need to                                                   implemented.
be addressed in order to meet the SR.
Page 145 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact& Observation                BVPS-1 Final Resolution                    Impact to Fire PRA ID     Requirement   Level          Closed Y/N IFQU-  IFQU-A5       Finding        Y        It appears that no inter-HEP     This F&O was entered into the BVPS         This issue remains A5-01                                        dependency analysis              Notification System as BV1 Notification    open in the BVPS-1 (between flood and non-          #600689090, Task 16, to track and          Fire PRA model which flood HEPs) was performed.       resolve the issues. As a resolution to     uses the BV1 REV5 Dependency between HEPs          this IFPRA Peer Review finding, Section    model as its basis; can significantly increase       10.4.6 (Dependencies between Human         however there is no the probabilities of             Interactions) was expanded to reiterate    impact to the Fire PRA combinations of HEPs.            Section 10.4.3 (Screening and Detailed     because internal fire However, Section 10.4 of         Analysis) discussion on the multiplier     initiators and flood the internal flooding PRA        factor applied to HEPs included in the     initiators are mutually reports states                   Internal Events PRA based on such          exclusive and have no "Dependencies between the        factors as the location of the action, the effect on each other.
flood mitigation human           timing of the action, and stress, etc. and actions and the non-flood        to include a discussion of the Riskman     Furthermore, the human actions modeled in         modeling analysis approach in which        BVPS-1 Fire PRA the remaining part of the        human actions included are evaluated       working model uses PRA model were judged to         conditionally based on the success or      BV1 REV5A as its be minimal due to the            failure status of the preceding human      basis, so this F&O will significant difference in the    action(s). As such, dependencies           be resolved when nature of the actions (e.g.,     among the human failure events in the      NFPA 805 is flood mitigation actions         Internal Events model (i.e., non-flood     implemented.
require field investigation by   human actions) were fully accounted.
the auxiliary operators, etc.)
and separation in time, etc.,
and as such no additional dependency treatment was considered needed." An evaluation of the HEP combinations should be documented to demonstrate S              S        S this conclusion.               -
Page 146 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation              BVPS-1 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed YIN IFQU-  IFQU-A7     Finding      Y      Performance of the internal    This F&O was entered into the BVPS         This issue remains A7-01                                  flood events quantification     Notification System as BV1 Notification   open in the BVPS-1 should be consistent with      #600689090, Task 12, to track and          Fire PRA model which the quantification of the       resolve the issues. As a resolution to    uses the BV1 REV5 internal events PRA. The       this IFPRA Peer Review finding,            model as its basis; quantification of the internal  analysis and discussion has been          however there is no flooding requires that          provided for performance of               impact to the Fire PRA applicable requirements         quantification with the applicable        because internal fire from the Internal Events        requirements. QU-B3 requirements          initiators and flood Quantification section be       have been documented in Section           initiators are mutually met. The current section on     12.4.4, Truncation Evaluation. The QU-    exclusive and have no Internal Flooding does not      B7 requirements have been                 effect on each other.
include a discussion of the     documented in Section 12.5.3, Mutually topics addressed in Section     Exclusive Events. QU-Cl & QU-C2           Furthermore, the 2-2.7 of the ASME/ANS           requirements have been documented in      BVPS-1 Fire PRA Combined PRA Standard.          Section 12.5.4, HFE Dependency. QU-       working model uses D1 & QU-D2 requirements have been         BV1 REV5A as its documented in Section 12.5.5              basis, so this F&O will Significant CDF Sequences and             be resolved when Accident Category (for CDF) and           NFPA 805 is Section 12.5.8 Significant LERF           implemented.
Sequences and Accident Category (for LERF). QU-D4 requirements have been documented in Section 12.5.2 Internal Flooding Comparison Between Plants and Table 12-5. QU-D6 requirements have been documented in Sections 12.5.5 - 12.5.7, and 12.3 for significant contributions to CDF. QU-D7 requirements have been documented in Section 12.5.6 for system importance that is based on importance for components and basic events.
Page 147 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status   Fact & Observation              BVPS-1 Final Resolution                  Impact to Fire PRA ID      Requirement Level        Closed Y/N IFQU-   IFQU-A9     Finding      Y        The loss of the CCR heat        This F&O was entered into the BVPS       This issue remains A9-01                                     exchangers in the PRA           Notification System as BV1 Notification  open in the BVPS-1 models have made an             #600689090, Task 19, to track and        Fire PRA model which optimistic assumption           resolve the issues. As a resolution to   uses the BV1 REV5 regarding the survivability of  this IFPRA Peer Review finding, a        model as its basis; cooling to the heat             BVPS Nuclear Engineering Analysis        however there is no exchangers following a          calculation was performed on this        impact to the Fire PRA system breach (see              specific Valve Pit assumption. The       because internal fire scenario VP1-FWLL-1). Use       calculation verified and demonstrated    initiators and flood of this assumption allowed a    that once the Valve Pit floods (in less  initiators are mutually potentially more severe         than 30 seconds), there is adequate      exclusive and have no scenario to be represented      flow to all the necessary heat exchanger effect on each other.
by a less severe scenario,      loads, so only the ruptured header The assumption was that         should be considered failed. Since the   Furthermore, the the vacuum at the inlet to      "A" RW pump is modeled and is the        BVPS-1 Fire PRA the CCR heat exchangers         strongest pump in the current Proto      working model uses would prevent sufficient loss    Flow model, the "A" RW break is         BV1 REV5A as its of cooling water from a         conservative and was hence used in this  basis, so this F&O will break in the piping             calculation. Results of the calculation  be resolved when downstream of the river         are documented in Section 8.4            NFPA 805 is water (RW) check valve in       assumption 2.                            implemented.
the valve pit from failing both trains of RW. This assumption appears to be non-conservative.
IFQU-  IFQU-A10    Suggestion   Y         Internal flooding contribution This F&O was entered into the BVPS       This issue remains Al 0-                                    to LERF should be                Notification System as BV1 Notification open in the BVPS-1 01                                       documented in some way          #600689090, Task 11, to track and        Fire PRA model which so that the apparent             resolve the issues. As a resolution to  uses the BV1 REV5 impacts on LERF from the        this IFPRA Peer Review suggestion,      model as its basis; flooding events could be         Section 12.5.8 contains a review of     however there is no reviewed. The discussion        internal flooding LERF sequences and    impact to the Fire PRA I concerning the impacts on        accident categories which describes     because internal fire Page 148 of 301

Table 1-4. Summary of BVPS-1 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation              BVPS-1 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed YIN                                  [
LERF for internal flooding      impacts that are evaluated in internal    initiators and flood events could be improved to     flooding LERF analysis.                   initiators are mutually discuss flooding impact on                                                exclusive and have no the different features used                                               effect on each other.
to mitigate releases.                                                     Furthermore, the BVPS-1 Fire PRA working model uses BV1 REV5A as its basis, so this F&O will be resolved when NFPA 805 is implemented.
IFQU-  IFQU-B2,    Finding      Y      The process used for            This F&O was entered into the BVPS        This issue remains B2-01  IFQU-B1                         quantification documents        Notification System as BV1 Notification   open in the BVPS-1 the calculation, screening,     #600689090, Task 13, to track and         Fire PRA model which scenarios deleted and           resolve the issues. As a resolution to    uses the BV1 REV5 walkdowns. However, there       this IFPRA Peer Review finding, the       model as its basis; is not enough                   supporting requirements listed in HLR-    however there is no documentation of the            QU-D have been completed in the           impact to the Fire PRA quantification process          internal flooding notebook Section 12.5   because internal fire specifically concerning the     Results and Insights.                     initiators and flood PRA Standard requirements                                                 initiators are mutually listed in HLR-QU-D. The SR                                                exclusive and have no requires that documentation                                               effect on each other.
must be consistent with the requirements described in                                                 Furthermore, the HLR-QU-D. These                                                          BVPS-1 Fire PRA requirements are not                                                     working model uses discussed at any point in                                                 BV1 REV5A as its the internal flooding PRA                                                 basis, so this F&O will reports.                                                                  be resolved when NFPA 805 is I implemented.
Page 149 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting.       Significance       Status    Fact &Observation                                 BVPS-2 Final Resolution      Impact to Fire ID      Requirement 1     Level              Closed                                                                                   PRA I YIN AS-10   AS-12             A                  Y         The BV PRA uses the WOG 2000 seal LOCA            Additional MAAP              No impact to Fire in a way that may be unacceptable to the          uncertainty cases for        PRA, because this NRC for risk based applications. MAAP runs        BVPS-2 were performed        issue was are performed to find the core uncovery times     using pessimistically        addressed in the for various sizes of seal LOCA. If the best       biased values along with     base PRA model estimate MAAP runs show the core is               setting input parameters     prior to building the covered at 24 hours, the sequence is              to their high or low limits. Fire PRA.
considered success. The result is that all        These cases were run out SLOCA sizes except the 480 gpm leak have          to 48-hours or until core no impact on CDF, because the core is             damage occurred. The shown to remain covered at 24 hours. This         success state for the strict interpretation of the 24 hour mission      BV2REV3B PRA model time results in a .01 probability of core         was redefined as any uncovery, even in sequences where SW or           case (including AC power is not restored.                         uncertainties) that did not go to core damage before This result is significantly more optimistic than 48-hours. For cases that most other Westinghouse PRAs. The                 went to core damage uncertainty in the calculation [due to the        before 48-hours but after possible variation in RCS pressure or seal        20-hours, additional LOCA size from the predicted] is not pursued. electric power recovery values were used, based The MAAP analysis shows time to core              on NUREG/CR-5496. For uncovery of greater than 24 hours, but the       cases that lead to core plant is not yet in a stable configuration.      uncovery before 20-hours, Declaration of success at this point, based      a plant specific electric only on MAAP results without thorough             power recovery model investigation of MAAP uncertainties (e.g.,       was used. If electric sensitivities) is a liberal application of the   power recovery was intent of the 24 hour success criteria and may   successful for these be non-conservative.                             cases, the sequence was The Supporting Requirement is in reference to NEI 00-02 Element - Subelement.
Page 150 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact& Observation                               BVPS-2 Final Resolution      Impact to Fire ID    Requirement' Level        Closed                                                                              PRA YIN also binned to the success end state.
DA-07  DA-04       A            Y      The random independent failure probabilities    As a resolution to this      No impact to Fire are based on bayesian update of plant           PRA Peer Review              PRA, because this specific data. The plant specific data is based observation, the success     issue was on the time interval 1987 to 2001, for unit 2   data (demands and hours      addressed in the only. The processed data is presented in a      of operation) for all Unit 2 base PRA model tabular form. Several questions are raised      components that used         prior to building the when this data is reviewed:                     Bayesian updating of their   Fire PRA.
failure rates were checked
: 1. The data collection effort gets data before  against the Maintenance the institution of the maintenance rule. The    Rule estimated success reporting rules and accuracy of the pre-1994    data, and were revised as data should be justified to be the same as the  needed if discrepancies post 1994 data collection effort.               were found. Additionally,
: 2. The number of demands for several            all RISKMAN failure data components is very high. For example, there     distributions that were were 2331 DG demands. This means that           Bayesian updated in the each DG was started 89 times per year,          BV2REV3A PRA model which is almost 2 per week.                     were revised in the
: 3. The run time for the first hour for the DG's BV2REV3B PRA model is 2331 hr, which means each DG ran for one     using the results of review hour each time it was started. That leaves no   for estimated demands time for the 931 hours of extended run time. and hours of operation.
The demands and run time do not match.          All Top Events were
: 4. The RHR pumps have 371 demand to             requantified in the start. This means each pump is started 14       BV2REV3B PRA model times per year. Since they are not operated     using these revised during power operation, this number seems       component failure rates, very high.                                      which were then used to
: 5. The MD AFW pump has 707 demands,             requantify the CDF and which is 27 demands per year.                   LERF.
: 6. ZTPMOR and ZTPMSR are events for generic motor driven pump. There are no         The specific observations recorded failures in 1.4E+6 hr. This            identified in the PRA Peer Page 151 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance   Status    Fact & Observation                                BVPS-2 Final Resolution        Impact to Fire ID      Requirement 1   Level          Closed                                                                                     PRA I_               I              I YIN    I                                                                                 I performance is far better than industry           Review Fact &
average. Without proper back-up information,      Observation DA-07 are it is suspect.                                    addressed below:
: 7. The TD AFW pump has 224 starts, which is 17 starts per year.                            1. The data collection effort gets data before the institution of the maintenance rule. The reporting rules and accuracy of the pre-1994 data should be justified to be the same as the post 1994 data collection effort.
Response: Both the pre and post Maintenance Rule failure data were reviewed to the extent possible with the information available at the time to see if they met the requirements to be considered a PRA failure.
This PRA failure definition has remained unchanged throughout the PRA model updating process, and is not based solely on the Maintenance Rule definition, so it was unaffected by the implementation of the Maintenance Rule.
: 2. The number of L               a              a        a ________________________________________________ a Page 152 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact& Observation           BVPS-2 Final Resolution        Impact to Fire ID     Requirement 1   Level        Closed                                                               PRA I               II             YIN    I                                                           I__
demands for several components is very high.
For example, there were 2331 DG demands. This means that each DG was started 89 times per year, which is almost 2 per week.
Response: The DG start demands (ZTDGSS) was revised to 440 in the BV2REV3B PRA model.
This value is based on the Maintenance Rule estimated OST starts (50) per DG (2) per 3 year period, during 13.2 year of operation, or about 16 starts per year for each DG. Using a two-stage Bayesian process with 0 failures in 440 demands resulted in a mean failure rate of 2.78E-03 per start, as opposed to the 8.42E-04 value used in the BV2REV3A PRA model.
: 3. The run time for the first hour for the DG's is 2331hr, which means each DG ran for one hour each time it was started.
That leaves no time for Page 153 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance  Status   Fact & Observation          BVPS-2 Final Resolution         Impact to Fire ID     Requirement'   Level         Closed                                                               PRA I_             It             IYIN    I                                                           I the 931 hours of extended run time. The demands and run time do not match.
Response: According to the System Engineer, each Unit 2 emergency DG is run for about a total of 2 hours each time that the OST is performed.
Therefore, using the revised start demand value of 440 in the 13.2 year update period, the operating hours for failures during the first hour (ZTDGS1) and operating hours for failures after the first hour (ZTDGS2) both used 440 hours during the Bayesian update process for the BV2REV3B PRA model.
: 4. The RHR pumps have 371 demand to start. This means each pump is started 14 times per year.
Since they are not operated during power operation, this number seems very high.
Response: The RHR Page 154 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status   Fact & Observation          BVPS-2 Final Resolution     Impact to Fire ID      Requirement 1   Level        Closed                                                           PRA
  -   I               I    _I        YIN    I pump start demands (ZTPMAS) was revised to 168 in the BV2REV3B PRA model. This value is based on 13.2 year of operation comprised of historical IPE data (11/87 through 12/88), the BV2REV2 PRA model update data (1/89 through 12/96), and the Maintenance Rule estimates for the 1/97 through 12/00 period, or about 6 starts per year for each RHR pump. Using a two-stage Bayesian process with 0 failures in 168 demands resulted in a mean failure rate of 1.89E-03 per start, as opposed to the 1.38E-03 value used in the BV2REV3A PRA model.
: 5. The MD AFW pump has 707 demands, which is 27 demands per year.
Response: The motor driven AFW pump start demands (ZTPMDS) was revised to 460 in the BV2REV3B PRA model.
This value is based on Page 155 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance     Status    Fact & Observation                                BVPS-2 Final Resolution         Impact to Fire ID      Requirement'    Level            Closed                                                                                      PRA I                 I YIN    I                                                                                IY 13.2 year of operation comprised of historical IPE data (11/87 through 12/88), the BV2REV2 PRA model update data (1/89 through 12/96), and the Maintenance Rule estimates for the 1/97 through 12/00 period, or about 17 starts per year for each motor driven AFW pump. Using a two-stage Bayesian process with 0 failures in 460 demands resulted in a mean failure rate of 1.26E-03 per start, as opposed to the 1.02E-03 value used in the BV2REV3A PRA model.
: 6. ZTPMOR and ZTPMSR are events for generic motor driven pump. There are no recorded failures in 1.4E+6 hr. This performance is far better than industry average.
Without proper back-up information, it is suspect.
Response: Database variable ZTPMOR is only used for the main feedwater DumDs. A L              a _______________          a ________________________________________________ a                             .1.
Page 156 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status    Fact & Observation                   BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level Closed YN     JI  _    _    _      _    _    _ _ _ I_         _      _    _      _
PRA thorough search of the I Y/N available failure data from I                                                               MWRs, NPRDS, and EPIX were reviewed for these pumps. Although these data sources did list failures for these pumps, they consisted of mechanical pump seal leaks, oil leaks, and packing leaks. Itwas further noted that these leaks only degraded the pumps and did not result in any failures. Therefore, theses leaks were not counted as failures in the PRA model. However, the pumps were taken off line to repair them after discovery, which was accounted for in the PRA model pump unavailability due to maintenance activities.
Database variable ZTPMSR is used for the small standby pumps. A thorough search of the available failure data from MWRs, NPRDS, and EPIX were reviewed for these pumps. Although these data sources did list Page 157 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance    Status Fact & Observation          BVPS-2 Final Resolution      Impact to Fire ID      Requirement'   Level           Closed                                                          PRA
_   __             _              Y/N    I failures for these pumps, they consisted of mechanical pump seal leaks, oil leaks, flange leaks, excessive oil consumption, and high pump vibrations. It was further noted that these only degraded the pumps and did not result in any failures. Therefore, theses were not counted as failures in the PRA model. However, the pumps were taken off line to repair them after discovery, which was accounted for in the PRA model pump unavailability due to maintenance activities if tracked by the Maintenance Rule or by using generic standby pump unavailability if they were not.
: 7. The TD AFW pump has 224 starts, which is 17 starts per year.
Response: The turbine driven AFW pump start demands (ZTPTSS) was revised to 156 in the L              J              .1        .1 BV2REV3B PRA model.
Page 158 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                                 BVPS-2 Final Resolution     Impact to Fire ID      Requirement1 Level        Closed                                                                                PRA YIN This value is based on 13.2 year of operation comprised of historical IPE data (11/87 through 12/88), the BV2REV2 PRA model update data (1/89 through 12/96), and the Maintenance Rule estimates for the 1/97 through 12/00 period, or about 12 starts per year for each turbine driven AFW pump. Using a two-stage Bayesian process with 1 failure in 156 demands resulted in a mean failure rate of 1.50E-02 per start, as opposed to the 1.14E-02 value used in the BV2REV3A PRA model.
HR-07  HR-10        A            Y      The BV PRA uses the SLIM methodology.              As a resolution to this     No impact to Fire The HEP's are grouped in to 10 categories          PRA Peer Review             PRA, because this and then each category is "calibrated" in          observation all operator    issue was terms of 1 to 5 other PRA's. The PRA's that        actions having a Risk       addressed in the were used were Oconee (1984), Seabrook             Achievement Worth           base PRA model (1983), Diablo Canyon (1987), TMI (1985),          (RAW) greater than 2        prior to building the Fermi (not referenced), South Texas (1988).        (generally accepted as the Fire PRA.
The categories reflect each type of error (rule, risk significant threshold) skill, knowledge, diagnosis, response). The        were compared to similar HRA's on which these are based are                 actions for all representative of nuclear plant procedures,        Westinghouse plants by training and operator cognizance typical for       using the WOG/B&WOG mid-1 980.                                         PSA Comparison I Database (Revisions 2     1 Page 159 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact& Observation                                  BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level          Closed                                                                                    PRA I_                           I Y/N    I                                                                                I The error rate curves should be updated to         and 3). Additionally, a reflect current operator performance in the        smaller subset of these nuclear power industry. The use of 15 year         plants was also looked at.
old reliability data will limit the ability of the These consisted of; PRA to support risk based applications.            Westinghouse 3-loop plants (since these were assumed to have similar operation action completion times based on plant power to heatup volume ratios), plants that also used the SLIM process, and Indian Point 2, which received a superior finding in their Human Reliability Analysis peer review. The results of this comparison show that the human error rates used in the BV2REV3A PRA model are all within the range of both comparison groups defined above, except for human action OPRCD3 (operator fails to cooldown and depressurize during a SGTR). However, the BV2REV3A value is of the same order of magnitude as most of the other plants reviewed and is not considered to be an outliner. It is therefore believed that the basic Page 160 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. I Significance   Status   Fact &Observation                 BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level         Closed                                                                   PRA
_ ___I       j _ _ _ _ _ YN_
I error curves used in the calibration of the I YIN                                        BV2REV3A HRA are not grossly out of date, and that the current human error rates used in the PRA model are acceptable as is.
Moreover, as a final resolution to this observation, future updates of the BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology. The BV2REV3B PRA model was not changed as a result of this observation.
This F&O was written against an obsolete HRA PRA model (BV2REV3B) and is considered to be resolved by the updated HRA PRA model incorporated in BV2REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinqhouse. The Page 161 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                               BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-1 3.
HR-11  HR-27         A            Y      The BV HRA does not have a process to           In the initial development    No impact to Fire perform a systematic search for dependent       of the IPE HRA, an effort     PRA, because this human actions credited on individual            was made to eliminate the     issue was sequences. One case of dependent HEPs           dependency between            addressed in the was identified and treated (OF1 and 0B2).       human actions by              base PRA model However, it is not known how this was found. adjusting the split fraction  prior to building the Other potential cases of dependent human        value of the second           Fire PRA.
actions in SGTR. LOCAs or feed and bleed        dependent action, given sequences were not addressed. PRAs              that the first action failed.
typically have one or more of the dependent     For example, if the HEPs.                                           operators failed to manually reestablish Main SGTR-OD*CD*WM, or RR*WM                         Feedwater following the SGTR-SL*OD*CD*WM                                failure of Auxiliary SLOCA -CD*MU                                    Feedwater, the human Trans- OB*MU                                    error rate for Trans- OF*OB*MU                                 implementing Bleed and Init - Start standby CCP
* Trip RCP             Feed cooling later in the accident progression was There could potentially be other combinations   adjusted upwards. If the that were not identified.                       dependent actions were required to take place in Current HRA practices generally require a       the same period of time systematic process to identify, assess and      during the accident adjust dependencies between multiple human      progression, the second errors in the same sequence, including those    dependent action was in the initiating events.                       assigned to be a guaranteed failure. For Moreover, there was no process in the HRA       example, if the operators to adiust HEP on the final sequences and        failed to cooldown and Page 162 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance  Status   Fact& Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement'   Level         Closed                                                                               PRA
_               YIN
_I      I determine combinations of operator errors      depressurize the RCS by credited on individual sequences. A            using the secondary sensitivity study was done, but did not adjust coolant system, no credit the HEPs. The cutoff was 4E-9, so that many    was given to the operators other combinations were already below the      to depressurize the RCS truncation. It is not clear how HEPs in the    using the Pressurizer initiating events were treated in the study. PORVs. However, as a resolution to this PRA To be consistent with current HRA methods,     Peer Review observation there must be a systematic process to          a method was established identify, assess and adjust dependencies       to verify that all dependent between multiple human errors in the same      operator actions were sequence, including those in the initiating    captured by reviewing events.                                        sequences with two or more failed split fractions that have a contribution from human actions. Of the sequences reviewed, the human actions were either previously adjusted during the IPE HRA, or were determined to be independent between split fractions. This independence was based on the actions not being conducted by the same set of operators (e.g.,
control room Reactor Operator action vs. local Auxiliary Plant Operator action), or different procedures being used separated by sufficient time in the accident Page 163 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                BVPS-2 Final Resolution       Impactto Fire ID     Requirement 1 Level        Closed                                                                PRA IYINI                                                              IIN progression (e.g., actions to makeup to the RWST given SI recirculation failures, following operator actions to align a spare Service Water pump earlier in the accident sequence progression).
Human actions that are modeled in a single top event have appropriate dependencies modeled in the fault trees. Moreover, as a final resolution to this observation, future updates of the BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology. The BV2REV3B PRA model was not changed as a result of this observation.
This F&O was written against an obsolete HRA PRA model (BV2REV3B) and is considered to be resolved by the updated HRA PRA model incorporated in BV2REV4, which underwent a focused Peer Review in accordance with the quidance in ADDendix B of Page 164 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact& Observation                               BVPS-2 Final Resolution         Impact to Fire ID     Requirement' Level        Closed                                                                                   PRA Y/N NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
TH-01  TH-08        A            Y        The Beaver Valley Unit 2 Ventilation and        A new room heatup               No impact to Fire Room Cooling Analysis Notebook describes        analysis was performed          PRA, because this the HVAC requirements for the South             for the Safeguards              issue was Safeguards Equipment Room. This analysis        Building using realistic        addressed in the is described as the basis for not requiring     time-dependent DBA heat         base PRA model room cooling in the PRA model.                  loads, based on MAAP            prior to building the generated success               Fire PRA.
The heat load for this area is only listed as a criteria. The results of this number (24898W or 85034BTU/hr) with no          analysis were reviewed description of equipment assumed operating      and compared to the EQ or other conditions considered. The heat        temperature limits to see if load for this analysis is referenced to         the necessary Calculation Number 12241-US(B)-210, "Loss       components to mitigate of Ventilation Study for Several                core damage or Buildings/Areas Outside Containment."           containment failures Again this calculation determines the heat      would be functional at the source in the South Safeguards Room as          time that they were 85034 BTU/hr by reference to another            required to function (up to calculation and lacks any description of        24 hours). It was assumed equipment running etc. The              concluded that all PRA referenced calculation was 12241-B-215-0,       modeled equipment "Heat Gains, Heat Sinks and Beginning           located within the Temperature for Emergency Switchgear,           Safeguards Building CV&RCA, Diesel Gen. Bldg., Safeguards           would be available to I Bldg and Auxiliary Bldg for Loss of Ventilation perform its PRA function      I Page 165 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status  Fact& Observation                                  BVPS-2 Final Resolution     Impact to Fire ID     Requirement' Level         Closed                                                                                 PRA I_             II            YIN    I_                                                I Analysis." The objective of this calculation       during a loss of all was to "...calculate the rate of increase of       ventilation for up to 24 ambient temperature during a loss of               hours. Therefore, it was ventilation [caused by a fire in the Cable         determined that the Tunnel] in the areas listed..." In the Heat        Safeguards Building Gains to Areas section of this calculation the     ventilation system is not South Safeguards Area states "since the            required for support of the plant is not experiencing accident conditions,     PRA modeled equipment the load used for normal plant operation.          located within the area, However, since this analysis occurs                and the BV2REV3A PRA assuming a fire, the auxiliary feedwater pump      modeling assumptions is in operation." The heat load in this area is    regarding this remain calculated as                                      valid. The BV2REV3B MDAFWP(68700)+Electrical(16334)=85034              PRA model was not BTU/hr. An additional reference for this heat      changed as a result of this load is to calculation 12241-B-62B, Rev. 0,        observation.
dated 8-13-85. This final calculation, "Safeguards Area Ventilation - Loads and Air Rates," describes the accident heat load for the South Safeguards Area as 210,136 BTU/hr and the heat load from one MDAFWP and electrical as 68,700 and 15,398 BTU/hr respectively.
It appears from this research that the heat load values for this area are only for a single operating MDAFWP while the room additionally contains the TDAFWP, the Train A QSS Pump, and the Train A SIS Pump. It appears the values in previous calculations were misapplied and that the correct heat load during an accident situation has not been correctly analyzed for this area.
As stated in 12241 -B-62B, "Single failure Page 166 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution     Impact to Fire ID      Requirement 1 Level        Closed                                                                             PRA Y/N cannot be applied in determining which components are operating since the worst case environment must be calculated.
Therefore, all equipment must be assumed to be operating ifthe equipment function is required."
AS-07 I AS-1 9        B            Y      For the SGTR event tree one of the operator     As resolution to this       No impact to Fire actions is to initiate Bleed and Feed (top      observation, existing       PRA, because this event OB). The success criteria for OB          documents were              issue was indicates that the basis for the success        reviewed. Based on the      determined to criteria assumes that the operator must have    EOP Background              have no effect on stopped the RCPs prior to OB in order to        document for FR-H. 1,       the BVPS PRA extend the time available to initiate bleed and steam generator dryout is   model.
feed (referenced EOP FR-H. 1). If the tripping  expected to occur at 33.1 of the RCPs is a prerequisite for the degree    minutes if all RCPs of success of OB where in the model is this     remain running during a dependency accounted for.                       loss of all secondary cooling. If the RCPs are tripped 5 minutes after the reactor trip, steam generator dryout is expected to occur at 40.9 minutes. This difference of less than 8 minutes is not expected to significantly impact the human error rates calculated for Top Event OB, since the actions to trip the RCPs, initiate SI and open a PORV are fairly simple actions that can be accomplished within minutes.
Therefore, these actions Page 167 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                               BVPS-2 Final Resolution     Impact to Fire ID     Requirement1 Level        Closed                                                                              PRA YIN are all assumed to be accounted for in the current human action failure rate, so the HER was not revised in the BV2REV3B PRA model.
DA-02  DA-03        B            Y      Table A-1 indicates that the period of time for  As a resolution to this     No impact to Fire the data collection was approximately 13         PRA Peer Review             PRA, because this years. The table indicates that this data is for observation, the success    issue was Unit 2. However, when the estimated              data (demands and hours     addressed in the average demands per year were computed it        of operation) that was      base PRA model was not clear how this information was           used in the Bayesian        prior to building the derived based on the expected demands per        updating of the             Fire PRA.
year. In some cases the number of                component failure rates extrapolated demands per time period do not      for Unit 2 was revisited match what would be the expected number of       and checked against the demands.                                         Maintenance Rule estimated success data, provided by the System Engineers. The Maintenance Rule data was based on a 3-year frequency, so the demands and hours of operation were adjusted for the 13.2 years used for the Bayesian update.
When there was a large discrepancy between the demands or hours of operation that were used in the BV2REV3A PRA model data update and those based on the Maintenance Rule data.
Page 168 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation             BVPS-2 Final Resolution      Impact to Fire ID     Requirement' Level        Closed                                                               PRA I   _I_                    YIN    I the demands or hours of operation used for Bayesian updating were revised to use those solely estimated from the Maintenance Rule data.
When there was only a minor discrepancy between the two, the total success data used for Bayesian updating was based on the values from the IPE (11/87 through 12/88), the BV2REV2 PRA model data update (1/89 through 12/96), and the Maintenance Rule estimates for the 1/97 through 12/00 period.
This helped to preserve any historical success data that may have been different from the test frequencies used by the System Engineers in estimating the Maintenance Rule demands and hours of operation. However, either way, all failure data distributions that were Bayesian updated in the BV2REV3A PRA model were revised in the BV2REV3B PRA model Page 169 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact& Observation                             BVPS-2 Final Resolution     Impact to Fire ID     Requirement' Level        Closed                                                                           PRA Y/N using these new estimated demands and hours of operation. This process and the results are documented in Appendix A (PLG Report:
Summary of Plant Data December 2002 Update) and Appendix E (BV2 Component Failure and Success Data: From 11/17/87 - 12/31/00) of BVPS-2 Data Analysis PRA Notebook, Revision 1.
DA-06  DA-08        B            Y      The generic MGL data used in the BV Unit 2    The following wording was   No impact to Fire PRA is referenced, almost exclusively to the  added to Revision 1 of the  PRA, because this PLG generic database. Although the data       Data Analysis PRA           issue was analysis was updated recently, there is no    Notebook to document the    addressed in the discussion in the Data Analysis Notebook      justification for using     base PRA model regarding the availability of newer data      existing dated data in      prior to building the sources, e.g., NUREG/CR-5497. There           developing the common       Fire PRA.
should, at a minimum be a discussion of the   cause failure parameters currently available data sources. It is noted for the BV2REV3B PRA that at least one Beta factor from            model update.
NUREG/CR-5497 is used, but it is not          Additionally, NUREG/CR-referenced in the data notebook.              5497 is now included in the notebook as Reference 15.
InApril 2001, Westinghouse issued WCAP-1 5674 in order to provide guidance to the owner's group utilities for Page 170 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance    Status    Fact & Observation          BVPS-2 Final Resolution    Impact to Fire ID      Requirement 1   Level           Closed                                                           PRA I              I  Y/N    IN improving common cause analyses used in their PRA models. Section 5.5 of the WCAP recommended several generic common cause failure data sources, one of which was NUREG/CR-5497 that was issued in October 1998, along with a CD-ROM disc for utilities to use in developing better common cause MGL parameter estimates.
This NUREG was also to be used in another Westinghouse project to develop a database consisting of a common set of realistic common cause failure events for use among the owners group member utilities.
During this project development it was noted that there were some major discrepancies in the classification of common cause failures between the published NUREG and the CD-ROM. As such, the NRC was to update the coding of their A               L              4.        4.
common cause failure Page 171 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting.      Significance   Status   Fact & Observation                   BVPS-2 Final Resolution     Impact to Fire Requirement 1 ID
______   _   ___ ____JYIN Level          Closed I
PRA events and database, and I YIN                                           Westinghouse was to I                                                              provide input and feedback so that there would be consistency between plant-specific PRA models when using the data. However, at the time of the BVPS Unit 2 common cause MGL data update during Revision 3, the NRC update was still not available. As such, a decision was made during the update process to keep the existing generic MGL data, which is almost exclusively based on the PLG generic database (Reference 1), dated circa 1989. Two exceptions to this were for the development of the battery (ZBBATR) and battery charger (ZBBCHR) failure to operate beta factors.
These beta factor parameter estimates were developed using the NUREG/CR-5497 corresponding maximum likelihood estimate (MLE) values.
Page 172 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution      Impact to Fire ID     Requirement' Level        Closed                                                                             PRA YIN Updated common cause failure data from WCAP-16672, based on NUREG/CR-6819, were ultimately used inthe BV2REV5 PRA model and appropriately documented. The methodology for the update was taken from NUREG/CR-5485.
DA-08  DA-04        B            Y      Acomparison of the failure probabilities for   As part of the resolution to No impact to Fire diesel generators and DG output breakers       Corrective Action 02-        PRA, because this was counter-intuitive.                         09037-03, the diesel         issue was generator and circuit        addressed in the DG FTStart = 8.4E-4                            breaker failure              base PRA model CB fail to close =1.75E-3                      probabilities were revised   prior to building the CB fail to open = 8.1E-4                       and incorporated into the    Fire PRA.
CB-beta =.12                                   BV2REV3B PRA model.
DG-beta = 7.6E-3.
From these probabilities, we can calculate the following CCF failure probabilities:
CCF 2 DG fail to start = 6.08E-6 CCF 2 CB fail to close = 2.1 E-4 CCF 2 CB fail to open = 9.7E-5 In the process of calculating station blackout frequency, these CCF's should appear in the model.
: 1. Failure of 2 DG will cause SBO at a single unit.
Page 173 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                               BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN
: 2. Failure of the 2 DG output breakers will cause SBO at a single unit
: 3. Failure of the 2 bus feed breakers to open will cause SBO at a single unit that is not recoverable by cross-tie.
: 4. This data implies that the DG's are far more reliable than the circuit breakers and feed breakers which are a much larger contributor to SBO frequency.
DA-09  DA-10         B            Y      There is very little guidance for or             Resolutions to this F&O      No impact to Fire documentation of the process of selecting        included adding a better     PRA, because this CCF groups. The System Analysis Overview         reference to the             issue was and Guidance Notebook provides some of           methodology used in          addressed in the the high level methodology, but there is no      retaining the common         base PRA model discussion in the Data Analysis or System        cause groupings, along       prior to building the Notebooks as to the development of the           with a listing of all of the Fire PRA.
groups that were ultimately modeled. In          common cause groupings general, the system notebooks document the       used inthe quantification CCF groups by referring to the Riskman           of the system top event output files. This is not very informative. For  models. These are example, the AC Electric Power System            provided in Section 7 Notebook provides no discussion of the CCF       "Common Cause model for the diesel generators. A discussion     Modeling" and Appendix of decoupling the Unit 2 diesels from the Unit   A,Table A-1 of the BVPS-1 should be included.                            2 Systems Analysis Overview and Guidance PRA Notebook, respectively. Additionally, a summary of all of the MGL parameters used in the top event common cause groupings is now I provided in Appendix C, Page 174 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                               BVPS-2 Final Resolution       Impact to Fire ID     Requirement1 Level        Closed                                                                               PRA YIN Table C-7 of the Data Analysis PRA Notebook.
Furthermore, it is the opinion of the BVPS PRA staff that the details of the common cause groups that were retained in the PRA system models and presented in Appendix C of the BVPS Unit 2 PRA System Notebooks, under the common cause sections of the RISKMAN System Notebook files are adequately documented and can be found by knowledgeable personnel.
Therefore, the practice of referencing this part of the notebook is deemed acceptable.
DA-10  DA-07        B            Y      The test and maintenance unavailabilities for   As resolution to this         No impact to Fire DG were reviewed. The following were            observation, the Diesel       PRA, because this observed.                                       Generator System              issue was Engineer was contacted        addressed in the
: 1. The DG are used in a cross-tie situation for to obtain the historical      base PRA model either unit. Thus, it is possible that the      diesel generator              prior to building the unaffected unit could be in shutdown and the    unavailability during plant   Fire PRA.
DG could be in overhaul. The outage time for    shutdown conditions. For the DG (when used as a cross-tie) must          the Unit 1 emergency include the OOS time during shutdown.           diesel generators, the shutdown unavailability
: 2. Appendix B of the data document indicates    was based on data maintenance outage was collected Nov 98         obtained from October Page 175 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                                 BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                                 PRA YIN through May 2000. This is not long enough to       1997 through September capture the DG overhaul experience.                2001. These values were then combined with the
: 3. For unit 2, the unit I DG are used for the      assumed on-line cross-tie. The T&M data must come from unit maintenance unavailability 1 experience. This information was not found. values to determine the total Unit 1 emergency diesel generator unavailability, which was used in the BV2REV3B electric power cross-tie model.
DE-04  DE            B            Y      There is no discussion of some flow                In response to this          No impact to Fire (Draft                            characteristics (e.g., spray effects, pipe whip) observation, the work that     PRA. This F&O IF-09)                            in the consideration of impacts from flood         was completed for the        was resolved in initiators.                                        Beaver Valley Unit 2 Risk-   the submitted Informed In-Service          BVPS-2 Fire PRA Inspection (RI-ISI) Indirect model, which used (Spatial) Consequence        BV2REV5A as its Evaluation was reviewed,     basis.
As a part of this evaluation process, an assessment of the postulated indirect (spatial) consequences associated with piping failures was made in order to further distinguish the piping segments. The indirect effects assessment was accomplished through an investigation of existing plant documentation on I pipe breaks, flooding, and Page 176 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact& Observation              BVPS-2 Final Resolution    Impact to Fire ID     Requirement' Level        Closed                                                             PRA Y/N    I plant layout along with a focussed plant walkthrough. The indirect effects that were specifically looked at included; pipe whip, jet impingement, sprays, and flooding resulting from pipe breaks or leaks. The results of this indirect effects evaluation did not identify any viable SSC impacts due to flood induced failure mechanisms that were not already addressed in the PRA flooding analysis documentation. No further flooding impacts were incorporated into the BV2REV3B PRA.
This F&O was written against an obsolete Internal Flooding PRA model (BV2REV3A) and is considered to be resolved by the updated Internal Flooding PRA model incorporated in BV2REV5A, which underwent a focused Peer Review in accordance with the guidance in ApDendix B of NRC RG Page 177 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement' Level        Closed                                                                             PRA YIN 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
DE-05  DE           B            Y      A number of flood-specific HEPs are included   To resolve this PRA Peer     No impact to Fire (Draft                           in the analysis (e.g., ZHEFL1-4). These four   Review observation,          PRA. This F&O IF-25,                           HEPs are evaluated in the HRA Notebook in      operator actions ZHEFL1      was resolved in IF-26)                           the calculation tables, but no discussion of   and ZHEFL2 were added        the submitted these actions is included in the HRA           to Table 3-1 "Beaver         BVPS-2 Fire PRA documentation, and only ZHEFL1 and             Valley Human Actions"        model, which used ZHEFL2 appear in the flood documentation in    and discussions of the       BV2REV5A as its the Appendix C of the IE Notebook.             scenarios now appear in      basis.
Appendix A "Dynamic Action Identifier Sheets".
Additionally, operator actions ZHEFL3 and ZHEFL4 are Unit 1 operator actions, and were removed from Table 3.5 "Human Error Rate Distributions" to avoid any confusion.
This F&O was written against an obsolete Internal Flooding PRA model (BV2REV3A) and is considered to be resolved by the updated Internal Flooding PRA I model incorporated in Page 178 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution      Impact to Fire ID     Requirement1 Level        Closed                                                                             PRA Y/N BV2REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
HR-01  HR-04        B            Y      Miscalibration errors are not considered for   This observation is not      No impact to Fire either independent or common cause pre-        totally correct, since the   PRA, because this initiator human errors. The PRA assumes        SSPS model did include       issue was that both would be captured in the equipment   instrument string            determined to failure data. However, the generic common      miscalibration errors in the have no effect on cause failure database is not verified as      fault tree model.            the BVPS PRA having included miscalibration errors as well. Additionally, common         model.
Therefore, there is a potential misapplication cause miscalibration of the generic common cause data use since     errors between trains are the generic data source may not include the    considered to be rare common cause miscalibration.                   events since the On-line Maintenance Program is developed to alternate work between trains on different weeks.
Furthermore, a search in the Corrective Action database and EPIX did not reveal any such miscalibration errors between trains at BVPS.
Therefore, this Page 179 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status Fact& Observation                                BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level          Closed                                                                                PRA I YIN    I observation was assumed to be resolved by the instrument string miscalibration errors already accounted for in the SSPS model. No further miscalibration errors were incorporated into the BV2REV3B PRA.
This F&O was written against an obsolete HRA PRA model (BV2REV3B) and is considered to be resolved by the updated HRA PRA model incorporated in BV2REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-03  HR-02         B              Y        The BV PRA uses the SLIM methodology to        While it is true that the FLI No impact to Fire quantify the post initiator human actions. The is a linear combination of    PRA, because this HRA quantification currently in use was        the PSF rankings and          issue was Page 180 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance   Status   Fact & Observation                                BVPS-2 Final Resolution     Impact to Fire ID      Requirement'   Level          Closed                                                                                 PRA I                              I YIN    IN completed for the IPE and has not been            weightings product, the     addressed in the updated. The SLIM method can only combine         actual HER is logarithmic   base PRA model the PSFs linearly to develop the overall FLI      as discussed in Section     prior to building the for each action. Current industry practice        2.1 of the HRA Notebook. Fire PRA.
contends that PSFs can have significant non-      Additionally, as shown in linearities. For example if a particular action   Table B-4 "Beaver Valley is rated poorly for a given PSF and               Unit 2" Group 4 Human moderately in all the others, middle of the       Actions Evaluation, road HEPs tend to result even though poor         between ZHEMU1 and performance in only one PSF may be                ZHEMU4, where the only indicative of poor human reliability              difference is in the timing irrespective of what is going on with the other   rankings, there is a PSFs. Mosleh of University of Maryland has        significant difference in addressed this issue in a refinement of the       the HER values.
FLIM method (which allows assignment of importance to PSFs) in an update of the           This PRA Peer Review Calvert Cliffs PRA. The BV PRA uses linear        observation was compilation of PSFs. The ability to use non-      dispositioned by the linear compilations, if desired would be an       resolution of F&O HR-07 enhancement.                                      above, where it was shown that the current human error rates used in the PRA model are acceptable as is, and by acknowledging the PRA Peer Review Team comment on its significance on CDF.
Moreover, as a final resolution to this observation, future BVPS PRA models will use the EPRI HRA Calculator, which uses a more current I              &#xa3;              a        a                                                 &#xa3; and robust methodology Page 181 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                            BVPS-2 Final Resolution     Impact to Fire ID     RequirementI Level        Closed                                                                          PRA Y/N to identify human action dependencies.
This F&O was written against an obsolete HRA PRA model (BV2REV3B) and is considered to be resolved by the updated HRA PRA model incorporated in BV2REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-09  HR-03        B            Y      There is not enough detail in the HRA to     This CA is being (was)      No impact to Fire reproduce the results. The following         rolled into CA 02-09043-    PRA, because this information was not available and does not   30 to track its resolution. issue was appear to have been retained:                                            addressed in the This F&O was written        base PRA model a) the time lines                            against an obsolete HRA     prior to building the PRA model (BV2REV3B)        Fire PRA.
b) discussion of the events chosen for       and is considered to be "calibration" from the other PRA's and the   resolved by the updated reason why they are applicable.              HRA PRA model I incorporated in BV2REV4, Page 182 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution    Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA YIN c) the basis for choosing 10 categories of      which underwent a HEP and the basis for assigning each BV         focused Peer Review in HEP to a category                               accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-13  HR-19         B            Y      Some discrepancies in the timing were           These operator actions     No impact to Fire observed in the PRA.                            were reassessed during     PRA, because this All the timing calculations were based on       the BVPS-2 PRA model       issue was hand calculations. Although the times           update,                    addressed in the seemed reasonable compared to other PRAs,       when the HRA was           base PRA model there were some observations.                   revised using the EPRI     prior to building the HRA Calculator.            Fire PRA.
: 1) There was a calculation done for steam generator dryout, which assumed all the         This F&O was written water would be exhausted from the SG by 1.1     against an obsolete HRA hours. Using 1.1 hours overestimates the        PRA model (BV2REV3B) time available to do F&B or restore AFW.        and is considered to be Effectiveness of decay heat removal will        resolved by the updated decrease way before all the water is gone in    HRA PRA model the SG.                                         incorporated in BV2REV4, which underwent a
: 2) ZHECC1 - start standby CCP provides a        focused Peer Review in time of 30 minutes, based on seal failure after accordance with the loss of seal cooling. But, after loss of CCW,   guidance in Appendix B of the RCP must be tripped with in 5-10 minutes    NRC RG 1.200, Rev.1, to avoid catastrophic seal failure. The 30      conducted during the minutes for seal failure after loss of cooling  week of October 29, 2007, Page 183 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution    Impact to Fire ID     Requirement' Level        Closed                                                                           PRA YIN does not apply. This scenario is for bearing   by Westinghouse. The failure after loss of CCW. The timing should   F&Os as a result from this be consistent.                                 focused Peer Review, as well as their resolutions
: 3) ZHEICl and ZHEIC2 show 70 and 30            are presented in Table 1-minutes based on seal failure after loss of    3.
seal cooling. The time should be consistent and should consider if the Loss of CCW to the RCP bearing must be considered.
: 4) ZHEMU1 - timing for MU indicates the operator has 1.6 hours to act, based on the time it takes to drain the RWST from minimum level "empty". The number should be coordinated with the boron dilution calculation, which assumes boron dilution times from a RWST level of 140,000 or 360,000 gallons. time allowed for operator diagnosis on the front end must be subtracted from time allowed
: 5) ZHEOB1 provides 78 minutes for feed and bleed, based on the time for a PORV to lift after loss of AFW. There is no analysis for this. In most PWR, F&B must be started prior to the time the PORV lifts. Start time for F&B should be based on MAAP analysis.
: 6) ZHEOCl - states there are 30 minutes to trip RCP after loss of seal cooling. The other parts of the PRA state 5 or 10 minutes. 30 min is a seal failure number, not a bearing failure number. ZHEOCI be based on 5 minutes.
Page 184 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                                 BVPS-2 Final Resolution   Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA Y/N
: 7) ZHEOS6 - timing states 1.3 hour available to start AFW. 1.3 hours is the time from reactor trip to core uncovery. AFW must be started before 1.3 hours. Also, if there is 1.3 hours allotted to start AFW, then there is no time for MFW restoration and F&B. The time from reactor trip to core damage must be apportioned to the 3 actions in this sequence.
: 8) ZHEWA5- 30 minutes to align diesel driven SW pump after LOSP. This time is based on seal failure due to loss of SW. The DG will fail in 8 minutes if there is no SW. The time to align Diesel driven pump is based on failure of the DG, which is 8 minutes.
IE-04   IE-16        B            Y      Subtier criteria requires that "The initiating     The initiating event      No impact to Fire event frequency should not use data from the       frequencies were          PRA, because this initial year of commercial operation."             reanalyzed using data     issue was Contrary to this data from 1987 (Beaver            from January 1, 1989      addressed in the Valley initial year of operation) is included in   through May 31, 2001. In  base PRA model the data update. Use of this data, though          addition, LOCA initiating prior to building the conservative, could shift the importance of        event frequencies were    Fire PRA.
components.                                        reanalyzed to address aging-related failure mechanisms based on the interim LOCA frequencies from Table 4.1 of the "Technical Work to Support Possible Rulemaking for a Risk-Informed Alternative to 10CFR 50.46 / GDC 35, Revision 1", dated July 2002. The results of this I reanalysis were           _       _I Page 185 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                               BVPS-2 Final Resolution    Impact to Fire ID      Requirement' Level        Closed                                                                             PRA YIN incorporated into the BV2REV3B by updating the initiating event frequencies.
IE-05   IE-13        B            Y      In appendix D of the initiating event notebook,  The interfacing systems    No impact to Fire the interfacing systems LOCA frequency is        LOCA initiating event      PRA, because this calculated referring to two references from      frequency was reanalyzed   issue was 1985. The 2 landmark ISLOCA reports              using the following        addressed in the (NUREG/CR-5102 and NSAC-152) were                documents:                 base PRA model written in 1992. Although the frequency                                     prior to building the calculated in the Beaver Valley PRA does not     1. G. Bozoki, P. Kohut,    Fire PRA.
seem out of the recognized range of values       and R. Fitzpatrick, for this frequency, due to the importance of     "Interfacing Systems this event for LERF, the compatibility of the    LOCA Pressurized Water method and data used in the PRA should be        Reactors," prepared for checked against the later references.            U.S. NRC, NUREG/CR-5102, BNL-NUREG-Other inconsistencies in the analysis are:       52135, February 1989.
OST 2.11.16 is performed prior to startup, if it 2. E. T. Burns, K.
has not been performed in the previous 9         Mohammadi, T.P., Mairs, months. The PRA assumes there are 3              V. M. Anderson, and B.
shutdowns per year (which is not supported        Hannaman, "ISLOCA by the historical performance of BV), so          Evaluation Guidelines,"
assigns a test frequency of 3 months. The        prepared for Electric maximum possible test interval for OST            Power Research Institute, 2.11.16 is 26 months [plant ascends to power      NSAC-154, September 8 months from last test for an 18 month run]. 1991.
The minimum is 9 months. The true average         3. D. A. Wesley, T. R.
test interval is likely in the 13-20 month        Kipp, D. K. Nakaki, H.
range. Substituting this test interval into the  Hadid-Tamjed, "Pressure-equation would have a significant affect on       Dependent Fragilities for frequency.                                        Piping Components -
Pilot Study on Davis-The probability of MOV 8889 being                 Besse Nuclear Power Page 186 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact &Observation                                  BVPS-2 Final Resolution      Impact to Fire ID      Requirement 1 Level        Closed                                                                                 PRA YIN inadvertently open is not considered.              Station," prepared for U.S.
NRC, NUREG/CR-5603, The LHSI lines are interconnected such that if     T191 002465, October CV 552 and 109 fail, both 132 and 133 will be      1990.
challenged. This is true for the other injection lines also. So the valve combinations is 3         The results of this revised times higher than shown.                           analysis were incorporated into the The probability of pipe over pressure is           BV2REV3B by updating assumed to be the same as pipe rupture.            the interfacing systems This is not consistent with the two 1992           LOCA initiating event references listed above,                           frequency.
IE-08   IE-13         B            Y      Bayesian updating is used extensively in data      While there are indeed       No impact to Fire analysis and also in initiating event frequency    situations that Bayesian     PRA, because this calculations. Although mathematically correct,     updating with zero failures  issue was the use of Bayesian updating without some          could cause the posterior    addressed in the limitations has been criticized, with              mean to be significantly     base PRA model justification, in the past. Under certain          lower than the prior mean,   prior to building the conditions, bayesian updating with zero or 1       these are due to the use     Fire PRA.
failures may reduce a prior mean (with a high      of using moment error factor) considerably. Since PRA results      matching. This refers to and applications depend on, and are                the practice of changing a measured mainly by point estimate (mean)          prior that is presumably a results, but not by uncertainty bounds, any       lognormal distribution, to a evidence that shifts the mean considerably         gamma distribution by must be rigorously justified.                     matching the mean and the standard deviation.
The BV PRA uses bayesian analysis for              After the Gamma virtually all transient initiating events. In most distribution is updated cases, the plant specific data is 0 trips in 11    with plant data years. Ingeneral the posterior is lower than       analytically, the resulting the prior. Ifthe plant specific data was used      gamma distribution is by itself, the is enough data to justify a point  convert back to the estimate of about .05/yr. The prior for LOSP       lognormal distribution is .027. The prior for SGTR is .0074. The         again using the moment Page 187 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact& Observation                                  BVPS-2 Final Resolution       Impact to Fire ID    Requirement 1   Level        Closed                                                                                  PRA
_I._           II             YIN    I                                                II posterior for LOSP is .025 and for SGTR          matching method. It is
                                            .0048. In both these cases, the posterior is     known that in this lower than the prior and lower than the plant    practice, ifthere should be specific data can justify. This is due to the    zero failures, the resulting use of Bayesian analysis when too little plant   posterior gamma specific data exists.                            distribution has a mean value significantly lower Rules for when to use Bayesian analysis and than the prior mean.
when to use generic data should be               The BVPS analysis did developed to ensure that failure rates and       not use the moment initiating event frequencies are not reduced     matching methodology.
below both the generic values and the plant      Instead, the Bayesian specific estimates.                              update functionality provided by RISKMAN was used. There are two classes of priors used in the BVPS analysis. The first class are the lognormal distributions based on parameters from industry studies (e.g.,
LOCA initiators).
Updating a lognormal distribution with zero events in about 10 years does not change the mean in most cases (or there is a slight change in the third significant number).
The second class, which is a more general type of priors, is the industry data.
These priors consists of Page 188 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance  Status   Fact & Observation           BVPS-2 Final Resolution         Impact to Fire ID     Requirement 1 Level         Closed                                                                PRA IYIN    I                                                            I three parts. The first and most important part is the failure and success data for a set of PWR power plants. The second part is the so-called grid, which consists of a set of values for the median (of the assumed prior curve), and a set of values for the range factor (of the assumed prior curve).
The selection of median and range factor should be such that the resulting distribution should not be skewed toward either end of the median or range factor in the grid (grid is the matrix of median and range factor values). The third part of a prior is the so-called lambdas, which is a set of values for the possible bin values that the distribution can locate.
The lambdas do not affect the posterior mean distribution as long as it has sufficient range and sufficient number of values (typically 20 bins are sufficient for a distribution). It should be pointed out that for the Page 189 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance  Status   Fact & Observation          BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1   Level         Closed                                                             PRA I               I               YIN I_      I industrial data type of prior, updating it with zero failures typically results in a smaller mean value for the posterior then the prior. However, the decrease is much smaller in magnitude than the moment matching approach, and it should be treated as a normal behavior of the Bayesian analysis (i.e., zero failures always provide information leading to a lower estimate).
In response to this observation, each posterior distribution that was Bayesian updated with zero failures was reexamined to assure that there was no skewing of results on the grid, and that there were no abnormally large values (excessive probabilities) in a single lambda bin. In some cases a few more lambdas were added to actually bring the probability per each lambda lower than 0.1.
However, in these cases Page 190 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance   Status   Fact & Observation                            BVPS-2 Final Resolution      Impact to Fire ID      Requirement1 Level          Closed                                                                              PRA I Y/N    I the posterior distribution changed little compared to the BV2REV3A original set of lambdas (note, the grid was not changed in this response because these were checked in the original analysis and quality was assured). The results of the review did not identify any concerns, so confidence in the Bayesian update results using zero failures based on the discrete probabilistic distribution approach, which is a robust process, was maintained.
For the BV2REV3B PRA model, since the success time changed from 11 critical years to 9.93 critical years in response to Corrective Action 02-09042-01 (to remove the first year of commercial operation), the posterior mean shifted slightly higher than the original BV2REV3A PRA model analysis.
L2-03   L2-18        B              Y        All early SGTR core damage sequences with     In response to this          No impact to Fire I                                      wet SGs are classified as SERF (small early I observation, the           I PRA, because this Page 191 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact& Observation                                BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level         Closed                                                                                 PRA I_             II             YIN    I                                                I                            I release frequency) vs. LERF without regard       BV2REV3B PRA model           issue was to break location or other sequence specific     was revised to incorporate   addressed in the conditions such as SG isolation, primary to      WCAP-1 5955 "Steam           base PRA model secondary pressure equalization, etc. The        Generator Tube Rupture       prior to building the basis for the use of small release was           PSA Notebook"                Fire PRA.
scrubbing; however, there is no                  classification of SGTRs documentation supporting this classification. into LERF. In the For example, failure to cooldown and             BV2REV3B PRA model depressurize the RCS may result in lifting the   update, all steam ruptured SG ASDVs or safety valves.              generator tube ruptures Radionuclides, both volatile and non-volatile,   that are faulted and have entrained in the escaping steam result in a      a depleted RWST, or release to the environment. Without              have a loss of all evaluation, the magnitude of the release to      secondary cooling and the environment is unknown, and may be           consequential challenge sufficient to meet LERF classification.          to the steam relief valves are considered to be LERF contributors. For these cases it is assumed that leakage from the RCS will continue indefinitely through a faulted steam generator and the core will uncover after the RWST depletes.
Subsequently after closing this F&O, the ASME Standard recognizes scrubbing during SGTRs as a way to reduce LERF.
Ultimately resolved by GAP F&O LE-Cl0-01 (see Table 2-2).
Page 192 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                                BVPS-2 Final Resolution        Impact to Fire ID     Requirement 1 Level        Closed                                                                                  PRA YIN MU-02  MU-06         B            Y      The computer models of the PRA (electronic        IT has placed restrictions     No impact to Fire files for the input and output of the PRA         to the "S:/AII/PRA             PRA, because this model and its sensitivity analyses) should be     Engineering" directory.        issue was stored in a controlled manner. The subtier        The permissions for this       addressed for the criteria states that "a secure offsite storage    directory are limited to       base PRA model facility for computer codes, inputs, outputs,     specific design                prior to building the and models should be used".                       Engineering personnel.         Fire PRA.
This will prevent Discussions with the BV PRA staff indicate        unauthorized personnel that the PRA model files are kept on CDs and      from accessing PRA also on a network drive (not a protected          reports and models. In drive),                                           addition, the network is backed up daily, making To meet the intent of the subtier criteria, the   retrieval of lost files very model files should be also stored with the        easy.
same philosophy as the paper copies of calculation notes; namely stored by a dedicated organization (preferably outside of the PRA group), in a protected manner and be available for long term retrieval.
QU-02  QU-08         B            Y      The original top ten sequences were for total     In response to this            No impact to Fire CDF and not just internal. Of these three         observation, a new top         PRA, because this were control building fire, one seismic, and      event was included in the      issue was four external. The number 1 was ELOCA and         BV2REV3B PRA model,            addressed in the number 2 was ISLOCA, both which were the          which contained a switch       base PRA model initiating event which leads to guaranteed        to bypass the containment prior to building the failure. The remaining four were internal         event tree top events.         Fire PRA.
sequences which meant something. The              This allowed for the Level number five sequence was loss of AC bus           1 (CDF only) sequences "Purple" with other failures that lead to core    to be quantified and damage. Sequences 7 and 8 were LOIA with          reviewed, while also loss of heat removal (high and dry). The          maintaining the ability to number 10 sequence was ATWT (on a                 provide Level 2 sequence turbine trip) with the failure of the operator to results, when needed.
manually trip the reactor, with all subsequent I                               I Page 193 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement' Level        Closed                                                                              PRA YIN                                                                               I operator actions guaranteed failure. Since this had limited internal sequences, a larger report was reviewed with the objective to see what SBO looked like. The SBO was not on this and in fact the first LOSP was very low on the list. Then a sequence report was reviewed looking at LOSP only. Sequence
                                        #57 was the first SBO sequence and #58 was the second SBO sequence. The only difference between these was in the containment tree. With this is was realized that the containment tree was splitting up
("fractionalizing") the LOSP sequences, as opposed to some other sequences (such as ELOCA) which had one path through the containment tree. It was now realized that in order to analyze the sequences in the same context as previously, there needed to be a run of the event trees where the extra details of the containment tree suppressed. The utility staff ran this and the results and insights were noticeably different than before.
The results of the top ten were significantly different. The ELOCA and VSLOCA stayed the same value but now are sequences 2 and 4 respectively. The number 1 sequence is now loss of instrument air. ATWT on PLMFWA is number three (while the previous ATWT went to 12). Two sequences are control building flooding.
QU-03 QU-08                     YB     In ATWT, if the operators fail to trip the      In response to this          No impact to Fire reactor as an immediate action (top event       observation, the             PRA, because this OT) then subsequent operator actions RI and     BV2REV3B PRA model           issue was OA are failed. I suspect that this sequence     was revised to incorporate   addressed in the Page 194 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance   Status  Fact &Observation                              BVPS-2 Final Resolution      Impact to Fire ID      Requirement 1 Level          Closed                                                                              PRA I                            IYIN     I_                                                       _
has always been this way in the past, but with giving credit for the longer base PRA model the recent enhancements in the model, the      term operator action to      prior to building the sequence has risen into the top ten. This      emergency borate, even       Fire PRA.
leads to an overly conservative results in     though the earlier actions CDF. This appears to be the number 6 in        to manually trip the internal (#10 sequence in total CDF). Of the   reactor or to insert the top 50 sequences, 20% are ATWT. The total      control rods may have CDF for ATWT is a noticeable part of the       failed.
CDF, and would not support any future RI ATWT applications.                             The BV2REV3B PRA model was revised by removing the emergency boration (Top Event OA) human action dependency on prior ATWS human actions, which must be performed immediately; i.e., manual reactor trip (Top Event OT) and manual rod insertion (Top Event RI).
This involved editing the ATWS event tree split fraction logic rules for OAF by removing OT=F +
RI=F, as shown in Table 3.5-3 "ATWS Event Tree Logic Rules" of the Event Tree Analysis Notebook.
The basis for this change was derived from WCAP -
15831-P Section 5.1.1.12, where it is assumed that the operator action to Page 195 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                            BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level        Closed                                                                             PRA YIN emergency borate is independent of the previous operator actions since it does not need to be completed in the same short time period as the operator actions to trip the reactor, or manually drive in the control rods.
QU-04 AS-12          B            Y      An asymmetry discussion is provided in the    As a resolution to this       No impact to Fire PRA Quantification Notebook, section A.3. PRA Peer Review               PRA, because this The write-up includes general discussion      observation the PRA           issue was regarding the use of alignments to simulate   Quantification Notebook,      addressed in the the various modeling asymmetries in the       Section A.3 was revised       base PRA model systems modeling and the effect on event      to address which              prior to building the trees by partitioning some of the initiating  asymmetries are due to        Fire PRA.
event categories with some examples being     modeling and which are provided. Some of these asymmetries are       due to real plant due to modeling assumptions and some are      differences. Asymmetries due to actual plant differences. No specific  are also discussed in the discussion is provided to explain what system System Notebooks to asymmetries are due to simple modeling        explain where and why assumptions and which ones are due to plant   changes were made to differences.                                  reduce or eliminate them from the model and to identify the important ones that remain. Multiple examples can be given of where asymmetries were eliminated by applying initiating events to multiple trains (SW A & B) or multiple similar events such as floods and LOCAs. This helps to Page 196 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                          BVPS-2 Final Resolution     Impactto Fire ID     Requirement 1 Level        Closed                                                                         PRA YIN avoid asymmetries in importance on which train is running, or which piping loop is broken.
Furthermore, risk importance measures are grouped by BVPS system so asymmetries are negated when rating system importance.
Additionally, Risk importance measures of sister components (similar functions) on opposite trains are also conservatively set at the highest importance value to negate asymmetries.
By grouping these risk importance measures it ensures that Risk-Informed applications are not influenced by any PRA asymmetries.
QU-07  QU-15         B            Y      A review of the non-dominant sequences was  In response to this         No impact to Fire made. The non-dominant sequences are        observation, the split      PRA, because this those that are not normally saved when the  fraction logic rules were   issue was entire model is run. It was necessary to    re-examined and             addressed in the quantify one initiator at a time to get the compared to the             base PRA model cutsets below 4E-1 0. A review of these     dependency matrices,        prior to building the cutsets had the following observations:     The specific concerns       Fire PRA.
identified by the peer
: 1) SGTR 1.507E-12: IAF
* OD16B - how is     review were reviewed and OID possible when IA is failed?             corrected in the Page 197 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status   Fact & Observation                                 BVPS-2 Final Resolution         Impact to Fire ID    Requirement 1 Level        Closed                                                                                      PRA YIN BV2REV3B PRA model
: 2) TTrip 7.26E-1 1: AF1*OF1*OB4*CDF*RRI -         when in error. The ifAF, OF, OB and CD are failed, how can RR         BV2REV3B PRA model be asked in a probabilistic manner. RR             was then quantified using should be RRF.                                     only the Level 1 Top Events so that a review of
: 3) TTrip 3.233E-1 1:                               the CDF sequences could SAl *OS6*AF3A*OFF*OBF*CDF*RR1 - How                be performed to verify that can RR be asked in a probabilistic fashion         the revised split fraction after failure of all that?                         logic rules made sense.
This included looking at
: 4) TTrip 8.34E-12 AF1*MFF*OBI*CDF*RR1 - non-dominant sequences same question about RR?                            5 orders of magnitude lower than the total CDF
: 5) TTrip 1.1649E-12:                               value. Other concerns PR7*HH2A*OR3A*MU2: If HH2A is failed,              identified that were not in how can MU2 succeed? Does not MU2 use              error, were determined to the HHSI pumps?                                    have sufficient justification provided in the System
: 6) TLMFW 1.2559E-12: AF1*OF1*OB1*HH1:              Notebooks and Why is OF1 in the tree for Loss MFW? Why is Dependency Matrices.
OB1 in the same sequence as HH1. If OB1 fails, there is no initiation of HHSI, so why is I HH1 included?
QU-09  QU-31        B            Y        This element asks whether the sequence             As an interim resolution to     No impact to Fire results by sequence, sequence types, and           this PRA Peer Review            PRA, because this total was reviewed and compared to similar         observation a ballpark          issue was plants to assure reasonableness and identify       comparison was made             addressed in the any exceptions.      A review  of the PRA          utilizing the WOG PSA           base PRA model documentation did not reveal a comparison of Model and Results                     prior to building the the current PRA revision results to results of     Comparison Database,            Fire PRA.
similar plants.                                    Revision 3. Items compared included; initiating event I frequencies and their         I Page 198 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                              BVPS-2 Final Resolution   Impact to Fire ID      Requirement 1 Level        Closed                                                                          PRA YIN conditional CDF, component failure rates, human error rates, and success criteria. While, this review was not detailed no outliers were identified, and the conditional CDF from LOSP initiators was comparable with North Anna, a nearly identical plant.
This CA is being (was) rolled into CA 02-09043-30 to track its complete resolution.
Ultimately resolved by GAP F&O F&O IE-C10-01 (see Table 2-2).
QU-10   QU-30         B            Y      The initiating event frequency for interfacing In response to this       No impact to Fire system LOCA (i.e., initiator VSX) was          observation, the Monte    PRA, because this quantified using point estimates (result of    Carlo value generated for issue was 2.2E-7) and using Riskman's Monte Carlo        the updated interfacing   addressed in the algorithm (result 3.OE-7). The difference is   systems LOCA initiating   base PRA model explainable based on data dependence           event frequency in        prior to building the between valve failures,                        response to CA 02-09042-  Fire PRA.
02 previously identified, But the event tree quantification used the     was used in the lower, point estimate result. The 3.OE-7       quantification of the Monte Carlo result should be used in the       BV2REV3B PRA model.
quantification.
ST-02  ST-10         B            Y      The internal flooding analysis was done for    In response to this       No impact to Fire the IPE and has not been updated since then. Iobservation, the work that  PRA. This F&O Page 199 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. J Significance Status Fact & Observation                              BVPS-2 Final Resolution        Impact to Fire ID     Requirement'   Level        Closed                                                                                PRA I    _         YIN                                                                                 I All flood barriers were treated                 was completed for the          was resolved in deterministically and assumed to succeed.       Beaver Valley Unit 2 Risk-     the submitted The sub-criteria for this element suggests that Informed In-Service            BVPS-2 Fire PRA flood propagation pathways should include       Inspection (RI-ISI) Indirect   model, which used failure of doors, floor drains, and other flood (Spatial) Consequence          BV2REV5A as its barriers.                                       Evaluation, as well as,        basis.
several updated flooding analyses performed after the IPE submittal were reviewed. The results of this review determined that the flooding analyses did consider the potential of flood barrier failures due to the flood water static head on the door latching mechanisms. It was concluded that the IPE flooding analysis assumptions regarding the propagation of flood waters did consider flood barrier failures, and remains valid. No further flooding impacts were incorporated into the BV2REV3B PRA.
This F&O was written against an obsolete Internal Flooding PRA model (BV2REV3A) and is considered to be resolved by the updated Internal Floodinq PRA Page 200 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                                 BVPS-2 Final Resolution       Impact to Fire ID     Requirement' Level        Closed                                                                                  PRA YIN model incorporated in BV2REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
SY-01  SY-12        B            Y      Loss CCP/CCR results in a loss of seal water       An evaluation was             No impact to Fire heat exchanger cooling (discharges directly        performed to see at what      PRA, because this to the charging pump suction) as well as loss      temperature the available     issue was of non-Regenerative heat exchanger cooling         NPSH would be lower           determined to (discharges to the VCT). The result is a           than the required NPSH at have no effect on potential common mode failure of all charging      the charging/HHSI pump        the BVPS PRA pumps due to an increasing charging pump           design flowrate. The          model.
inlet temperature, coupled with the loss of        results of this evaluation CCP/CCR, this results in an RCP seal LOCA.         revealed that the VCT Riskman macro RWSTSO (VCT swap-over to             temperature would have RWST) contains logic to include the failure of     to increase by more than the components required to perform this            123 OF for this condition to action, but the operator action is not included,   be true and result in a loss Given the uncertainty of the time to charging      of NPSH. With multiple pump failure, the operator action may              high temperature alarms dominate the mechanical component failures,        coming in at more than 100 OF prior to reaching this temperature, there would be plenty of time available to operators to I perform mitigating actions. I Page 201 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status   Fact& Observation                                BVPS-2 Final Resolution      Impact to Fire ID    Requirement 1 Level        Closed                                                                                 PRA YIN Moreover, a loss of NPSH would only impact the running charging pump, since the standby pump does not automatically start, unless a Safety Injection Signal is present, in which case the suction would automatically swap over to the RWST. The third pump would only be manually aligned and started following the failure of the first two normally aligned pumps.
Therefore, this observation was not considered to be a valid common cause failure mechanism of the charging/HHSI pumps, so the operator action was not included in the BV2REV3B PRA model.
SY-02  SY-03        B            Y        The degree of documentation in the systems       The Riskman Split            No impact to Fire analysis should provide enough detail that the   Fraction and Common          PRA, because this systems analysis can be duplicated with          Cause Tables are             issue was minimal effort. A review of the Auxiliary        attached as an Appendix      addressed in the Feedwater System Notebook (Book 2, Tab 2)        to each of the System        base PRA model and the Main Feedwater System (Book 3,           Notebooks. These tables      prior to building the Tab 6) revealed that the Split Fraction          contain the necessary        Fire PRA.
definition / truth tables are not documented     split fraction and Common and the Common Cause assumptions are not         Cause information. This documented. There is no discussion as to         action closes this issue.
I where these assumptions came from or the       I Page 202 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. 1 Significance Status Fact & Observation                                BVPS-2 Final Resolution      Impact to Fire ID     Requirement Level          Closed                                                                                PRA YIN definition of the split fractions utilized in the Systems Analysis. The absence of this information could result in the inability to reproduce the Systems Analysis for verification of results or future applications.
SY-03  SY-15         B            Y      Some initiator dependent component failure        The LHSI initiator success   No impact to Fire modes do not appear to be modeled. For            criteria was reviewed to     PRA, because this example, the S18890 MOVs are included in          address the specific PRA     issue was the model for fail to open to prevent LHSI        peer review concerns.        determined to pump overheating during low flow conditions.      Once such concern was        have no effect on For this specific example, large LOCAs            that the LHSI fault tree     the BVPS PRA should only consider transfer open as a flow      modeled the failure to       model.
diversion; failure to open is not applicable. open of the mini-flow For small LOCAs, the failure to open is           MOVs during a small correctly modeled, but transfer closed should     break LOCA, but did not also be included. For medium LOCAs, the           model the transfer closed need to open or close the S18890's may            failure. Typically the PRA require additional thermal hydraulic analyses. only modeled passive Other system designs susceptible to initiator     failures (e.g., transfer specific failure modes include systems with       closed) if there were no pumps which have mini-flow which return to        active failure modes (e.g.,
the pump's suction. Systems like this may         failure to open) modeled, require operator action to stop these pumps if since the active failures downstream pressure prevents adequate flow dominate the components to prevent pump overheating.                      failure probability (usually by three orders of magnitude). Therefore, this concern was not incorporated into the BV2REV3B PRA model update. Another concern was that the LHSI fault tree always queried the opening of the pump mini-flow valves even though Page 203 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact& Observation          BVPS-2 Final Resolution       Impact to Fire ID     Requirement'   Level          Closed                                                            PRA I              I YIN    II                                                       I/N they would not be required to open during a large break LOCA, and that doing so may provide a flow diversion. To address this concern the BVPS-2 LHSI fluid flow model was reviewed for large LOCAs with and without the mini-flow value opened. It was concluded that the difference in flow delivered to the reactor vessel was less than 75 gpm if the mini-flow valve remained open.
Therefore, this was not determined to be a valid flow diversion path and was not incorporated into the BV2REV3B PRA model. Additionally, while including the mini-flow valve failure to open for large break LOCAs is not required, the Large break LOCA contribution to total CDF is less that 0.1 percent, so it was not considered to be vital to remove it from the BV2REV3A PRA model.
The other Top Event fault trees for systems with mini-flow protected DumDs Page 204 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status    Fact & Observation                           BVPS-2 Final Resolution    Impact to Fire ID     Requirement 1  Level        Closed                                                                            PRA YIN were reviewed to ensure that there were no obvious potential for initiator specific success criteria missing form the model. It was found that the Recirculation Spray System Trains C and D also have the same type of mini-flow valve failure modes modeled as the LHSI pumps, so the above justification also applies. All other systems with mini-flow valves were not considered to be dependent on the initiating event.
SY-06  SY-06           B           Y         Assumptions concerning non-modeled failure   As a resolution to this    No impact to Fire modes, or support systems due to low         PRA Peer Review            PRA, because this frequency sequences need to be               observation, guidance      issue was reconsidered with respect to specific        was added to the System    addressed in the applications. For example, condenser hotwell Analysis and Overview      base PRA model level is assumed to always be adequate due   Notebook to include        prior to building the to redundancy of sources (i.e., via steam    assumptions concerning     Fire PRA.
dumps, or makeup); however, some of these    non-modeled failure sources may not be available during online   modes, or support T/M.                                         systems.
Also many of these done when the CDF was in the 2E-4 range. Now that CDF is in 8E-6 range many of these items may no longer be insignificant in the current model.
SY-16  SY-13           B           Y         The sequence modeling credits RWST refill    An evaluation was          No impact to Fire I             II                _Ifor     LOCA's and SGTR. The RAW worths of       performed using the        PRA, because this Page 205 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                                BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level         Closed                                                                                  PRA I_             I              YIN    I                                                 II the split fractions indicate that without RWST,   BVPS Unit 2 Cycle 10         issue was CDF would be 3.8E-5. RWST refill is modeled       core design analysis         determined to in split fractions WM and MU.                     (WCAP-15779, Rev. 0)         have no effect on boron requirements for       the BVPS PRA The minimum make up rate is 150 gpm. The          shutdown (k=0.99) at         model.
actual makeup rate [if this procedure was         beginning of life and hot used] may be up to 400 gpm. The initial water     zero power as the source for RWST refill is the boric acid          minimum required boron blenders. This system has a 7,000 gallon          concentration to prevent tank at 7,000 ppm boron. This system does         recriticality. The results not have sufficient volume nor flow rate to       of this evaluation match the times and volumes needed for safe       determined that the boron shutdown in the sequences modeled. The            concentration delivered to ultimate source of water is unborated river       the RCS would be above water. To provide enough input to the RWST,       the minimum required to the flow path is into the Fuel Pool and then      maintain subcriticality for from the fuel pool to the RWST.                   the entire 24-hour mission time, when using The Miscellaneous Notebook documentation           unborated water for states "The current BV2REV3A PRA model             makeup to the RWST at assumes that 400 gpm is required for              the flowrates determined makeup to the RWST during the entire               in the MAAP LOCA mission time." Boron dilution of the fuel pool    success criteria analyses.
is calculated, but not boron dilution of the      Additional operator core. The observation is that if unborated         actions to add boron to water was used to make-up for the times           the RWST via the spent required, boron dilution could occur in the        fuel pool, to increase the core, thus negating the RWST make up               shutdown margin, could function. Due to the fact that RWST cause          be implemented, but were significant core damage reduction, the ability     not credited in the PRA to use RWST make-up should have a more             model. The BV2REV3B substantial analytical basis.                      PRA model was not changed as a result of this This observation is worse for unit 2 than unit     observation.
1, because of the smaller RWST volume. The Page 206 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance  Status Fact &Observation                                 BVPS-2 Final Resolution      Impactto Fire ID      Requirement'   Level         Closed                                                                                PRA I
_              I              IYIN    I minimum core boron concentration for hot        A precaution was also zero power at BOL is 771 ppm. For most of       added to BVPS-2 OM the sequences where RWST make-up is             Procedure 20M-7.4.O used, the reactor is assumed to be              "Makeup To The depressurized and cooled down [LOCA's and       Refueling Water Storage SGTR]. For the purpose of this F&O, it is       Tank," that if a significant assumed necessary to maintain a 1500 ppm        volume of river water is boron concentration. The RWST switchover        added to the Spent Fuel is 140,000 gallons for unit 1 and 360,000       Pool, boric acid addition to gallons for unit 2. Times to boron dilution (in the Spent Fuel Pool may the RWST) is shown below:                       be required to maintain adequate shutdown Unit 1 dilution to 771 ppm at 150 gpm = 15h     margin.
Unit 1 dilution to 771 ppm at 400 gpm = 5h Unit 1 dilution to 1500 ppm at 150 gpm = 4.5h Unit 1 dilution to 1500 ppm at 400 gpm = 1.7h Unit 2 dilution to 771 ppm at 150 gpm = 38 h Unit 2 dilution to 771 ppm at 400 gpm = 14h Unit 2 dilution to 1500 ppm at 150 gpm =
11.5h Unit 2 dilution to 1500 ppm at 400 gpm = 4.3h Only one of these conditions can meet a 24 hour mission time.
Considering that RWST make-up is used to lower CDF and LERF to the extent it does, the technical basis should be stronger. The calculation must match the conditions of the sequences for which it is used, must use a representative flow rate, and must consider the uncertainties in the inputs and the outcome.
SY-17   SY-21          B              Y       Service Water success criteria appears to       The Service Water            No impact to Fire have no supporting analysis as to 1 service     System Design Basis          PRA, because this Page 207 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                                BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                                PRA YIN water cooling pump could provide sufficient       Document provides the        issue was flow. Additionally, there appears to be some      basis for one pump           addressed in the HEP for some manual operator action to start      operation to meet the        base PRA model standby pumps under some circumstances.           single failure criterion and prior to building the No success criteria for the time available for    still provide adequate       Fire PRA.
these actions was found.                          station cooling under accident conditions.
Table 3-1 of the Human Reliability Analysis PRA Notebook gives a summary description of the Service Water human actions analyzed in this study. Also provided in this table are the time windows that are available to the operators in the performance of the task described along with the basis for the timing.
TH-02  TH-08         B            Y      The Beaver Valley Unit 2 Ventilation and          The Unit 2 Ventilation and   No impact to Fire Room Cooling Analysis Notebook Table 7           Room Cooling Analysis        PRA, because this lists that for item 10, Control Building,        Notebook only looked at a    issue was Operators add portable fans; not included in      loss of ventilation in the   determined to risk model. It appears from Figure A-9           Unit 2 side of the Control   have no effect on "Temperature as a Function of Time in             Building. In reality, the    the BVPS PRA Control Room with No Ventilation-Fan Added       Unit 1 and Unit 2 Control    model.
in 10 Minutes," that without the addition of the Rooms are located within fans the temperature in the Main Control          the same building Room would impact instrument qualification,      separated by a partial wall Though this appears to be an important            (there is no wall above the operator action that justified not adding MCR    "egg crate" ceiling), so a HVAC to the model, there is no operator          loss of ventilation at one action to add fans for MCR cooling within 10     unit will not result in the Page 208 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting.      Significance   Status   Fact & Observation                           BVPS-2 Final Resolution        Impact to Fire ID     Requirement 1   Level          Closed                                                                               PRA I              I_Y/N    I                                                                           I minutes.                                     total loss of ventilation to the common Control Additional investigation into the MCR heatup Building. As resolution to calculation 12241-US(B)-21 1 revealed that   this observation, a two different values were used for the MCR   separate calculation heat load. Page C-4 uses a MCR heatup        (8700-DMC-3467, Rev. 1) value of 156,861 BTU/hr (-46000W) and        was reviewed, which was page IPE-4 uses 74665W. The trend shown      previously performed in on Figure C-3 is the more expected MCR       response to an Appendix room heatup, rather than the temperature     R Unit 1 Control Room spike seen on IPE-9.                         Ventilation fire. This calculation combined the Control Room volumes and heat loads, and took credit for the Unit 2 HVAC to cool both Control Room areas. While it was noted that this calculation was performed assuming a loss of Unit 1 HVAC it was determined to be applicable to a loss of Unit 2 HVAC as well, since the HVAC flow rate were similar at each unit. The results of this analysis concluded that during a loss of ventilation at one Unit, the Control Building temperature would remain below the Equipment Qualification limits during a 24-hour mission time, even without setting up portable ventilation fans.
Page 209 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution    Impact to Fire ID     RequirementI Level        Closed                                                                            PRA YIN This analysis assumed a homogenous mixture of air existed between the Control Rooms, so itwas assumed that the operators would open the common doors between the Control Rooms to aid in cooling. This action was assumed to be a guaranteed success in the PRA model, since both Control Rooms are continuously manned and human nature would drive the operators to do so after they begin to feel uncomfortable. It was determined that this observation did not impact the PRA model, so the recommend changes were not incorporated into the BV2REV3B PRA model.
AS-01  AS-12        C            Y      Beaver Valley is using a modified version of    As a resolution to this    No impact to Fire the WOG 2000 seal LOCA model, which is          PRA Peer Review            PRA, because this derived from the BNL "best estimate" model,     observation, sensitivity   issue was with Beaver Valley specific MAAP runs for       analyses were performed    addressed in the time to core uncovery. The time of the start of on the BVPS Unit 1 MAAP    base PRA model excessive leakage is 30 minutes in this         RCP seal LOCA cases to     prior to building the model. The NRC has not accepted this from       investigate the impact of  Fire PRA.
licensing submittals. Since Beaver Valley is    varying the timing of the planning some extensive AOT submittals in       increased RCP seal the future, this will have to be addressed. leakage from 30 to 13 Page 210 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting.      Significance   Status     Fact & Observation                      BVPS-2 Final Resolution       Impact to Fire ID      Requirement'     Level          Closed                                                                           PRA YIN     I minutes on the resultant time to core damage. The conclusion from these sensitivities was that the change in onset of the increased RCP seal LOCA leakage from 30 minutes to the minimum time of 13 minutes would not lead to significantly earlier times to core damage. Since the BVPS RCP Seal LOCA models are comparable between Unit 1 and Unit 2, it was concluded that there would be similar insignificant core damage timing impacts at Unit 2.
Therefore, it was concluded that the time to core damage provided in Attachment A, Appendix E, of this notebook for the RCP seal LOCA sequences is sufficient for use in the electric power recovery models.
The e-mail from Fauske &
Associates to FENOC transmitting the results of these BVPS-1 MAAP SBO sensitivity runs is provided in Appendix E of A              .1.              U        .1. _________________________________________________________________________________________
                                                                                        -.                             J Page 211 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                              BVPS-2 Final Resolution     Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA YIN the BVPS-2 Electric Power Recovery Analysis PRA Notebook.
Ultimately resolved based on WCAP-1 5603, Rev. 1-A, NRC Approved, May 2003, Seal LOCA start time is 13 min.
AS-04  AS-07         C            Y      AMSAC is a mitigation system that only         In response to this PRA     No impact to Fire appears in the ATWS tree. Actually AMSAC       Peer Review observation,    PRA, because this is a redundant start of AFW and turbine trip   the GENTRANS Event          issue was that is useful in mitigation even when SSPS    Tree (see Figure D-4a)      addressed in the has failed but the reactor trip has been       was modified to include     base PRA model successful. Additionally AMSAC is only model   Top Event PL (Power         prior to building the as a system point estimate of 1E-2 (see F&O    Level <40 %)and Top         Fire PRA.
SY-20). This could affect/reduce the           Event AS (ATWS system/equipment importance of SSPS, AFW       Mitigating System and Turbine Trip                               Actuation Circuitry) before asking Auxiliary Feedwater in Top Event AF. The split fraction logic rules and macros were also modified to credit the use of AMSAC for providing a diverse method of starting the AFW pumps (see Tables 3.4-3 &3.4-4). Section 3.4 "General Transient/Small LOCA Event Trees" and Tables 3.4-1 and 3.4-2 were also revised to account for I these new top events in Page 212 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance     Status   Fact & Observation          BVPS-2 Final Resolution       Impact to Fire ID     Requirement'    Level            Closed                                                             PRA
_ _ __ _ __ _ _  __   ___    _   YN_        _ _ _ _ _ _ _ _ _ _ _ _ _       _ _ _ _ _ _              _ _   _   _   _ _
I the GENTRANS Event Tree.
I Y/N With respect to the AMSAC top event being quantified using a point estimate value instead of a fault tree analysis, it was not deemed necessary to pursue a detailed fault tree analysis at this time.
The point estimate value of 1.OE-02/demand used in the BVPS PRA models is taken from WCAP -
11993 (Reference 1) and is conservative with respect to unavailabilities of a one signal train and the design criteria applied to AMSAC by the Westinghouse Owner's Group. Additionally, the more recent WCAP-15831-P (Reference 14) also uses this point estimate value, as has other studies, as an appropriate value to use.
A detailed fault tree would probably result in a lower AMSAC unavailability value, but this is not expected to have a siqnificant imDact on the Page 213 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting.         Significance  Status   Fact& Observation                                    BVPS-2 Final Resolution        Impact to Fire ID      Requirement'        Level         Closed                                                                                       PRA YIN core damage frequency, due to the already low significance of SSPS failures in non-ATWS
_sequences.                    I AS-09   AS-18               C             Y        The SGTR event tree assumes that the                 The concerns of this PRA       No impact to Fire actuation of PORVs (should be PORV due to            Peer Review observation        PRA, because this definition of B&F success criteria) will result in   are unfounded, since the       issue was the CIB (8 psig) actuation. A review of the          timing of the CIB initiation   determined to MAAP runs (Success Criteria, Attachment A,           following bleed-and-feed       have no effect on Appendix F, Table 3) indicates that CIB              scenarios during a SGTR        the BVPS PRA occurs for cases in which OB (B&F) is                will not impact the NPSH       model.
successful for cases in which AFW is failed          of the HHSI pumps. This and it occurs in approximately 2 hours. The          CA was dispositioned by QSS is assumed to be actuated given the              examining the MAAP CIB signal. The water injected to the                SGTR accident sequence containment sump is necessary for NPSH               summary files as success. It isn't clear what will happen in the      summarized below:
case that CIB does not occur until 2 hours into the scenario and what effect this may           For the SGTR cases with have on the NPSH concerns.                           a loss of secondary cooling, the HHSI pumps will initially be taking suction from the RWST, either due to an SI signal being generated or to the bleed-and-feed initiation.
After about 6 minutes following the initiating of bleed-and-feed, the containment sump would begin to fill when the PRT rupture disc blows.
During this time there will I _______________ .1. _____________ ________ _____________________________________________      a be RCS mass and energy Page 214 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting.      Significance     Status   Fact & Observation            BVPS-2 Final Resolution       Impact to Fire ID       Requirement 1   Level            Closed                                                               PRA I _I_                             YIN    I                             I released inside of the containment from the open PORVs, which will slowly start to increase the containment pressure and also be providing inventory directly into the containment sump.
After approximately 2 hours a CIB occurs, and QSS will start and also begin to add RWST inventory into the sump, so that when the RSS pumps start about 10 minutes later there should be sufficient inventory in the sump to provide adequate NPSH to the RSS pumps. However, if a sufficient amount of water is not collected in the containment sump after this time, the recirculating spray pumps must be manually turned off and then turned back on when NPSH is sufficient. Operator actions to first turn off and then to turn on the RSS pumps are modeled in Top Events SM and OR.
I                I              .1.
Success of these actions Page 215 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                            BVPS-2 Final Resolution       Impact to Fire ID      Requirement'   Level        Closed                                                                             PRA
_       _      YIN    __I                                                                       I ensures that the RSS pumps will be available when the RWST reaches the low-level setpoint and SI Recirculation is initiated. At this time the HHSI pumps would be piggybacked onto the RSS pumps, and adequate NPSH would be provided.
Prior to this CIB signal being generated, the QSS and RSS will not start.
However, the HHSI pumps will continue to take suction from the RWST until the low level SI Recirculation setpoint is reached. At this time even without a CIB initiation, approximately 350,000 gallons of RWST water would have been directed into the containment sump though the opened PORVs, so that when the HHSI pumps are piggybacked onto the RSS pumps, adequate NPSH would also be provided.
DA-03  DA-03          C            Y      The documentation of the CCF MGL              The resolution to this F&O     No impact to Fire parameters is presented in Appendix C of the] was to put highlighted         PRA, because this Page 216 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                                BVPS-2 Final Resolution     Impact to Fire ID     Requirement 1 Level        Closed                                                                               PRA YIN Data Analysis Notebook. The final                 shading and bold text in    issue was compilation of the MGL parameters is              Table C-6 of the BVPS       addressed in the presented in Table C-6. The results are           Unit 2 Data Analysis PRA    base PRA model presented as "Plant-Specific" distributions,      Notebook for the MGL        prior to building the but this table is in fact a mix of parameters     distributions that were     Fire PRA.
developed based on plant specific event           developed based on a screening, in some cases Bayesian updating,       plant specific analysis, so and in other cases generic data. With some        that they are more easily difficulty, the reviewer could trace back         identified. This table was through the documentation to determine the        also renamed to Table C-actual source of the MGL parameter, but a         6 Beaver Valley Unit 2 -
naming convention that identifies the             Common Cause MGL parameter as plant specific, or generic would     Distributions, so that it be helpful. As a minimum, generic data could      does not imply that all the be presented in a separate table from the         MGL distributions are parameters generated based on plant specific      plant-specific.
analysis.
DA-04  DA-05         C            Y      The data notebook describes several sources       F&O DA-04 was originally No impact to Fire for the generic component failure distributions   assigned as a "B"Level of PRA, because this for the BV Unit 2 model. Column 6 provides        Significance in the draft   issue was the disposition of the 6 sources of               WOG PRA Peer Review         addressed in the information. Item f- 994 STP data was used        Report, but was             base PRA model to derive the failure rate distribution for the   downgraded to a "C" in      prior to building the automatic recirculation check valve failure to    the final report. This      Fire PRA.
open and was cloned from ZTVCOS using             observation was resolved PLG generic check valve database                  by adding discussions to distributions. Then the data from STP of 0 in     Section 3.5.F "1994 STP 704 demands was used. It is not clear what        Data" of the BVPS-2 Data this database variable was used for and if itis   Analysis PRA Notebook currently being used. The discussion does         as to why and how the not indicate why was no information used          database variable for the from the BV plant history in this update          automatic recirculation process.                                          check valve failure to open (ZTVARD) was I developed, as well as an Page 217 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA YIN explanation as to why there wasn't any plant specific data included in the update.                 _
DA-05  DA-03         C            Y      Table C-6 lists the Beta factor for battery     This PRA Peer Review         No impact to Fire failure fails to operate (ZBBCHR) as a point    observation was              PRA, because this estimate of 1.26E-2. The source of this value   dispositioned during the     issue was is not documented in the Data Analysis          resolution of F&O DA-06      addressed in the Notebook. A review of the EP System             (CA 02-09042-12).            base PRA model Notebook found a reference to this value in     Although, Appendix C         prior to building the an assumption, stating that the value was       does not specifically list   Fire PRA.
taken from NUREG/CR-5497. Appendix C of         the source document the Data Analysis Notebook should be self       references, they are contained with respect to the source of the     specifically identified in generic MGL. Appendix C does not                Section 3.6 "Calculation of reference NUREG/CR-5497. Are all other          Common Cause Factors,"
generic parameters actually from the PLG        and are included in database or are other sources used? Is this     Section 5 "References" in the only value taken from 5497? What was        the Data Analysis PRA the basis for using one selected value from     Notebook. Section 3.6 5497?                                           also provides the basis for using common cause data sources other than the PLG common cause database.
DA-1 1 DA-05         C            Y      A statement needs to be made in the             This PRA Peer Review         No impact to Fire assumptions to describe the method of           observation was              PRA, because this assembling the data. The write-up implies       dispositioned by adding a    issue was that only unit 2 data is included in the tables discussion in Section 3.3    addressed in the but there appears that some unit 1 pumps        "Presentation of Plant-      base PRA model may have been included. If this is the case,    Specific Data" of the Data   prior to building the then the text needs to explain that Unit 2      Analysis PRA Notebook to     Fire PRA.
equipment is included and only the Unit 1       identify what Unit 1 equipment that may be needed to shutdown        equipment is included in Unit 2 is included,                            the development of the Page 218 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution     Impact to Fire ID     Requirement 1 Level        Closed                                                                             PRA YIN Unit 2 database distributions or test and maintenance unavailabilities.
DE-02  DE-04         C            Y      In a limited review of the dependency           Most of the concerns of     No impact to Fire matrices in Appendix B of the Event Tree        this PRA Peer Review        PRA, because this Analysis Notebook, it appears that some         observation are             issue was items maybe missing.                            unfounded, and are          addressed in the attributed to a lack of     base PRA model
                                         - There appeared to be no dependencies          understanding of how to     prior to building the listed for instrument AC inverters 2-3 and 2-4, read the matrices. For      Fire PRA.
but it was later noticed that that was covered  example, sheet 2 of Table by a footnote in the AC section (2-1 & 2-2 had  B-2 "Support-to-Frontline the footnote in both places).                   System Dependency Table" does list Note 30
                                         - Note 33 does not state the DC power for       for the DC dependencies.
RTB shunt coil "B".                             Likewise, sheet 1 of Table B-1 "Support-to-Support
                                         - No DC power for containment isolation         System Dependency valves was listed.                              Table" identifies vital bus III and vital bus IV as
                                         - No AC dependencies for AC power for           failing AMSAC.
instrument AC were identified.                  Additionally, sheet 2 of Table B-1 lists Note 43 for
                                         - There are no dependencies shown for           the AMSAC DC AMSAC, but that maybe appropriate for the       dependencies.
level of detail of AMSAC modeling.
However, as the Team observed, Note 33 of Table B-1 "Support-to-Support System Dependency Table" did not state the DC power for RTB "B" shunt coil, so this note was revised to Page 219 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                             BVPS-2 Final Resolution      Impact to Fire ID     Requirement Level        Closed                                                                            PRA YIN address this oversight.
Also, Notes 4 and 5 were added to Table B-1 vital bus III and vital bus IV matrices to clarify their DC dependencies, while these same notes already identified the AC dependencies.
DE-03  DE-1 1      C            Y      The flooding analysis and the IPE state       Since the documentation      No impact to Fire (briefly) that a plant walkdown was           for the flooding walkdown    PRA. This F&O performed. But there is no documentation of   that was performed as        was resolved in the walkdown, or the insights gained from the part of the IPE could not    the submitted walkdown, available for review. The           be located, the walkdown     BVPS-2 Fire PRA walkdown "notebook" would be a valuable       that was completed for the   model, which used resource for analyst in future updates of the Beaver Valley Unit 2 Risk-   BV2REV5A as its PRA.                                          Informed In-Service          basis.
Inspection (RI-ISI) Indirect (Spatial) Consequence Evaluation was credited, as discussed in the response to F&O DE-04 above. Since this RI-ISI walkdown is documented in a BVPS calculation and is retrievable, it is not deemed necessary to reproduce it for the PRA notebooks.
This F&O was written against an obsolete Internal Flooding PRA model (BV2REV3A) and is considered to be Page 220 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                           BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                           PRA YIN resolved by the updated Internal Flooding PRA model incorporated in BV2REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
DE-06  SY            C            Y      Some of the flood frequencies are based on a This F&O was written         No impact to Fire document (PLG-0624) that is dated 1988.      against an obsolete          PRA. This F&O The next update should include consideration Internal Flooding PRA        was resolved in of more recent flood data sources.           model (BV2REV3A) and         the submitted is considered to be          BVPS-2 Fire PRA resolved by the updated      model, which used Internal Flooding PRA        BV2REV5A as its model incorporated in        basis.
BV2REV5A, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions Page 221 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA Y/N are presented in Table 2-4.
DE-07  SY            C            Y      The PRA documentation should include a          This F&O was written         No impact to Fire discussion of the potential impact of floods on against an obsolete          PRA. This F&O systems that are shared between the two         Internal Flooding PRA        was resolved in units. Although this impact is expected to be   model (BV2REV3A) and         the submitted minimal, one example is the potential impact    is considered to be          BVPS-2 Fire PRA on the electric power crosstie to Unit 1        resolved by the updated      model, which used availability due to floods in the service water Internal Flooding PRA        BV2REV5A as its intake structure. Is the Unit 1 diesel          model incorporated in        basis.
dependence on service water correctly           BV2REV5A, which accounted for when the flood impacts the        underwent a focused Peer availability of the Unit 1 service water        Review in accordance system?                                         with the guidance in Appendix B of NRC RG 1.200, Rev. 1, conducted during June 6-9 2011, by the PWR Owners Group.
The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
HR-02  HR-06         C            Y      A generic error of omission term from the       This F&O was written         No impact to Fire PLG database (ZHEO1A) was used for all          against an obsolete HRA      PRA, because this misalignment HEPs without regard for            PRA model (BV2REV3B)         issue was procedural or operational failure barriers such and is considered to be      addressed in the as independent verification, peer checks,       resolved by the updated      base PRA model walkdowns, etc. However, plant specific data    HRA PRA model                prior to building the was used for test and maintenance               incorporated in BV2REV4,     Fire PRA.
frequencies. Therefore, the overall             which underwent a misalignment errors were a hybrid of generic    focused Peer Review in and plant specific data. This was used for      accordance with the systems which are important to CDF (e.g.,       guidance in Appendix B of AF, SI).                                        NRC RG 1.200, Rev.1, Page 222 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                                BVPS-2 Final Resolution       Impact to Fire ID     Requirement 1 Level        Closed                                                                                 PRA YIN conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
HR-10  HR-18         C            Y      The number of operators interviewed for the       This PRA Peer Review          No impact to Fire performance shaping factors was stated to be      observation was               PRA, because this 3 operators, 3 training staff and 3 PRA staff. dispositioned by              issue was This is a low number of operators for the         acknowledging that, while     addressed in the FLIM method to succeed. Having the PRA            technically only 3            base PRA model staff fill out the PSF forms dilutes the operator operators were                prior to building the input to the process.                             interviewed, the training     Fire PRA.
staff personnel were former operators that still held a senior reactor operator's license at the time of the interview.
Therefore, a total of six licensed personnel were used in developing the PSFs. Additionally, as a final resolution to this observation, future BVPS PRA models will use the EPRI HRA Calculator, which uses a more current and robust methodology to identify human action dependencies.
This F&O was written        I Page 223 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                               BVPS-2 Final Resolution     Impact to Fire ID      Requirement' Level        Closed                                                                              PRA YIN against an obsolete HRA PRA model (BV2REV3B) and is considered to be resolved by the updated HRA PRA model incorporated in BV2REV4, which underwent a focused Peer Review in accordance with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during the week of October 29, 2007, by Westinghouse. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 1-3.
IE-01   IE-04        C            Y       In section 3.3 of the Initiating Events         In response to this         No impact to Fire Notebook, there is a discussion about the       observation, Section 3.3    PRA, because this justification for the exclusion of Random RCP of the Initiating Events       issue was Seal LOCAs as a separate IE that is based        Analysis PRA Notebook       addressed in the on the RCP floating ring seals and the           was revised to add further  base PRA model assumption of limited leak flow. The             clarification based on the  prior to building the justification provided to account for assuming   floating ring seals (per    Fire PRA.
this is a discussion by FENOC with               Reference 15) as to why Westinghouse. No documentation of this           random RCP seal LOCAs discussion is provided and no further           were eliminated from the technical justification is given as to why      Beaver Valley PRA random seal failure should have the             model. Additionally, this frequency and be included in Category           Section was revised to G1I/QG9 under RTRIP.                            provide justification as to why a random RCP seal I failure at Beaver Valley Page 224 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact& Observation                            BVPS-2 Final Resolution       Impact to Fire ID      Requirement 1 Level        Closed                                                                            PRA YIN that resulted in a reactor trip would be captured under the RTRIP initiating event frequency.
IE-02   IE-13         C            Y      In the discussion of the process used for    In response to this           No impact to Fire Initiating Event frequency update, BWR data  observation, Section 2.3      PRA, because this and other NSSS vendor PWRs are excluded      of the Initiating Events      issue was from the update without sufficient           Analysis PRA Notebook         addressed in the documentation.                               was revised to provide a      base PRA model brief explanation for why     prior to building the BWR and other PWR             Fire PRA.
NSSS vendor data were excluded from the BVPS initiating event frequency update.
IE-03   IE-10         C            Y      The Support System Faults that are used as   In response to this           No impact to Fire Initiating Events are assigned a Code        observation Tables Al         PRA, because this Designator. The System Codes and Top         and A9 in the Initiating      issue was Events for these designators are not         Events Analysis PRA           addressed in the explained. The System Notebook does not      Notebook were revised to      base PRA model clearly explain how the System is considered include a cross-reference     prior to building the to cause an Initiating Event in the Model. from the initiating event     Fire PRA.
                                                                                       "Code Designator" to the applicable PRA System Notebook. In addition, Table A2 of this notebook provides a failure modes and effects analysis of the key BVPS Unit 2 support systems and why they were considered for initiating events, so it was not judged to be necessary to duplicate this information in the Page 225 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions on System Notebooks. It was not the intent of the PRA System Notebooks to be stand-alone documents, but rather to be supplemented by the PRA analysis notebooks. 4-Plant trip trends in the recent years are          In response to this            No impact to Fire showing a general decrease in trips/year. A        observation, Figure 3-1        PRA, because this simple trend analysis (like a histogram)           was generated to present       issue was showing number of trips versus years for           a plan trip trend histogram    addressed in the each unit should be considered as a                and Section 3.2 of the         base PRA model subsection in the initiating events section.       Initiating Events PRA          prior to building the This would possibly allow better estimation of     Notebook was revised to        Fire PRA.
plant specific transient event frequency.          include a discussion of the Currently, there appears to be no analysis to      plant trip trend analysis show whether there is a positive or negative       performed for BVPS Unit trend (or a lack of it). Also, a trend analysis    2.
fits well with the concept of plant-specific nature of analysis in question.
For example, consider a plant with 10 years of trip data; the first 5 years each have 5 trips/year; the last 5 years have 1 trip per year. This would result in an average of 3 events per year over a ten-year period. Now consider another plant where the two numbers are interchanged; it has 1 event per year for the first five years and 5 events per year for the next five years. The overall average is still 3 events per year. In both cases, there are definite trends; the first plant should actually use a frequency of 1 trip per year; the second plant should use 5 trips per year. In any case, neither plant should use 3 Page 226 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact& Observation                              BVPS-2 Final Resolution       Impactto Fire ID      Requirement' Level        Closed                                                                              PRA YIN
__                                      trips per year.
IE-07   IE-03        C            Y      There was not enough information in the        In response to this           No impact to Fire initiating event report to reproduce the       observation, Table Al 1       PRA, because this results.                                       was generated in              issue was Appendix A of the             addressed in the
: 1. The prior distributions were not available. Initiating Events Analysis    base PRA model PRA Notebook to show          prior to building the
: 2. the screening of the WCAP IE report was     the set of input data used    Fire PRA.
not available                                  in the creation of each first stage (prior) distribution
: 3. The derivation of prior means was not       identified in Table A4, as available.                                     well as, the resultant RISKMAN distribution parameters for the mean, median, 5th and the 95th percentiles. This data was input into the RISKMAN Data Module, using the "First Stage of Two Stage" distribution option to create the resultant prior distributions. The derivation of how RISKMAN generates these prior distributions using this option is contained in the RISKMAN Software Users Manual, and does not need to be reproduced in this notebook.
Additionally, there was no screening of the Westinqhouse WCAP-Page 227 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance  Status Fact& Observation                                BVPS-2 Final Resolution      Impact to Fire ID      Requirement' Level         Closed                                                                               PRA Y/N 15210 initiating event data, since each individual utility performed a through review of their plant's trip events to ensure that the data was valid.
L2-02   1-2-08       C             Y       Most containment phenomena are either           Ultimately resolved by       No impact to Fire excluded via generic, or plant specific         GAP F&O LE-F2-01 (see        PRA, because this analyses, or are modeled as a point estimate. Table 2-2).                  issue was Other issues such as whether the                                             addressed in the containment is inerted are more directly                                     base PRA model quantified. For example, the L1/L2 interface                                 prior to building the directly quantifies those end states when the                                Fire PRA.
sprays are operating; operation of the sprays is considered to de-inert containment.
L2-04   L2-21        C             Y       Top Event 10 - Containment Failure Prior to     Ultimately resolved by       No impact to Fire Vessel Breach (Cl) states that because the      GAP F&O LE-D6-01 (see        PRA, because this Beaver Valley Unit 2 containment normally      Table 2-2).                  issue was operates at subatmospheric conditions, the                                   addressed in the existence of large pre-existing leaks is                                     base PRA model believed to be negligible. Current L2 analysis                              prior to building the would not support containment conversion                                     Fire PRA.
application MU-01   MU-04        C             Y        Plant changes that may impact the PRA           Ultimately resolved by      No impact to Fire model are documented, and resolved via Risk    procedure NOBP-CC-           PRA, because this Evaluation Review (RER) forms. Continuing      6001 and Design              issue was training is used to educate engineering        Interface Evaluation (DIE)   addressed in the (includes procedure writers) on when an RER    process that evaluates       base PRA model is required vs. direct procedural guidance. changes for PRA impact.      prior to building the The update process could be improved by                                     Fire PRA.
adding a similar review process into other I_      I plant change procedures.
MU-03   MU-1 1       C             Y        When the PRA model is updated for plant        Ultimately resolved by       No impact to Fire modifications or for decreases in CDF all      procedure NOBP-CC-           PRA, because this areas of applications should be evaluated. 6001, Section 7 lists RI-    issue was Page 228 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution       Impact to Fire ID     Requirement' Level        Closed                                                                              PRA YIN Certain applications can be adversely          applications that need        addressed in the impacted by decreases in CDF. For              updated following a new       base PRA model example, credit taken for examining            ERM (Effective Reference      prior to building the segments in a RI-ISI program could decrease    Model).                       Fire PRA.
with a decrease in CDF (or even an unrelated CDF increase, depending on changes to the risk profile.)
Additionally more than just the change in CDF needs to be evaluated. The risk profile may change drastically without a corresponding change in the CDF. For example CDF due to one IE may go up by 30% in conjunction with another change in CDF due to a different IE decreasing by 25%.
This would cause only a 5% change in CDF but significant changes to the risk profile.
QU-01  QU-07        C            Y      PRA Peer Review Subtier Criteria for this      As resolution to this PRA     No impact to Fire sub-element describes the need for             Peer Review observation       PRA, because this documentation of the limitations of simplified it should be noted that the   issue was models. This documentation could not be        RISKMAN model is used         determined to found for Beaver Valley Unit 2.                for purposes for risk         have no effect on sensitivities (e.g., SDP      the BVPS PRA findings) and risk-           model.
informed applications (e.g., BVPS-2 SSPS Slave Relay STI Extension), as such, there are no simplified model used for these purposes and hence nothing to document. Additionally, the intent of the PRA Notebooks was to document the                I Page 229 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status  Fact & Observation                                BVPS-2 Final Resolution        Impact to Fire ID     Requirement 1 Level        Closed                                                                                   PRA YIN development process and results of the RISKMAN PRA model, not to document the Safety Monitor model or its process that currently uses pre-solved sequence, or to document other risk-informed sensitivities and programs. Moreover, future versions of the Safety Monitor for RISKMAN users are to incorporate a full requantification of the sequences in place of pre-solved sequences.
QU-05  QU-23         C            Y        RISKMAN allows the user to apply a cutoff at     This truncation problem is     No impact to Fire the system (i.e., top event) level. This cutoff  expected to go away            PRA, because this is applied prior to the event tree               when BVPS updates the          issue was quantification. In general, no truncation (i.e., PRA software with the          addressed in the a value of 0) is used in the systems cutset      RISKMAN version that           base PRA model generation. But non-zero values are used for     contains binary decision       prior to building the a handful of top events. Of these most use       diagrams (BDD). The            Fire PRA.
very low cutoffs (<1E-12). The one exception     BDD software has the to this (as best this reviewer could determine)  ability to solve fault trees is the quantification of Top Event WC where a    without using cutsets, so cutoff of 5E-7 was used. Top Event WC is an      that no truncation values intermediate top used to quantify Top Event      are necessary. Therefore, WA and WB. Split Fraction WC1 has an             including additional unavailability of about 3E-9.                    discussions on this topic would not be of any value The SW system notebook discusses the             to analysts in future I system level cutoff and when it is used.         updates using the BODD       I Page 230 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution    Impact to Fire ID     Requirement1 Level        Closed                                                                           PRA YIN However, the potential quantitative impacts    methodology.
associated with the truncated results are not discussed.                                     Ultimately resolved by quantifying the split fractions using the BDD methodology, starting with the revision 4 PRA model.
SY-04  SY-27        C            Y      It would be desirable to reference the         Ultimately resolved in     No impact to Fire success criteria source in the system          Revision 5 PRA model       PRA, because this notebook. Success criteria are specified in    System Notebooks,          issue was the "Success Criteria" notebook, and the       Section 3 "SYSTEM          addressed in the reviewers found it difficult to flip from one  SUCCESS CRITERIA"          base PRA model source to another, especially when using the                              prior to building the electronic documentation CD.                                              Fire PRA.
SY-05  SY-12        C            Y      The system notebooks do not specifically       Ultimately resolved in     No impact to Fire discuss the dependencies that may be           Revision 5 PRA model       PRA, because this present regarding HVAC / room cooling.         System Notebooks,          issue was However, review of the HVAC notebook           Section 4 "SUPPORT         addressed in the identified the various spatial locations that  SYSTEMS"                   base PRA model may require HVAC and indicated the various                                prior to building the analyses that have been completed to either                               Fire PRA.
require HVAC dependencies or not.
SY-07  SY-26        C            Y      The Beaver Valley Unit 2 system notebooks       Ultimately resolved by    No impact to Fire have no indication of system engineering       GAP F&O F&O SY-C1-02       PRA, because this reviews. These reviews help ensure that        (see Table 2-2).           issue was systems are model in accordance with day-                                 addressed in the to-day plant operations and additionally                                  base PRA model expand the PRA knowledge of the system                                    prior to building the engineers.                                                                Fire PRA.
SY-08  SY-01        C            Y      The guidance did not provide for more          Boundary conditions were   No impact to Fire complete description of the actual boundary    developed using the        PRA, because this conditions used in the system analysis. It did dependency matrices,       issue was talk about support, but the actual details are which are located in       addressed in the not required (i.e. what AC bus is needed for  Appendix B of the Level 1  base PRA model which pump for that boundary condition for     Event Tree Analysis PRA    prior to building the Page 231 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                              BVPS-2 Final Resolution      Impact to Fire ID     Requirement 1 Level        Closed                                                                              PRA YIN the split fraction). As a result most of the    Notebook.                    Fire PRA.
notebooks do not give a good description of what each split fraction means and its usage.
The only place this appears to be actually documented is the description on the split fraction in the RISKMAN split fraction.
SY-09  (sic SY-14)   C            Y      System Diagrams contained in System             Each System Notebook         No impact to Fire Notebooks do not have explanation of color      has had a note added         PRA, because this highlighting. Figures are difficult to read and prior to the links for the   issue was many component lDs are not legible.             System drawings. This        addressed in the note explains the color      base PRA model There also does not appear to be a              scheme used on the           prior to building the discussion of 'Operating experience for the     drawings. Some parts of      Fire PRA.
system' required in the guidance document.      some of the drawings are difficult to read, but using the zoom function does make it easier to read most of the smaller print.
This is a limitation of the scanner used for this project. In all notebooks however, the drawing number is very easy to read, making retrieval of a larger and more legible drawing very easy. This is a Level 'C' F&O and is considered as a recommendation. The actions defined here are considered appropriate for closure of this F&O.
Operating experience for the system is subsumed Page 232 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution    Impact to Fire ID     Requirement 1 Level        Closed                                                                           PRA YIN in the system engineer's review.
SY-10  (sic SY-14)   C            Y      The Fault Trees for IA, IC have Transfer       Resolved in Revision 5     No impact to Fire Gates and page numbering that is confusing. PRA models that have       PRA, because this IA page 6 transfers to page 7 but page 7 top   Fault Trees redrawn so     issue was gate transfers to age 1. In IC, page 1 is a    Top Gate is on page 1. addressed in the transfer from page 5 which is the Top Event                               base PRA model IC. This is confusing and is easily fixed. NOTE: The BV2REV5A         prior to building the FTs are not organized due  Fire PRA. Also, to the addition of NFPA    this is a 805 basic events,          documentation-only issue.
SY-12  SY-17         C            Y      The Service cooling water system notebook      Ultimately resolved by     No impact to Fire assumption #7 has 10 minutes to trip the       GAP F&O F&O SY-B7-01       PRA, because this RCP's on loss of cooling. However, in the      (see Table 2-2).           issue was Miscellaneous system notebook, top event                                  addressed in the OC has 5 minutes to trip the RCP's. Note,                                 base PRA model this time might be important in quantifying an                            prior to building the HEP.                                                                      Fire PRA.
SY-1 3 SY-1 3        C            Y      Several systems appeared to be modeled as      The AFW pump macros        No impact to Fire point estimate only, AMSAC and the             were revised in the        PRA, because this Switchyard. This is acceptable, per the peer   BV2REV3B PRA model to      issue was review guidance, but consideration could be    include credit for AMSAC   addressed in the given to adding some detail to these models. to start the AFW pumps     base PRA model (in addition to the SSPS   prior to building the signal), given that the    Fire PRA.
signal is generated during non-ATWS events.
The Switchyard (Top Event OG) was modeled as a single basic event.
However, it used a lognormal distribution to quantify Monte Carlo Page 233 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                             BVPS-2 Final Resolution    Impact to Fire ID     Requirement 1 Level        Closed                                                                           PRA YIN values in addition to the point estimate value.
Furthermore, the PRA model already addressed transient induced LOSP events due to failures of the USST/SSST and Switchyard breakers in the normal bus top events.
The current methods to address the AMSAC and Switchyard failure probabilities are deemed acceptable as is.
SY-15  SY-10         C            Y      HVAC support analysis appears to only          As a resolution to this    No impact to Fire consider 8 hours versus 24 hours. The          PRA Peer Review            PRA, because this analysis was extended to 24 hours based        observation Table 6 in the issue was upon the fact that the curves were essentially Ventilation and Room       addressed in the flat after 8 hours. Some of the curves are     Cooling Analysis PRA       base PRA model straight and increasing and not flat and       Notebook was revised to    prior to building the constant.                                      show the expected area     Fire PRA.
temperature at 24 hours following the loss of ventilation. Areas that exceed their EQ temperature limits are discussed in the Section 6 and Appendix A of this notebook.
The success criteria for top event "T is        Ultimately resolved in    No impact to Fire missing from Table 3.3-2 of the Event Tree      Revision 5 PRA model      PRA, because this Notebook although it is described on page 58    Level 1 Accident          issue was of the notebook.                               Sequence Analysis          addressed in the Page 234 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                               BVPS-2 Final Resolution   Impact to Fire ID     Requirement 1 Level        Closed                                                                            PRA YIN Notebooks, Table 3.3-2 &  base PRA model Table 3.4-2.              prior to building the Fire PRA.
AS-06  AS-1 7        D            Y      The success criteria for top event NM is         Top Event NM is a switch  No impact to Fire missing from Table 3.3-6 of the Event Tree       to query if early core    PRA, because this Notebook although it is described on page 67     damage has occurred       issue was of the notebook.                                 during the SI injection   addressed in the phase, and does not have  base PRA model any success criteria per  prior to building the se, so is not included in Fire PRA.
the Success Criteria Tables.
DA-01  DA-19         D            Y      Appendix B of the Data Analysis Notebook is      Ultimately resolved in    No impact to Fire titled incorrectly. It includes reference to     Revision 5 PRA model      PRA, because this "Common Cause Data Sources" in the title,        Data Analysis Notebook,   issue was but the appendix contains no CCF                 renamed Appendix B title  addressed in the information,                                                               base PRA model prior to building the Fire PRA.
DE-01  DE-01         D            Y      The guidance for including spatial information   Ultimately resolved in    No impact to Fire in the system notebooks could not be found       Revision 5 PRA model      PRA, because this in the system notebook guidance document.        Systems Analysis          issue was However, it appears that most, ifnot all, the    Overview and Guidance     addressed in the system notebooks did have a section on           Notebooks, Section 5      base PRA model spatial considerations for flooding, fire and    "SPATIAL                  prior to building the seismic.                                         CONSIDERATIONS"           Fire PRA.
SY-1 1 SY-15         D            Y      The AC power system calculation notebook,        Ultimately resolved in    No impact to Fire has top event OG which has a split fraction      Revision 5 PRA model      PRA, because this for generic loss of power after a plant trip. Data Analysis Notebooks,  issue was The basic event report for this was missing      Tables A-1 and A-2.       addressed in the from the system notebook, but the system                                   base PRA model notebook listed a database variable "OGIX"                                 prior to building the used. This variable could not be found in the                              Fire PRA.
data notebook. It was in the RISKMAN model with no references from where it came from. I Page 235 of 301

Table 2-1. Summary of BVPS-2 2002 Internal Events PRA Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                           BVPS-2 Final Resolution Impact to Fire ID     Requirement' Level        Closed                                                                      PRA YIN It was determined that it came from the PLG-0500 revision 1, 1989.
Page 236 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                   BVPS-2 Final Resolution                    Impact to Fire ID  Requirement   Level       Closed                                                                                 PRA Y/N IE- IE-A6         B           Y      There is no documentation of         Documentation of interviews with           No impact to Fire A6-                                  interviews of plant personnel (e.g., system engineering plant personnel to      PRA, because 01                                   operations, maintenance,             determine if potential system              this issue was engineering, safety analysis) to     descriptions have been overlooked is       addressed in the determine if potential initiating    located in Unit-2 PRA Notebook (PRA- base PRA model events have been overlooked. This    BV2-AL-R05a) Systems Analysis              prior to building is required to meet capability       Overview and Guidance, Appendix B.         the Fire PRA.
category II                          Credit was taken for the system review in the notebook PRA System Review as a checklist for relevant combinations of events that might have been unnoticed. Review of the initiating events section in the system notebooks was also included as review of the system description by system engineers. Also, review of AOPs (e.g.,
D5X, 20M-53C.4.2.28.1) can be credited.                                I Page 237 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                     BVPS-2 Final Resolution                 Impact to Fire ID   Require m en t Level        Closed                                                                                PRA Y/N IE-  IE-C8          C            Y      All the relevant combinations of       The Initiating Events section of the    No impact to Fire C8-                                     events involving the annual            system notebooks now contains a         PRA, because 01                                      frequency of one component failure     description of the development of the   this issue was combined with the unavailability (or   support system initiating events.       addressed in the failure during the repair time of the  Except as noted, the mission time for   base PRA model first component) of other              normally running equipment is           prior to building components are not available in the    changed from 24 hours to 8760 hours     the Fire PRA.
support system notebooks. The          times the plant availability factor.
support system notebooks list which    Portions of the system fault tree logic initiators are developed from the      which is not used to quantify support fault trees and provide a diagram of   system initiating event frequency is the fault tree, however there is no    also noted.
narrative explanation of how these fault trees are modified and what assumptions are used to develop the support system initiator frequencies.
RISKMAN reports, provided as System Notebook appendices, list the details of the system IE models (i.e. cutsets, modified basic event equations, etc.), however there is no discussion of which component failures were considered, what mission time assumptions are used, or description of the development of the system IE models. Therefore it is difficult to determine if all relevant combinations of events have been considered.
IE- IE-C9          B            Y      Plant-specific information used in the The Recovery Considerations section      No impact to Fire C9-                                    assessment and quantification of       of the System Notebooks now              PRA, because 01                                     recovery actions included in the       documents the operator actions that     this issue was support system initiating event        were modified in the quantification of  addressed in the Page 238 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                     BVPS-2 Final Resolution                  Impact to Fire ID    Requirement  Level        Closed                                                                                 PRA Y/N analysis is not included in the        the system initiating event frequency. base PRA model support system notebooks. Analysis     No new recovery actions are credited     prior to building of the recovery actions should be      in the analysis of initiating event      the Fire PRA.
consistent with the applicable         frequency.
requirements in the Human Reliability Analysis IE-   IE-C10        B           Y      There is no comparison of the          In the Initiating Events Analysis        No impact to Fire C1 0-                                  initiating event analysis with generic Notebook, Table A6 demonstrates a        PRA, because 01                                     data sources or explanation of         comparison of initiating event           this issue was differences to provide a               frequencies for the Westinghouse 3-      addressed in the reasonableness check of the results. loop PWR. The industrial events are      base PRA model from WOG Rev 7 PSA comparison            prior to building database. Comparably Beaver Valley 2 the Fire PRA.
to other Westinghouse 3-loop PWR plants has most initiating events frequencies close to order of magnitude. Some differences in plant frequency include MLOCA with a higher frequency than comparable plants by an order of magnitude and interfacing systems LOCA (VSX) with a frequency one magnitude lower than similar plants. MLOCA initiating event frequency has been updated for PRA-BV2-AL-R05a to a new methodology       I Page 239 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance   Status Fact & Observation                        BVPS-2 Final Resolution                     Impact to Fire ID   Requirement   Level          Closed                                                                                       PRA Y/N based on NUREG-1 829 (April 2008) and lowering the effective break size therefore lowering the frequency. The WOG Rev 7 of other Westinghouse 3-loop PWRs was developed before the methodology of NUREG-1 829 was used. The lower order of magnitude difference for the initiator, VSX, is due to the difference of the amount of valves that are required. For BV 2, an occurrence would require at least three normally closed valves, which isolate the RCS from low pressure piping, to fail in the open position. Whereas, BV 1 would require at least two normally closed valves in this event and a difference of one order of magnitude for the frequency of the initiator. Blank gaps in Table A6 do not have data for 1 that plant from the WOG database.         I DA- DA-C4         B              Y      A clear basis for the identification of   Documentation of this is now included       No impact to Fire C4-                                     events as failures is not included in     in Section 3.3 of the Unit 2 Data           PRA, because 01                                      the Data Analysis Notebook. This          Analysis Notebook (PRA-BV2-AL-              this issue was basis could be used to distinguish        R05a).                                      addressed in the between those degraded states for                                                     base PRA model which a failure, as modeled in the                                                    prior to building PRA, would have occurred during                                                       the Fire PRA.
the mission and those for which a failure would not have occurred (e.g., slow pick-up to rated speed).
-~J.             I              I Page 240 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance  Status   Fact & Observation                       BVPS-2 Final Resolution                     Impact to Fire ID   Requirement  Level         Closed                                                                                        PRA YIN It could not be determined from the Data Analysis Notebook ifany failures were screened out or if the maintenance rule MPFFs are used as the data source.
DA-  DA-C5         B            Y        There is no listing or description in     For Beaver Valley Unit 2, repeated         No impact to Fire C5-                                      the Data Analysis Notebook of            plant specific component failures           PRA, because 01                                       repeated component failures that         occurring within a short time interval      this issue was were counted as a single failure.        were counted as a single failure during     addressed in the implementation of the Maintenance          base PRA model Repeated component failures               Rule. PRA data is taken from               prior to building occurring within a short time interval    Maintenance Rule sources and               the Fire PRA.
should be counted as a single failure    therefore meets the requirements of ifthere is a single, repetitive problem  the ASME PRA standard."
that causes the failures. In addition only one demand should be counted.
DA-  DA-C8         B            Y        Plant records should be used and          Maintenance Rule plant specific            No impact to Fire C8-                                      documented to determine the time          unavailability data is incorporated into   PRA, because 01                                       that components are configured in        the PRA model. Documentation of this        this issue was their standby status. This is required    can be found in the Presentation of        addressed in the to change SR DA-C8 from Capability        Plant-Specific Data section of the Data    base PRA model Category I to III                        Analysis notebook under sub-section         prior to building Component Maintenance Data and is          the Fire PRA.
evidenced by the Prior Maintenance Data of Appendix B."
DA-  DA-C10        B            Y         Decompose failure modes into sub-        Component failure modes have been          No impact to Fire C10-                                     elements and count                        handled appropriately to meet this         PRA, because 01                                       demands/failures individually in the      Supporting Requirement at the CC-Il        this issue was sub-elements.                            level. Failures of sub-elements of a       addressed in the component that are modeled explicitly      base PRA model in the PRA are associated with the         prior to building sub-element and not the component          the Fire PRA.
I__ I_       I_      I                                         Iitself. Documentation of this can be      I Page 241 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                    BVPS-2 Final Resolution               Impact to Fire ID  Requirement  Level       Closed                                                                             PRA Y/N found in the Presentation of Plant-Specific Data section of the Data Analysis Notebook (PRA-BV2-AL-R05a) under sub-section Component Failure Event Allocation and is evidenced by the data in Table A-1.
HR- HR-B1, HR-   B           Y      This F&O is a carry-over from the     As outlined in HRA Notebook Section   No impact to Fire B1- D2                              peer review (F&O HR-2).               2.2, testing and maintenance          PRA, because 01                                                                        procedures were evaluated to identify this issue was A generic error of omission term      potential misalignments. These        addressed in the from the PLG database (ZHEO1A)        potential misalignments were          base PRA model was used for all misalignment HEPs    evaluated using the EPRI HRA          prior to building without regard for procedural or      Calculator 4.1.1 to develop specific  the Fire PRA.
operational failure barriers such as  HEPs for each potential misalignment independent verification, peer        as documented in HRA Notebook checks, walkdowns, etc. However,      Table 3.5.
plant specific data was used for test and maintenance frequencies.
Therefore, the overall misalignment errors were a hybrid of generic and plant specific data. This was used for systems which are important to CDF (e.g., Auxiliary Feedwater, Safety Injection).
Page 242 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance    Status    Fact & Observation                       BVPS-2 Final Resolution               Impact to Fire ID   Requirement   Level           Closed                                                                                   PRA Y/N     I HR-  HR-D3         B               Y         While the discussion in the system       Procedure quality has been            No impact to Fire D3-                                          notebooks (AFW and QS/RS                 incorporated into human error         PRA, because 01                                           notebooks were reviewed)                 probability assessments.              this issue was references the procedures, no            Documentation of this can be found    addressed in the documentation of quality of those        throughout the HRA Notebook,          base PRA model procedures or administrative controls    particularly the Dynamic Actions      prior to building was found.                               section and tables of Section 3.      the Fire PRA.
HR-  HR-12          B              Y         The BV HRA does document a               Section 2.3 of the Unit 2 HRA         No impact to Fire 12-                                         process to perform a systematic          notebook (PRA-BV2-AL-R05a) has        PRA, because 01                                           search for dependent human actions       been created to document that PRA     this issue was credited on individual sequences. It     Analysis No. PRA-BV2-12-002-R00,      addressed in the is clear from the human action           "BVPS-2 HRA Dependency Analysis,"     base PRA model identifier sheets documented in the      Revision 0 provides the process used  prior to building BVPS-2 HRA notebook that such an         for the dependency analysis           the Fire PRA.
evaluation has been performed, but       evaluation. The results of this human there is no evidence of the process      action dependency analysis did not documented in the HRA notebook.          reveal any new dependencies that were not already analyzed.
To be consistent with current HRA methods, there must be a systematic process to identify, assess and adjust dependencies between multiple human errors in the same sequence, including those in the I initiating events.                     I HR- HR-I1,         B              Y         The HRA notebook sporadically            A new Assumptions section has been    No impact to Fire 13- HR-13,                                  discusses assumptions and                added to the Unit 2 HRA notebook      PRA, because 01  AS-C3,                                  uncertainties. Per the Clarification to (PRA-BV2-AL-RO5a). All major           this issue was regulatory Guide 1.200 Revision 1,       assumptions and sources of            addressed in the IE-D3, 1 ________ I                                        &
Page 243 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O    Supporting. Significance Status   Fact & Observation                     BVPS-2 Final Resolution                  Impact to Fire ID     Requirement   Level        Closed                                                                                   PRA YIN IF-F3,                              there is an increased importance in    uncertainty are listed in this location, base PRA model LE-F3,                              the industry to identify assumptions                                            prior to building and uncertainties in the PRA model.                                             the Fire PRA.
LE-G4, In reviewing the HRA notebook, it is Sc-c1,                              difficult to locate the assumptions SC-C3,                              and uncertainties.
QU-F4 HR-    HR-I1, HR-12  C            Y        The Beaver Valley Unit 2 system        The BVPS Units 1 & 2 PRA and             No impact to Fire 11-                                        and data notebooks have been           System notebooks were formally           PRA, because 01                                         updated and exist in draft form, but   reviewed and signed off as part of the   this issue was there is no record of formal review    update process.                          addressed in the and approval. Furthermore, only a                                               base PRA model subset of the total PRA notebooks                                               prior to building have been updated for this revision                                             the Fire PRA.
I         _                           of the PRA.
HR-    HR-12          C           Y        There is no evidence in the HRA or     During the Extended Power Uprate         No impact to Fire 12-                                        Success Critera notebooks that an      evaluation, plant operations did review  PRA, because 02                                         operator review of the HRA has         the operator actions and timings.        this issue was been performed.                        These reviews are documented in          addressed in the FENOC Letters L-06-003 and L         base PRA model 018. Furthermore, several operator       prior to building action scenarios were evaluated using    the Fire PRA.
the plant simulator.
IF-   IF-Ala         B           Y        It is not clear from the               This F&O was written against an          This F&O was Ala-                                       documentation that a comprehensive     obsolete Internal Flooding PRA model     resolved in the 01                                        assessment has been conducted to       (BV2REV4) and is considered to be        submitted BVPS-finalize the combined rooms            resolved by the updated Internal         2 Fire PRA including propagation, barriers, etc. Flooding PRA model incorporated in       model, which The IF assessment is based on large    BV2REV5A, which underwent a              used BV2REV5A flood areas but there is no            focused Peer Review in accordance        as its basis.
description of the process used to     with the guidance in Appendix B of define those areas with respect to     NRC RG 1.200, Rev. 1, conducted I flood propagation and barriers,        during June 6-9, 2011, by the PWR Page 244 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                      BVPS-2 Final Resolution                  Impact to Fire ID  Requirement   Level       Closed                                                                                    PRA Y/N Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-A3         B           Y        There is no evidence in the IF          This F&O was written against an          This F&O was A3-                                    Notebook that it represents the         obsolete Internal Flooding PRA model     resolved in the 01                                     current as-built-as operated plant      (BV2REV4) and is considered to be        submitted BVPS-(circa 2007). Rev4 documentation        resolved by the updated Internal         2 Fire PRA in another document may include the     Flooding PRA model incorporated in       model, which information to show that the IF         BV2REV5A, which underwent a              used BV2REV5A assessment is current, but it is not in focused Peer Review in accordance        as its basis.
this Notebook, IF-A3-01 was written     with the guidance in Appendix B of as a B level F&O to provide             NRC RG 1.200, Rev. 1, conducted documentation that the IF               during June 6-9, 2011, by the PWR assessment still represents the as-     Owners Group. The F&Os as a result built as operated plant in 2007, This   from this focused Peer Review, as well probably also applies to other PRA      as their resolutions are presented in elements from the ASME PRA              Table 2-4.
Standard (e.g., SY, SC, HR, etc.)
and should be addressed generically for the BVPS PRA. This would facilitate future reviews and development of PRA applications.
IF- IF-B1         B           Y        The ASME PRA Standard states "for       This F&O was written against an          This F&O was B1-                                    each flood area, identify the potential obsolete Internal Flooding PRA model     resolved in the 01                                     sources of flooding." Section C3.1      (BV2REV4) and is considered to be        submitted BVPS-identifies flood sources in each area   resolved by the updated Internal         2 Fire PRA but clear documentation of each         Flooding PRA model incorporated in       model, which source in an area is lacking. The       BV2REV5A, which underwent a              used BV2REV5A Standard expects a more systematic      focused Peer Review in accordance        as its basis.
approach for identifying potential      with the guidance in Appendix B of flood sources and then later            NRC RG 1.200, Rev.1, conducted I screening them. The IF assessment       during June 6-9, 2011, by the PWR      I Page 245 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                Impact to Fire ID  Requirement    Level        Closed                                                                                PRA YIN here includes initial screening         Owners Group. The F&Os as a result without written justification. It is    from this focused Peer Review, as well suggested that a complete               as their resolutions are presented in discussion of potential sources be      Table 2-4.
documented and the basis for screening potential sources.
IF- IF-B1          B            Y      Section C3.1 states that major flood    This F&O was written against an        This F&O was B1-                                    sources were reviewed to identify       obsolete Internal Flooding PRA model   resolved in the 02                                     potential flood locations. The ASME     (BV2REV4) and is considered to be      submitted BVPS-standard suggests that first you        resolved by the updated Internal       2 Fire PRA identify flooding areas then identified Flooding PRA model incorporated in     model, which all flooding sources in that area.      BV2REV5A, which underwent a            used BV2REV5A This method used for BVPS may           focused Peer Review in accordance      as its basis.
have lead to overlooking other          with the guidance in Appendix B of sources of flooding within each area. NRC RG 1.200, Rev.1, conducted during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-B2,         B            Y      The SR B-2 of the PRA Standard          This F&O was written against an        This F&O was B2-                                    requires "For each source of            obsolete Internal Flooding PRA model   resolved in the 01                                     flooding, identify the flooding         (BV2REV4) and is considered to be      submitted BVPS-mechanisms that would result in a       resolved by the updated Internal       2 Fire PRA fluid release including failure models, Flooding PRA model incorporated in     model, which human-induced mechanisms, and           BV2REV5A, which underwent a            used BV2REV5A other events resulting in a release     focused Peer Review in accordance      as its basis.
into the flood area." In addition, SR   with the guidance in Appendix B of Page 246 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact &Observation                      BVPS-2 Final Resolution                Impact to Fire ID  Requirement   Level        Closed                                                                               PRA YIN IF-B3                             B-3 requires "For each source and      NRC RG 1.200, Rev. 1, conducted its identified failure mechanism,      during June 6-9, 2011, by the PWR identify the characteristic of release Owners Group. The F&Os as a result and the capacity of the source."       from this focused Peer Review, as well Section C3.1 of the IFNotebook         as their resolutions are presented in does not provide enough detail to      Table 2-4.
judge whether these requirement is met. One example is that although a few human error induced floods (e.g., testing or maintenance errors) were considered, there is no evidence of a systematic assessment of potential test and maintenance errors.
Page 247 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                Impact to Fire ID   Requirement   Level        Closed                                                                                PRA YIN IF-  IF-C2b        B            Y      Section C3.1 does not have enough       This F&O was written against an        This F&O was C2b-                                   detail to show that the capacity of     obsolete Internal Flooding PRA model   resolved in the 01                                     the drains and the amount of water      (BV2REV4) and is considered to be      submitted BVPS-retained by the sumps, berms, dikes,    resolved by the updated Internal       2 Fire PRA and curbs was estimated. The            Flooding PRA model incorporated in     model, which reviewer notes that it is likely that   BV2REV5A, which underwent a            used BV2REV5A this was performed but there is no      focused Peer Review in accordance      as its basis.
record of the assessment. The           with the guidance in Appendix B of capacity of drains and the amount of    NRC RG 1.200, Rev.1, conducted water retained by sumps, etc. should    during June 6-9, 2011, by the PWR be documented in the IF Notebook.       Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in I Table 2-4.
Page 248 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                Impact to Fire ID    Requirement   Level        Closed                                                                                PRA Y/N IF-   IF-C3         B            Y      The PRA Standard states "for each       This F&O was written against an        This F&O was C3-                                     SSCs identified in IF-C2c identify the  obsolete Internal Flooding PRA model   resolved in the 01                                      susceptibility of each SSC in the       (BV2REV4) and is considered to be      submitted BVPS-flood area to flood-induced failure     resolved by the updated Internal       2 Fire PRA mechanism". Also, the SR-C3a            Flooding PRA model incorporated in     model, which states, "to determine susceptibility of BV2REV5A, which underwent a            used BV2REV5A SSC to flood-induced failure            focused Peer Review in accordance      as its basis.
mechanism, take credit for the          with the guidance in Appendix B of operability of SSC identified in IF-    NRC RG 1.200, Rev.1, conducted C2c with respect to internal flood      during June 6-9, 2011, by the PWR impact only if supported by an          Owners Group. The F&Os as a result appropriate combination of: 1) test or  from this focused Peer Review, as well operational data, 2) engineering        as their resolutions are presented in analysis, and 3) expert judgment." It   Table 2-4.
is likely that flood-induced failure mechanisms were considered in the IF assessment but are not identified in the IF Notebook. Section C3.1 does not provide enough detail on the impact of the flood on SSCs.
IF-  IF-C3a, IF-   B            Y      The IF-C3b SR requires that all         This F&O was written against an        This F&O was C3b- C3b                               potential mechanisms that can           obsolete Internal Flooding PRA model   resolved in the 01                                     create interconnections between         (BV2REV4) and is considered to be      submitted BVPS-flooding areas be considered for        resolved by the updated Internal       2 Fire PRA CCII and that barrier unavailability     Flooding PRA model incorporated in    model, which also be considered for CCIII. There      BV2REV5A, which underwent a           used BV2REV5A is no evidence in the Appendix C of     focused Peer Review in accordance      as its basis.
the Initiating Events Notebook that     with the guidance in Appendix B of any mechanism other than open            NRC RG 1.200, Rev.1, conducted obvious pathways (e.g., vents in        during June 6-9, 2011, by the PWR doors, tunnels, etc.) were              Owners Group. The F&Os as a result considered. This may be just a          from this focused Peer Review, as well Page 249 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                       BVPS-2 Final Resolution                 Impact to Fire ID   Requirement    Level        Closed                                                                                  PRA Y/N documentation issue for CCII.            as their resolutions are presented in Table 2-4.
Also, the RI-ISI program did a comprehensive assessment of flooding potential for various break locations. A comparison should be performed between the RI-ISI flooding assessment and the PRA IF assessment to ensure consistency.
Note that upgrading to CCIII requires the additional consideration of barrier unavailability, for example due to maintenance activities or maintenance unavailability.
IF-  IF-C3c         B            Y      Develop engineering calculations for     This F&O was written against an         This F&O was C3c-                                    ALL flooding scenarios, not just the     obsolete Internal Flooding PRA model    resolved in the 01                                      "worst case" scenarios. This is likely   (BV2REV4) and is considered to be       submitted BVPS-just a documentation issue, but since    resolved by the updated Internal        2 Fire PRA it is missing from the IF Notebook,      Flooding PRA model incorporated in      model, which SR IF-C3c is not met.                    BV2REV5A, which underwent a             used BV2REV5A focused Peer Review in accordance       as its basis.
I with the guidance in Appendix B of    I Page 250 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                       BVPS-2 Final Resolution                Impact to Fire ID  Requirement    Level       Closed                                                                                 PRA Y/N NRC RG 1.200, Rev. 1, conducted during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-C4,         B           Y      The operator actions credited inthe      This F&O was written against an        This F&O was C4- IF-C6,                            IFflooding assessment are based on       obsolete Internal Flooding PRA model   resolved in the 01  IF-C8                             detailed HRA assessments for two         (BV2REV4) and is considered to be      submitted BVPS-operator actions. Cues, procedures,      resolved by the updated Internal       2 Fire PRA etc. are detailed in the HRA             Flooding PRA model incorporated in     model, which assessment. It is not clear ifthese      BV2REV5A, which underwent a            used BV2REV5A actions are also applied to scenarios    focused Peer Review in accordance      as its basis.
other than those used to quantify the    with the guidance in Appendix B of HEP in the HRA Notebook. In              NRC RG 1.200, Rev.1, conducted addition, there are a number of other    during June 6-9, 2011, by the PWR instances inwhich the operators are      Owners Group. The F&Os as a result assumed to be highly reliable. There     from this focused Peer Review, as well is also no indication that these are     as their resolutions are presented in validated by operator interviews.        Table 2-4.
Cleaner documentation of the operator actions that are credited (as well as those not credited), and their basis, should be completed to assist in future reviews and for risk applications inwhich the performance of operators is important. Also a clear linkage between the IFand HRA Notebooks should be documented for the basis of the important HRA input and some of the operator actions to screen scenarios is based on highly    I Page 251 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact &Observation                         BVPS-2 Final Resolution                Impact to Fire ID  Requirement    Level        Closed                                                                                    PRA Y/N    I reliable operator actions.
IF- IF-C4          B            Y        SR-IF-C4 requires the development         This F&O was written against an        This F&O was C4-                                      of flood scenarios by examining the       obsolete Internal Flooding PRA model   resolved in the 02                                       equipment and relevant plant              (BV2REV4) and is considered to be      submitted BVPS-features in the flood area and area in    resolved by the updated Internal       2 Fire PRA potential propagation paths, taking       Flooding PRA model incorporated in     model, which credit for appropriate flood mitigation   BV2REV5A, which underwent a            used BV2REV5A systems or operator actions, and          focused Peer Review in accordance      as its basis.
identifying susceptible SSCs. No          with the guidance in Appendix B of flood scenarios are developed in the      NRC RG 1.200, Rev.1, conducted IF Notebook.                              during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-C5,         B            Y        The screening methodology                 This F&O was written against an        This F&O was C5- IF-C5a,                              documented in Section C3.1 does           obsolete Internal Flooding PRA model   resolved in the 01  IF-C7,                               not follow the systematic                 (BV2REV4) and is considered to be      submitted BVPS-IF-D7                                methodology described in the              resolved by the updated Internal       2 Fire PRA Standard. For the IFassessment,           Flooding PRA model incorporated in     model, which the screening is performed at the         BV2REV5A, which underwent a            used BV2REV5A source and location level and, in         focused Peer Review in accordance      as its basis.
some cases, without adequate basis        with the guidance in Appendix B of as discussed in a previous F&O (IF-       NRC RG 1.200, Rev.1, conducted B1-01). The method used in the IF         during June 6-9, 2011, by the PWR flooding assessment may be                Owners Group. The F&Os as a result technically adequate, ifthe basis is      from this focused Peer Review, as well better documented, even though it        as their resolutions are presented in does not meet the Standard SRs for        Table 2-4.
C-5, C5a and C7.                        I Page 252 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                     BVPS-2 Final Resolution                  Impact to Fire ID  Requirement    Level        Closed                                                                                   PRA Y/N    I IF- IF-D1          B            Y        The FENOC response to DE-06 from       This F&O was written against an          This F&O was D1-                                      the OG Peer Review is incomplete,      obsolete Internal Flooding PRA model     resolved in the 01                                       The F&O is concerned about the         (BV2REV4) and is considered to be        submitted BVPS-vintage of the data used to estimate   resolved by the updated Internal         2 Fire PRA pipe break frequencies and the         Flooding PRA model incorporated in       model, which FENOC response talks about             BV2REV5A, which underwent a              used BV2REV5A walkdowns.                             focused Peer Review in accordance        as its basis.
with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-D5,         B            Y        The IF pipe and tank break             This F&O was written against an          This F&O was D5- IF-D5a                               frequencies used in the IF             obsolete Internal Flooding PRA model     resolved in the 01                                       assessment are based on 1988 and       (BV2REV4) and is considered to be        submitted BVPS-1990 data. The prior pipe break        resolved by the updated Internal         2 Fire PRA frequencies should be updated to       Flooding PRA model incorporated in       model, which reflect more recent experience and     BV2REV5A, which underwent a              used BV2REV5A should include plant specific          focused Peer Review in accordance        as its basis.
experience. In estimating pipe break   with the guidance in Appendix B of frequencies, it is recommended that    NRC RG 1.200, Rev.1, conducted experience with safety related vs. during June 6-9, 2011, by the PWR BOP piping be considered along with    Owners Group. The F&Os as a result active pipe degradation                from this focused Peer Review, as well mechanisms. Credit for condition       as their resolutions are presented in monitoring programs should also be     Table 2-4.
applied where applicable.            I                                        I Page 253 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                       BVPS-2 Final Resolution                Impact to Fire ID  Requirement   Level        Closed                                                                                 PRA YIN IF- IF-El         B            Y      The Standard states "for each flood      This F&O was written against an        This F&O was El-                                   scenario, review the accident            obsolete Internal Flooding PRA model   resolved in the 01                                    sequences for the associated plant-      (BV2REV4) and is considered to be      submitted BVPS-initiating event group to confirm        resolved by the updated Internal       2 Fire PRA applicability of other accident          Flooding PRA model incorporated in     model, which sequences model." A spot check           BV2REV5A, which underwent a            used BV2REV5A was made to provide reasonable           focused Peer Review in accordance      as its basis.
confidence that the overall results      with the guidance in Appendix B of are correct. However, there is no        NRC RG 1.200, Rev.1, conducted record that EACH scenario was            during June 6-9, 2011, by the PWR reviewed.                                Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-Fl,         B           Y      The Internal Flooding documentation This F&O was written against an             This F&O was Fl- SY-A4                             does not include the results of the      obsolete Internal Flooding PRA model   resolved in the 01                                    walkdowns performed during the           (BV2REV4) and is considered to be      submitted BVPS-original assessment. FENOC               resolved by the updated Internal       2 Fire PRA response to OG Peer Review F&O           Flooding PRA model incorporated in     model, which DE-4 indicates that the RI-ISI           BV2REV5A, which underwent a            used BV2REV5A walkdowns are documented and             focused Peer Review in accordance      as its basis.
cover the issues required for an         with the guidance in Appendix B of Internal Flooding walkdown. To           NRC RG 1.200, Rev.1, conducted facilitate future maintenance and        during June 6-9, 2011, by the PWR reviews of the internal flooding         Owners Group. The F&Os as a result assessments, the use of the RI-ISI       from this focused Peer Review, as well walkdowns for internal flooding          as their resolutions are presented in should be documented in the              Table 2-4.
Internal Flooding Notebook and a direct reference to a retrievable copy the RI-ISI walkdowns should also be included.                              I Page 254 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                Impact to Fire ID  Requirement   Level        Closed                                                                                PRA Y/N IF- IF-F2         B            Y      The documentation of the processes      This F&O was written against an        This F&O was F2-                                   to identify flood areas, sources,       obsolete Internal Flooding PRA model   resolved in the 01                                    pathways, scenarios, etc. are not       (BV2REV4) and is considered to be      submitted BVPS-clearly documented. For example,        resolved by the updated Internal       2 Fire PRA the rules used to screen out sources    Flooding PRA model incorporated in     model, which and areas are not defined and the       BV2REV5A, which underwent a            used BV2REV5A bases for eliminating or justifying     focused Peer Review in accordance      as its basis.
propagation pathways is either not      with the guidance in Appendix B of clearly defined or not provided at all. NRC RG 1.200, Rev.1, conducted during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-F2         B            Y      The IFNotebook states that the          This F&O was written against an        This F&O was F2-                                   annual frequency of a flood scenario    obsolete Internal Flooding PRA model   resolved in the 02                                    in location X is Rx = Fi*fx,i*fs,x*fp,x (BV2REV4) and is considered to be      submitted BVPS-and the quantify scenarios in which     resolved by the updated Internal       2 Fire PRA recover actions can be included is      Flooding PRA model incorporated in     model, which Sx=Rx (Dx + lx). However, the           BV2REV5A, which underwent a            used BV2REV5A frequency is never quantified using     focused Peer Review in accordance      as its basis.
these equations. This is confusing      with the guidance in Appendix B of for a reviewer - what is the purpose     NRC RG 1.200, Rev. 1, conducted of these statements ifthey are not      during June 6-9, 2011, by the PWR used? or ifthey are used, an            Owners Group. The F&Os as a result explanation is needed.                  from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
Page 255 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                     BVPS-2 Final Resolution                Impact to Fire ID  Requirement    Level        Closed                                                                               PRA YIN IF- IF-Alb, IF-    C            Y      Although it is apparent that dual unit This F&O was written against an        This F&O was Al- Bla, IF-C4a,                       impacts for internal flooding were     obsolete Internal Flooding PRA model   resolved in the 01  IF-D4                              considered, the details are buried in  (BV2REV4) and is considered to be      submitted BVPS-the individual assessments. To         resolved by the updated Internal       2 Fire PRA assist future reviews and the          Flooding PRA model incorporated in     model, which development of risk informed           BV2REV5A, which underwent a            used BV2REV5A applications, it is recommended that   focused Peer Review in accordance      as its basis.
a separate section of the Internal     with the guidance in Appendix B of Flooding documentation be created      NRC RG 1.200, Rev.1, conducted to summarize the search for and        during June 6-9, 2011, by the PWR results of an assessment of dual unit  Owners Group. The F&Os as a result internal flooding impacts.             from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
IF- IF-A4,         B            Y      The OG Peer Review F&O DE-3            This F&O was written against an        This F&O was A4-                                    documented the lack of                 obsolete Internal Flooding PRA model   resolved in the 01                                     documentation of a walkdown for        (BV2REV4) and is considered to be      submitted BVPS-internal flooding and other PRA        resolved by the updated Internal       2 Fire PRA purposes. The F&O response by          Flooding PRA model incorporated in     model, which FENOC is incorrect and does not        BV2REV5A, which underwent a            used BV2REV5A address the F&O. As a result, the      focused Peer Review in accordance      as its basis.
walkdown documentation is still not    with the guidance in Appendix B of identified. The walkdown needs to      NRC RG 1.200, Rev. 1, conducted be documented and reviewed from        during June 6-9, 2011, by the PWR the perspective of internal floods in  Owners Group. The F&Os as a result order to assign a CC to several of     from this focused Peer Review, as well the SRs for Internal Flooding.         as their resolutions are presented in IF-C9,                                                                    Table 2-4.
Page 256 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                     BVPS-2 Final Resolution                  Impact to Fire ID  Requirement    Level        Closed                                                                                 PRA W/N IF-D4                              It is noted that in response to OG F&O DE-04, FENOC used the RI-ISI documentation in place of the original walkdown documentation.
Based on the scope of the RI-ISI walkdowns, this is considered to be an acceptable substitute for the Internal Flooding assessment since the same considerations are being investigated (e.g., drain locations, equipment elevations, etc.).
However, a retrievable walkdown document needs to be identified in the IF Notebook.
IF- IF-D1,         C            Y      The IF assessment does not rely on     This F&O was written against an          This F&O was Dt- IF-D3,                             grouping of IEs, sources, locations,   obsolete Internal Flooding PRA model     resolved in the 02  IFD3a                              etc. The screening methodology         (BV2REV4) and is considered to be        submitted BVPS-discussed in the IF Notebook and       resolved by the updated Internal         2 Fire PRA assessed under the IF-C-xx SRs         Flooding PRA model incorporated in       model, which methodology resulted in only a         BV2REV5A, which underwent a              used BV2REV5A handful of flooding events to be       focused Peer Review in accordance        as its basis.
considered. These were individually with the guidance in Appendix B of assessed in the overall PRA            NRC RG 1.200, Rev.1, conducted quantification using RISKMAN. The      during June 6-9, 2011, by the PWR methodology used may be                Owners Group. The F&Os as a result technically adequate in spite of not   from this focused Peer Review, as well meeting the ASME Standard SRs for as their resolutions are presented in grouping if it can be justified that   Table 2-4.
only a handful of events are important.                           I                                        I Page 257 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                       BVPS-2 Final Resolution                Impact to Fire ID  Requirement  Level        Closed                                                                                 PRA Y/NIN IF- IF-D4        C            Y      The PRA documentation should             This F&O was written against an        This F&O was D4-                                  include a discussion of the potential    obsolete Internal Flooding PRA model   resolved in the 01                                   impact of floods on systems that are     (BV2REV4) and is considered to be      submitted BVPS-shared between the two units. This       resolved by the updated Internal       2 Fire PRA impact is expected to be minimal.        Flooding PRA model incorporated in     model, which One example is the potential impact      BV2REV5A, which underwent a            used BV2REV5A on the electric power crosstie to Unit   focused Peer Review in accordance      as its basis.
1 availability due to floods in the      with the guidance in Appendix B of service water intake structure. Is the   NRC RG 1.200, Rev.1, conducted Unit 1 diesel dependence on service      during June 6-9, 2011, by the PWR water correctly accounted for when       Owners Group. The F&Os as a result the flood impacts the availability of    from this focused Peer Review, as well the Unit 1 service water system?         as their resolutions are presented in Table 2-4.
IF- IF-D5         C           Y      The IEF for pipe breaks is based on      This F&O was written against an        This F&O was D5-                                  a generic 80-% capacity factor.          obsolete Internal Flooding PRA model   resolved in the 02                                   There are two issues with this           (BV2REV4) and is considered to be      submitted BVPS-method: a) current capacity factors      resolved by the updated Internal       2 Fire PRA are typically greater than 80% so        Flooding PRA model incorporated in     model, which that the IEFs are slightly lower, and    BV2REV5A, which underwent a            used BV2REV5A b) the method is inconsistent with       focused Peer Review in accordance      as its basis.
the method used to calculate other       with the guidance in Appendix B of IEFs. It is recommended that the         NRC RG 1.200, Rev.1, conducted calculation for IF IEF be revised to     during June 6-9, 2011, by the PWR be consistent with the method used       Owners Group. The F&Os as a result for other IEFs.                          from this focused Peer Review, as well as their resolutions are presented in I Table 2-4.
Page 258 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status   Fact & Observation                       BVPS-2 Final Resolution                Impact to Fire ID   Requirement  Level        Closed                                                                                   PRA YIN IF-  IF-D6        C            Y        The IF flooding assessment uses          This F&O was written against an        This F&O was D6-                                     screening criteria to limit the          obsolete Internal Flooding PRA model   resolved in the 01                                      operator induced floods during           (BV2REV4) and is considered to be      submitted BVPS-maintenance (e.g., due to operator       resolved by the updated Internal       2 Fire PRA errors such as inadvertently opening     Flooding PRA model incorporated in     model, which isolation valves which maintenance       BV2REV5A, which underwent a            used BV2REV5A is occurring). One of the screening      focused Peer Review in accordance      as its basis.
criteria is whether the maintenance      with the guidance in Appendix B of activity is performed during power       NRC RG 1.200, Rev.1, conducted operation or at shutdown. The            during June 6-9, 2011, by the PWR application of these criteria to         Owners Group. The F&Os as a result potential floods should be re-           from this focused Peer Review, as well assessed in light of recent practices    as their resolutions are presented in to perform more maintenance at           Table 2-4.
power to shorten the shutdown periods. It is expected that this will have a small to negligible impact on the IF assessment and is therefore I assigned a Level C.                    I IF-  IF-E5         C           Y        There are a number of operator           This F&O was written against an        This F&O was E5-                                     actions credited in the IF               obsolete Internal Flooding PRA model   resolved in the 01                                      assessment that are used to screen       (BV2REV4) and is considered to be      submitted BVPS-potential flooding events based on       resolved by the updated Internal       2 Fire PRA the operator's ability to diagnose the   Flooding PRA model incorporated in     model, which pipe break and isolate the leak          BV2REV5A, which underwent a            used BV2REV5A thereby preventing the flood.            focused Peer Review in accordance      as its basis.
However, these operator actions are      with the guidance in Appendix B of based on judgment. For others, one       NRC RG 1.200, Rev.1, conducted of the two HEPs that are analyzed is during June 6-9, 2011, by the PWR used based on judgment. Examples         Owners Group. The F&Os as a result include:                                 from this focused Peer Review, as well as their resolutions are presented in
~.I.
Page 259 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact &Observation                       BVPS-2 Final Resolution Impact to Fire ID  Requirement  Level       Closed                                                                 PRA Y/N
: 1) InSection C4.3.6 it is stated that   Table 2-4.
operator will receive sump alarms and be alert to the loss of RWST tank level ... the possibility that the operators do not locally isolate the tank ... is estimated as 6.7E-03 from ZHEFL2.
: 2) In Section C3.2.1 itis stated that a flood from the fan room should be detected quickly since this room is next to the control room. The control building sump high-level alarm would alert operators. Failure of the air conditioning would also alert operators.
It is recommended that a better basis for these operator actions be developed to ensure consistency with the remainder of the PRA.\
Page 260 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                Impact to Fire ID    Requirement    Level       Closed                                                                                PRA Y/N IF-   IF-E5a         C           Y      Several operator actions in the IF      This F&O was written against an        This F&O was E5a-                                    assessment use the HEPs                 obsolete Internal Flooding PRA model   resolved in the 01                                      documented by detailed analysis for     (BV2REV4) and is considered to be      submitted BVPS-ZHEFL1 and 2. These assume that         resolved by the updated Internal       2 Fire PRA the cues, procedures steps, action,     Flooding PRA model incorporated in     model, which timing, etc. are similar enough to that BV2REV5A, which underwent a            used BV2REV5A for ZHEFL1 or 2 but this is not         focused Peer Review in accordance      as its basis.
documented in the IF Notebook or        with the guidance in Appendix B of the HR Notebook. To be consistent       NRC RG 1.200, Rev.1, conducted with the operator action                during June 6-9, 2011, by the PWR assessments for the remainder of        Owners Group. The F&Os as a result the PRA, it is recommended that         from this focused Peer Review, as well better documentation be developed       as their resolutions are presented in to support the use of ZHEFL1 or 2       Table 2-4.
for these operator actions, or new I_                                 HEPs be developed as appropriate.
IF-   IF-F1          C           Y      If the current IF methodology is        This F&O was written against an        This F&O was Fl-                                     retained, a comparison of the current   obsolete Internal Flooding PRA model   resolved in the 02                                      methodology to the ASME Standard        (BV2REV4) and is considered to be      submitted BVPS-is recommended to facilitate future     resolved by the updated Internal       2 Fire PRA reviews.                                Flooding PRA model incorporated in     model, which BV2REV5A, which underwent a            used BV2REV5A focused Peer Review in accordance      as its basis.
with the guidance in Appendix B of NRC RG 1.200, Rev.1, conducted during June 6-9, 2011, by the PWR Owners Group. The F&Os as a result from this focused Peer Review, as well as their resolutions are presented in Table 2-4.
Page 261 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status   Fact & Observation                     BVPS-2 Final Resolution                 Impact to Fire ID   Requirement    Level       Closed                                                                                  PRA YIN LE-   LE-C2a, LE-   B           Y        SR LE-C2a is assigned a capability     The Level 2 LERF Analysis Notebook      No impact to Fire C2a- C2b, LE-C3,                         category I because BVPS 2 does not     Section 2.5 "General Discussion of      PRA, because 01    LE-C6                              use operator actions post core         Level 2 Operator Actions" discusses     this issue was damage. This is considered             operator actions considered for this    addressed in the conservative treatment of operator     model.                                  base PRA model actions following the onset of core                                            prior to building damage. To meet capability             WCAP-16657-P suggests seven             the Fire PRA.
category III for this SR, BVPS 2 level potential operator actions (OA) for 2 analysis must contain realistic      inclusion in a Level 2 PRA model.
operator actions, based on SAMGs,      Each of these actions along with two EOPs, etc. such as WCAP-16657-P.       others were reviewed specifically for Beaver Valley Unit 2. The Level 2 OA to restore feedwater to a dry steam generator was added to the PRA model.
LE-   LE-C2b        B           Y        Only recovery of AC power after        Section 2.5 of the Level 2 LERF         No impact to Fire C2b-                                     UTAF is discussed in the Level 2       Analysis Notebook discusses the use     PRA, because 01                                       notebook. It is concluded that not     of Level 2 Operator Actions for         this issue was enough time exists to assign a high    recovery; specifically recovery of      addressed in the success probability. No other          feedwater to a dry steam generator is   base PRA model recoveries are discussed.              included in the CET Top Event OL. AC    prior to building electric power recovery is included in  the Fire PRA.
I        _                                                                 the Level 1 Top Event RE LE-  LE-C9a, LE-   B           Y        Level 2 and LERF analysis stopped      A discussion has been added to the      No impact to Fire C9a-  C9b                                at containment failure and continued   Level 2 LERF Analysis PRA Notebook      PRA, because 01                                       operation of equipment and operator    Section 2.4 General Modeling            this issue was actions were not modeled.              Assumptions and Criteria for Level 2    addressed in the Operation of mitigating systems after  Analysis to justify the significance of base PRA model containment failure is not modeled     the containment spray system on         prior to building I either. Justify the lack of credit of  LERF mitigation following containment   the Fire PRA.
Page 262 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                      1BVPS-2 Final Resolution                Impact to Fire ID    Requirement  Level        Closed                                                                                 PRA YIN I
equipment survivability,                failure. Details of equipment survivability can also be found in Appendix A.
LE-   LE-Cl0       B            Y      SGTR and containment bypass did         A discussion has been added to the      No impact to Fire C1 0-                                  not take credit for scrubbing.          Level 2 LERF Analysis Notebook          PRA, because 01                                     WCAP-16657 suggests that                Section 3.3 "Containment Event Tree,"   this issue was scrubbing for tube rupture events       Top Event OL to credit SGTR             addressed in the can be credited by an operator          scrubbing and the basis for the         base PRA model action restart auxiliary feedwater to   decontamination factor.                 prior to building the ruptured steam generator.                                                   the Fire PRA.
LE-   LE-D5         B           Y      Beaver Valley Thermal Induced           The PI-SGTR and TI-SGTR methods         No impact to Fire D5-                                    SGTR is based on a 1995 Fauske          are included in Appendix F of the Level PRA, because 01                                     and Associates report and               2 LERF Analysis Notebook.               this issue was Westinghouse Calculation CN-RRA-                                                addressed in the 02-38. Recent investigations                                                    base PRA model suggest that these results may be                                               prior to building too optimistic. A more reasonable                                               the Fire PRA.
approach may be implementing WCAP 16341, "Simplified LERF Model," and characterizing the uncertainties based on that latest EPRI, PWROG, and NRC interactions.                         I Page 263 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation                    BVPS-2 Final Resolution                   Impact to Fire ID    Requirement    Level        Closed                                                                                 PRA Y/N LE-   LE-D5          B            Y      The Cl analysis for BV2REV3b is       Following the Beaver Valley Unit 2        No impact to Fire D6-                                      based on a sub-atmospheric            Atmospheric Containment Conversion        PRA, because 01                                       containment. BV2 has been             modification, the containment still       this issue was converted to atmospheric so this      normally operates at slightly sub-        addressed in the analysis must be revisited,           atmospheric conditions. A discussion      base PRA model BVI REV4 does account for the         has been added in the Level 2 LERF        prior to building atmospheric containment conversion    Analysis Notebook Section                 the Fire PRA.
in the Containment Isolation          "Condensed Plant Damage State notebook. The results of a similar    Matrix for Beaver Valley Unit 2" to assessment for BV-2 need to be        outline the Beaver Valley Unit 2 incorporated in the LERF notebook. containment change from sub-atmospheric to atmospheric and the I                                                                         impact on the Level 2 analysis.
LE-    LE-E4         B            Y      The BV2 LERF model is quantified      The Level 2 phenomena split fraction      No impact to Fire E4-                                      using RISKMAN. Only point-            distributions are included in Table 3-26  PRA, because 01                                       estimates for each top event are      of the Level 2 LERF Analysis              this issue was used and there are no uncertainty     Notebook. This table contains Beaver      addressed in the estimates or uncertainty              Valley Unit 2 plant specific Level 2      base PRA model propagation.                          phenomena distributions along with the    prior to building mean, median, 5th%ile, and the            the Fire PRA.
95th%ile. A discussion on how these distributions were developed is provided in Section 3.4 of this notebook.
LE-   LE-F2         B            Y      The PRA Peer Review Team              The LERF uncertainty analysis was         No impact to Fire F2-                                     suggested in F&O L2-02 using          performed as part of the quantification   PRA, because 01                                      uncertainty analysis for the LERF top process using Monte Carlo sampling of     this issue was events to ensure that future          the Level 2 split fraction distributions. addressed in the applications are not affected by use  The result of this analysis is provided   base PRA model of point estimates.                   in the BVPS-2 Quantification              prior to building Notebook, Revision 5, Section 1.5.6       the Fire PRA.
Page 264 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                  Impact to Fire ID   Requirement   Level       Closed                                                                                  PRA YIN This F&O was entered into the          "Results of Containment Performance BVPS Corrective Action Program as      Analysis."
CA 02-09043-26 (Reference 16) to track and resolve the issues. The suggested PRA Peer Review Team resolution to this observation was not addressed in the BV2REV3B PRA model update, but will be evaluated sometime later in a future PRA model update.
This update has not yet been completed. At the time, it was a "C" level F&O but the PRA standard raises the requirements for PRA quality and this F&O is now a "B" level.
LE- LE-G5         B           Y      Limitations of the LERF analysis are    Section "Limitations of the Level 2      No impact to Fire G5-                                   identified throughout the BV2 Level 2   Model" has been added to the Level 2     PRA, because 01                                    notebook. However, they need to be      LERF Analysis Notebook to include        this issue was gathered into a single location to      limitations of the Level 2 analysis. addressed in the facilitate future usage.                                                         base PRA model prior to building the Fire PRA.
LE- LE-B3         C           Y      In Section 2.1 of the LERF              Level 2 LERF Analysis Notebook           No impact to Fire B3-                                  Notebook, it is stated that MAAP,       Section 2.1 "Guidelines on Grouping      PRA, because 01                                   STCP, and MELCOR are used to            Core Damage Sequences into Plant         this issue was characterize the timing of important    Damage States Based on Their             addressed in the events. There is no evidence that       Accident Progression Attributes" has     base PRA model STCP and MELCOR are ever used.          been updated to include a discussion     prior to building of the codes used and their applicable   the Fire PRA.
I analyses.                              I Page 265 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-2 Final Resolution                Impact to Fire ID  Requirement    Level        Closed                                                                                  PRA Y/N LE- LE-D3          C            Y      The LERF assessment for ISLOCA            The ISLOCA analysis is reported in the No impact to Fire D3-                                    is self contained in the Appendix D       Initiating Event Notebook. The Level 2 PRA, because 02                                     of the Initiating Event Analysis          LERF Analysis notebook contains a      this issue was notebook. There is no reference to        pointer to the ISLOCA analysis in      addressed in the the ISLOCA assessment in the              Section 1.2 "Interrelationship with    base PRA model LERF notebook. It is not readily          Other Parts of PRA."                   prior to building apparent from reading the LERF                                                   the Fire PRA.
notebook that an ISLOCA assessment was done.                    I QU- QU-F4, QU-     A            Y      The Revision 3B Quantification            Documentation of a more rigorous       No impact to Fire F4- E4, IE-D3                          notebook Section 5 states that the        uncertainty analysis for the Beaver    PRA, because 01                                     PRA notebooks..."include an               Valley Unit 2 Revision 5a PRA model    this issue was estimation of the uncertainty             is presented in Section 5 and Appendix addressed in the introduced by the data used to            B of the Quantification Notebook       base PRA model quantify the PRA model...This                                                    prior to building uncertainty estimation does not,                                                 the Fire PRA.
however, reflect possible effects on the results from other sources of uncertainty. Such sources may include such things as: optimism or pessimism in definitions of sequence, component, or human action success criteria; limitations in sequence models due to simplifications (for example, not modeling available systems or equipment) made to facilitate quantification; uncertainty in defining human response within the emergency procedures...; degree of completeness in selection of initiating events; assumptions regarding phenomenology or Page 266 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                        BVPS-2 Final Resolution Impact to Fire ID  Requirement  Level        Closed                                                                   PRA YIN structures, systems, and components (SSC) behavior under accident conditions... While it is difficult to quantify the effects of such sources of uncertainty, it is important to recognize and evaluate them because there may be specific PRA applications where their effects may have a significant influence on the results.
QU-F4 requires that these sources of uncertainty be characterized regardless of the difficulty of the evaluation. By Beaver Valley's own admission (above), it is important to recognize and evaluate them because there may be specific PRA applications where their effects may have a significant influence on the results.
Furthermore, the documentation provided in Chapter 5 of the Quantification notebook makes a start at identifying the sources of model uncertainty. PWROG guidance suggests the number of identified sources of uncertainty typically is on the order of 50 items.
it is also suggested the BVPS perform a more rigorous search to complete a fairly complete list of sources of uncertainty.
Page 267 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact &Observation                     BVPS-2 Final Resolution                     Impact to Fire ID   Requirement  Level       Closed                                                                                   PRA Y/N QU-  QU-B9        B           Y      Component boundary conditions are A table of component boundaries was             No impact to Fire B9-                                  not well defined. The Data Analysis added to section A.4 of the Unit 2            PRA, because 01                                   Notebook, as well as several system PRA Data Analysis Notebook (PRA-              this issue was notebooks (AFW &SWS) were             BV2-AL-R05a).                               addressed in the reviewed and there is no discussion                                               base PRA model of component boundary (a pump fail                                                prior to building to start, for example.. .does the                                                 the Fire PRA.
component boundary include the local circuitry?). There are assumptions made regarding system boundaries, but no discussion of component boundaries. As a result, module definitions can not be determined.
QU-  QU-F4, QU-   B           Y      A detailed description of the         Documentation of the RISKMAN                No impact to Fire F4-  F5                              RISKMAN quantification process is     software quantification limitations are     PRA, because 02                                   provided. However, the Revision 3B presented in Appendix A, Section A.1.1         this issue was Quantification notebook does not      "RISKMAN Software Limitations" of the       addressed in the discuss limitations inthe             Quantification Notebook                     base PRA model methodology,                                                                      prior to building the Fire PRA.
QU- QU-D5a        B           Y      Significant contributors to CDF have  Documentation of the significant            No impact to Fire D5a-                                 been identified, but there is no      contributors to CDF, including initiating   PRA, because 01                                   identification of SSCs and operator   events, accident sequences, basic           this issue was actions that contribute to initiating events (containing common cause             addressed in the event frequencies and event           failures), components, systems, and         base PRA model mitigation                            operator actions are included in            prior to building Section 3 "Results" of the                  the Fire PRA.
Quantification notebook. The System Notebooks also provide information on SSC and operator action (i.e., basic event) contribution to initiating event   I Page 268 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                   BVPS-2 Final Resolution                  Impact to Fire ID  Requirement  Level        Closed                                                                               PRA Y/N frequencies and event mitigation, in the cutset listing reports.
QU- QU-F6         B           Y      Beaver Valley does list important    The definition of significant accident   No impact to Fire F6-                                  operator action basic events;        sequences in provided in Section 3.1     PRA, because 01                                   however, there is no documented      of the Quantification Notebook.          this issue was definition of "significant". The     Section 3.1.4 provides the definition of addressed in the Revision 3B Quantification notebook  significant systems. The top 10 basic    base PRA model lists top accident sequences but     events, components, and operator         prior to building provides no definition of whether    actions ranked by Birnbaum               the Fire PRA.
they are "significant" or not. The   importance are also considered only discussion is that there is "no significant.
single sequence makes up a large fraction of the CDF".
Page 269 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact &Observation                        BVPS-2 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                    PRA Y/N The Revision 3B Quantification notebook states the following definition for important systems:
                                     "The system rankings for determining High Importance is based on having an F-V Importance greater than 5.OE-02 or a RAW greater than 10, while the Low Importance is based on having an F V Importance less than 5.0E-03 and a RAW less than 2. Medium Importance systems are comprised of everything else in between these importance measures." This definition agrees with the Regulatory Guide 1.200 definition for "significant contributors." However, there is no documented justification (no reference to a standard definition, such as R.G. 1.200 or the EPRI PRA Applications Guide).
QU- QU-D5b       C            Y      The BVPS-2 system importance              Documentation of the basic event and     No impact to Fire D5-                                  rankings are based on component           component importances are provided       PRA, because 02                                   importances; however there is no          in Section 3.1.3 "Basic Event and        this issue was specific discussion of component or       Component Importance Rankings," of       addressed in the basic event importances (excluding        the Quantification Notebook. A           base PRA model operator actions).                        complete listing CDF importance          prior to building measures for all basic events and        the Fire PRA.
components are provided in the linked files "CDF Basic Event Importance.xls" and "BV2R5L1 CDF Component 1 Importance.xls."                       I Page 270 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                   BVPS-2 Final Resolution                  Impact to Fire ID  Requirement  Level        Closed                                                                               PRA YIN Sc- SC-A5        B            Y      This SR requires that for sequences  A discussion has been added in the       No impact to Fire A5-                                  in which stable plant conditions     medium LOCA Top Event MU to              PRA, because 01                                   would not be achieved by 24 hr       address containment flooding and         this issue was using the modeled plant equipment    supply of make water. Containment        addressed in the and human actions, PERFORM           flooding is a severe accident mitigating base PRA model additional evaluation or modeling by strategy used to flood up to the lower   prior to building using an appropriate technique.      head of the RPV to significantly delay,  the Fire PRA.
and possibly prevent vessel failure.
The consequences of containment flooding have been addressed in BVPS-2 SAMG CA-5, "Containment Water Level and Volume," to determine when water levels are jeopardizing vital equipment and monitoring capabilities.
A review of Figures 1 & 2 and Table 6 of this document revels that no significant core damage mitigating equipment or instrumentation would be impacted, even if 3 RWST volumes are injected. There is an unlimited supply of makeup water via the Ohio River.
Page 271 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance  Status   Fact& Observation                        BVPS-2 Final Resolution                    Impact to Fire ID  Require m ent Level         Closed                                                                                       PRA IYIN    I The MU top event for medium LOCA         Furthermore, if a significant volume of and Small LOCA/General Transient         service water is added to the Spent uses RWST makeup as part of the          Fuel Pool, makeup procedure 20M-success path when recirculation has      7.4.0 recommends the addition of failed. While a mission time of 24       boric acid to the Spent Fuel Pool to hours is assumed, the plant is not at    maintain adequate shutdown margin.
a safe stable state because another      Therefore, at BVPS actions to add action is required for long term         makeup to the RWST and use the success. The RWST refill results in      HHSI pumps in SI injection mode for additional water to the containment      continued RCS makeup are which eventually will result in the      determined to result in a safe stable design basis flooding level being        plant condition. This would be true for exceeded and the potential for           all accidents identified in the F&O (i.e.,
subsequent loss of instrumentation       medium LOCA, small LOCA, General and control. The impact of               Transient, SGTR, and ISLOCA).
continued RWST makeup and injection into containment needs to be discussed in relation to the achievement of a safe stable state where no additional operator actions are required.
A similar situation exists for SGTR and ISLOCA where RWST refill is being used to maintain core cooling, but the justification for mission time of only 24 hours is not apparent given that the plant is not in a safe stable state by traditional definitions.
Page 272 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution               Impact to Fire ID  Requirement   Level        Closed                                                                               PRA Y/N SC- SC-C2         B            Y      No discussion of the limitations of     Section "MAAP-DBA Limitations" has    No impact to Fire C2-                                   the MAAP code for Success Criteria been added to the Success Criteria         PRA, because 01                                    are provided in the Success Criteria    Analysis Notebook to identify the     this issue was Notebook. Two known limitations         limitations of the MAAP-DBA code. addressed in the are the use of MAAP for early phase                                           base PRA model large LOCAs and the use of MAAP                                               prior to building for SG dryout assessments without                                             the Fire PRA.
benchmarking to design basis codes (e.g., bleed and feed initiation). It was observed in the Success Criteria Notebook that MAAP runs were made to justify only 1 accumulator (but that 2 of 2 intact accumulators appear to have been actually used as stated to be used in Section 3.1 of the Notebook). It is recommended that a discussion of MAAP limitations (similar to that provided in the EPRI assessment for MAAP 3) be documented or referenced in the Success Criteria Notebook.                            I SC- SC-A5         C            Y      The success criteria for top event      A discussion has been added to the    No impact to Fire A5-                                   WM for the SGTR states that 400         Success Criteria Analysis Notebook in PRA, because 02                                     gpm makeup to the RWST is              Section 3.5 "Steam Generator Tube     this issue was sufficient to maintain HHSI for RCS    Rupture" Top Event WM to address      addressed in the inventory control at full RCS          RWST makeup.                          base PRA model pressure despite leakage through a                                           prior to building ruptured SG tube.                                                            the Fire PRA.
Page 273 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                         BVPS-2 Final Resolution            Impact to Fire ID   Requirement  Level        Closed                                                                               PRA Y/N The maximum RCS inventory loss through a single SGTR is on the order of 600 gpm if the primary side is at normal operating pressure and the secondary side of the SG is not depressurized. This is in excess of the 400 gpm makeup and therefore appears to invalidate the success criteria as stated. Also, if continued HHSI at full system pressure is required, SG overfill is likely to occur and the SG will be depressurized and the leakage through the I_                                ruptured tube will even be higher.
SC-  SC-B1        C            Y      Reviewer Note R7 for TH states that        Section "MAAP-DBA Limitations" has No impact to Fire B1-                                   MAAP limitations were observed and been added to the Success Criteria         PRA, because 01                                    MAAP was not used for Large LOCA Analysis Notebook to identify the            this issue was early success criteria such as             limitations of the MAAP-DBA code. addressed in the accumulators. It was observed in                                              base PRA model the Success Criteria Notebook that                                            prior to building MAAP runs were made to justify only                                          the Fire PRA.
1 accumulator but that 2 of 2 intact accumulators was stated to be used in Section 3.1 of the Notebook. This may be confusing for future use because no discussion of MAAP limitations is presented in the Appendix containing the MAAP analyses (e.g., at page C-8 of the U2 Success Criteria Notebook).             I Page 274 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                      BVPS-2 Final Resolution                   Impact to Fire ID  Requirement  Level        Closed                                                                                   PRA YIN Sc- SC-B5        C            Y      The ASME PRA requirement for SC-        Attachment D has been added to the        No impact to Fire B5-                                  B5 includes the possibility of          Success Criteria Notebook to compare      PRA, because 01                                   comparison to check the                 the Beaver Valley Unit 2 results with     this issue was reasonableness of the success           North Anna Unit 1. Furthermore, the       addressed in the criteria. It is recommended that such   Beaver Valley PRA model success           base PRA model as effort be undertaken, possibly as    criteria developed using MAAP were        prior to building a PWROG or EPRI effort.                 compared with the NUREG-1953 Surry        the Fire PRA.
success criteria (a similar plant), which used the MELCOR computer code and were found to be in good agreement.
SC- SC-Cl, SY-   C            Y      The ASME PRA Standard for SC-Cl         Section "System Success Criteria" has     No impact to Fire C1- C1                               requires that Success Criteria be       been added to the Success Criteria        PRA, because 02                                   documented in a manner that             Analysis Notebook to show where the       this issue was facilitates applications, upgrades,     system specific success criteria are      addressed in the and peer reviews. The current state     contained in each system notebook,        base PRA model of the BVPS PRA Success Criteria is                                               prior to building that the accident sequence success      This was believed to be the best place    the Fire PRA.
criteria are gathered in the Success    to locate support system success Criteria Notebook, but other success criteria.
criteria are scattered about though the PRA. Examples include the SW success criteria and ISLOCA success criteria for U1. It is recommended that FENOC consider gathering all success criteria in the Success Criteria Notebook to facilitate future usage.              I Page 275 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status   Fact & Observation                      BVPS-2 Final Resolution                    Impact to Fire ID   Requirement   Level       Closed                                                                                      PRA Y/N I
SC-  SC-B1        S            Y        CCIII of the standard requires that     No response required for F&O SC-B1-        No impact to Fire Bi-                                     plant specific analyses be used to      02.                                        PRA, because 02                                      determine success criteria with plant                                              this was identified specific analyses. The large number                                                as a strength of of MAAP analyses for success                                                       the model.
criteria meet this requirement and the BVPS Ul and U2 PRAs are considered to be exemplary in this respect.
SY-  SY-A14, SY-   B           Y        The DRAFT Revision 4 System             Instances of excluded failure modes        No impact to Fire A14- A12, SY-C1                         notebooks (AFW, SWS, CCS, CCP,          and contributors to unavailability for the PRA, because 01                                      MFW were reviewed) discuss failure      applicable systems were reviewed and       this issue was modes and contributors to system        compiled into a single location in their   addressed in the unavailability and unreliability that   respective System Notebooks. When          base PRA model are excluded from the systems           warranted, justification for the excluded  prior to building analysis. However, the SY-A14           failure mode or unavailability             the Fire PRA.
criteria does not appear to have        contributor was made more thorough.
been applied consistently throughout This information is located in the the analysis. The only exceptions       Excluded Failure Modes and found where the SY-A14 criteria are     Unavailability Contributors section of explicitly met is in the CCS            the notebooks.
notebook, Section 14, c, Assumption
                                        #2, and the AFW notebook Section 14, c, Assumption #3. In some instances, such as the CCP notebook Section 14, c, Assumption
                                        #1, there was no explanation given for why the contributor was not modeled.                              I Page 276 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact& Observation                    BVPS-2 Final Resolution               Impactto Fire ID  Requirement   Level       Closed                                                                            PRA Y/N SY- SY-C1         B           Y      In providing the response to peer    I he Common Cause section ot the      No impact to Fire C1-                                  review F&O DA-09, which deals with   System Notebooks now references the   PRA, because 01                                   providing documentation of the CCF   Common Cause Modeling section,        this issue was groupings, Beaver Valley noted that  Table A-i, and Table 1 of the Systems addressed in the the Systems Analysis Overview and    Analysis Overview and Guidance        base PRA model Guidance notebook provides the       Notebook to thoroughly document the   prior to building process used to identify CCF         methodology and grouping of the       the Fire PRA.
groupings. The response further      common cause modeled in the PRA.
suggests details of the common cause groups that were retained in the PRA system models and presented in Appendix C of the BVPS Unit 2 PRA System Notebooks, under the common cause sections of the RISKMAN System Notebook files are adequately documented and can be found by knowledgeable personnel.
The reviewer agrees that one can review Appendix C of the Systems notebooks and see what the CCF groupings are and how the CCF probabilities were generated. The reviewer also agrees that high level guidance is provided in the Systems Analysis Overview and Guidance notebook. However, it appears a link between the two documents is missing.
Page 277 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact &Observation                       BVPS-2 Final Resolution                Impact to Fire ID   Requirement  Level        Closed                                                                                PRA Y/N For example, the guidance states "When identical, nondiverse, and active components are used to provide redundancy, they should be considered for assignment to common cause groups, one group for each identical redundant component". When the Systems notebook Appendix C is reviewed, the components contained in the CCF group is clearly identified, but there is no documentation that states that those components are "identical, and/or non-diverse" or used to provide redundancy.
Further examination of other sections System notebooks (such as Section 3 "System Success Criteria",
or Section 6 "Operating Features" would lead a reviewer to find this type of information. But this documentation is not always intuitively obvious and makes peer review difficult at times.
SY- SY-Al 1        C           Y      The system notebooks do not             An additional response has been        No impact to Fire All-                                  specifically discuss the                added to the evaluations of the areas  PRA, because 01                                    dependencies that may be present        that are represented by the actual top this issue was regarding HVAC I room cooling,          event equipment whether the HVAC       addressed in the However, review of the HVAC             dependency is required or not and is   base PRA model notebook identified the various         located in Support Systems section in  prior to building spatial locations that may require      the system notebooks.                  the Fire PRA.
HVAC and indicated the various        I Page 278 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                    BVPS-2 Final Resolution                  Impact to Fire ID  Requirement   Level        Closed                                                                                  PRA Y/N    I analyses that have been completed to either require HVAC dependencies or not..
SY- SY-B1         C            Y        At the time of the BVPS Unit 2         Up-to-date generic MGL CCF data has     No impact to Fire B1-                                     common cause MGL data update           been updated in PRA-BV2-AL-R05          PRA, because 01                                      during Revision 3, the NRC update      using WCAP-16672-P (Section 3.6 and     this issue was to NUREG/CR-5497 was still not        Table C-5 in the Data Analysis           addressed in the available. As such, a decision was     Notebook). In June 2008,                base PRA model made during the update process to     Westinghouse issued WCAP-16672-P         prior to building keep the existing generic MGL data,   which covers 1980 - 2003 in order to     the Fire PRA.
which is almost exclusively based on   provide guidance to address the the PLG generic database dated         concerns that were raised regarding circa 1989. There is no                the consistency and correctness of the documentation to illustrate that the   CCF events included in the NRC CCF Beaver Valley considered               database. The WCAP data source NUREG/CR-5497 during the               contains CCF parameter estimates for Revision 4 PRA update.                 the majority of risk-significant components whose performance are potentially applicable to PWROG utilities only in the U.S. designed by either Westinghouse or Combustion Engineering. The parameter estimates for failure modes of significant components that are generally included in the PRA are provided for the Alpha factors that are converted to the Multiple Greek Letter approach I (MGL) by the method in NUREG/CR-         _I Page 279 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                    BVPS-2 Final Resolution                   Impact to Fire ID  Requirement   Level        Closed                                                                                 PRA Y/N 5485 and to allow for quantifying CCF probabilities.
-SY- SY-B7         C            Y      The Service cooling water system      The Miscellaneous Top Events              No impact to Fire B7-                                   notebook assumption #7 lists 10       Notebook, Top Event OC models the         PRA, because 01                                    minutes to trip the RCPs on loss of   operator actions to trip the RCPs         this issue was cooling. However, in the              during situations that exist for greater  addressed in the Miscellaneous system notebook, top    than 5 minutes, in which either CCP is    base PRA model event OC has 5 minutes to trip the    lost to the RCPs, or both RCP seal        prior to building RCPs. Note, this time might be        injection and thermal barrier cooling     the Fire PRA.
important in quantifying HEP for      are lost. Both of these conditions RCP trip.                             would be covered in the abnormal operating procedure 20M-53C.4.2.6.8 "Abnormal RCP Operation", and RCP parameters would be monitored to identify situations that warrant an immediate RCP shutdown.
If either of these conditions exist for greater than 5 minutes, the human reliability analysis for operator actions OPROCI (loss of CCW) and OPROC2 (Loss of RCP seal Cooling) assume that the operators would trip the RCPs at 5 minutes, and that the RCPs seals 1 would be damaged in 13 minutes if Page 280 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact& Observation                    BVPS-2 Final Resolution                 Impact to Fire ID    Requirement  Level        Closed                                                                              PRA Y/N they were not tripped, leading to a 480 gpm per RCP seal LOCA. These timing assumptions and consequences are based on BVPS AOPs and WCAP-16141.
SY-   SY-B1 3      C            Y      There does not appear to be a        This F&O only applies to BVPS Unit 2. No impact to Fire B133-                                  detailed room heatup analysis to                                             PRA, because 01                                     support the evaluation for Area 7 in A detailed BVPS Unit 1 room heatup      this issue was the Revision 3B HVAC notebook.       analysis of the main steam valve room   determined to There are several qualitative        following an SBO (8700-DMC-2312,        have no effect on arguments in addition to crediting   Revision 0, Addendum 2), which          the BVPS PRA manual actions for SBO.              determined that the steady-state        model.
ambient air temperature is expected to be 133 0 F (with roof louvers open). It was judged that the Unit 2 main steam valve room would have a similar steady state ambient air temperature, so a detailed room heatup analysis was not warranted since this temperature is well below the equipment qualification temperature of 348 0 F for the area. Additionally, cooling vests are available for operators to wear while performing any actions located in the main steam valve room.
A subsequent search of Unit 2 calculations, revealed that a room heatup analysis of the Unit 2 main steam valve room following an SBO was performed (10080-DMC-56, Page 281 of 301

Table 2-2. Summary of BVPS-2 RG 1.200 Gap Analysis - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                    BVPS-2 Final Resolution                Impact to Fire ID  Requirement Level        Closed                                                                                PRA Y/N I
Revision 0, Addendum 1), which determined that the steady-state ambient air temperature is expected to be <120&deg;F (with roof louvers open).
SY- SY-C1         C          Y        The Beaver Valley Unit 2 system       System Engineers reviewed the          No impact to Fire C1-                                   notebooks have no indication of       system notebooks for PRA-BV2-AL-       PRA, because 02                                    system engineering reviews. These     R05, in which they had to present      this issue was reviews help ensure that systems      comments and provide input for the top addressed in the are model in accordance with day-to-  event system review. System            base PRA model day plant operations and additionally Engineering comments have been         prior to building expand the PSA knowledge of the       incorporated into BVPS-2 PRA           the Fire PRA.
system engineers,                     corresponding system notebooks. A table that contains the comments is located inAppendix B in the System Analysis Overview for BVPS-2.
SY- SY-B5, SY-    D          Y        The system notebooks do not           An additional response has been        No impact to Fire B5- B6, SY-B1i0,                      specifically discuss the              added to the evaluations of the areas  PRA, because 01  SY-B11                            dependencies that may be present      that are represented by the actual top this issue was regarding HVAC / room cooling,        event equipment whether the HVAC       addressed in the However, review of the HVAC           dependency is required or not and is   base PRA model notebook identified the various       located in Support Systems section in  prior to building spatial locations that may require    the system notebooks.                  the Fire PRA.
HVAC and indicated the various analyses that have been completed     Since this F&O is essentially the same to either require HVAC                as F&O SY-Al 1-01, itwas also dependencies or not.                  resolved by it Page 282 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                         BVPS-2 Final Resolution               Impact to Fire ID  Requirement  Level        Closed                                                                                  PRA W/N HR- HR-D5,       Finding      Y      BVPS does not have a written               Section 2.2 of the HRA Notebook       No impact to Fire PR-                                  process for evaluating dependencies        documents the methodology and         PRA, because this 001                                  between multiple HEPs occurring in a       evaluation of the pre-initiator HEPs. issue was single accident and does not provide       A summary of the EPRI HRA             addressed in the a summary of HEPs that were                Calculator results can be found in    base PRA model explicitly evaluated for dependencies      Table 3.5 which supplements the       prior to building the and the associated levels of               detailed calculations documented in   Fire PRA.
dependencies and joint HEPS. The           Appendix E.
HR-G7,                           BVPS HRA notebooks do not have a HR-H3,                           single summary table of the                Section 2.3 of the HRA notebook has preinitiator human actions and the         been created to provide a summary documentation of the evaluation of         of HEPs that were explicitly pre-initiator human actions in the         evaluated for dependencies and to system notebooks, which make it            document that PRA Analysis No.
difficult to identify which actions were   PRA-BV2-12-002-R00, "BVPS-2 actually evaluated.                        HRA Dependency Analysis,"
Revision 0 provides the process used for the dependency analysis evaluation (See F&O HR-12-01 in Section 6).
HR-I1, HR-12(d)3 HR- HR-G6, HR-   Finding      Y      BVPS does not appear to have               An internal consistency check for     No impact to Fire PR- 12                               evaluated their HEPs for internal          pre-initiator HEPs is documented in   PRA, because this 002                                  consistency consistent with the            Section 3.4 of the Unit 2 HRA         issue was requirements of HR-G6 and does not         notebook (PRA-BV2-AL-R05a).           addressed in the have a documented process to do                                                  base PRA model so.                                        The original post-initiator HRA was   prior to building the developed using the SLIM/FLIM         Fire PRA.
process, and as such were grouped with respect to similar performance I shaping factors and weights (e.g.,
Page 283 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance   Status   Fact & Observation             BVPS-2 Final Resolution               Impact to Fire ID  Requirement  Level          Closed                                                                        PRA I YIN    I actions where time and preceding actions are most important were grouped together) to have internal consistency during the HEP development. As a final check of overall consistency, the HEPs from each group were then compared with those of other groups to determine if the differences in the HEPs were warranted by the differences in the scenarios and PSF ratings.
The BV2REV4 PRA model revised the HRA methodology from the SLIM/FLIM process to the EPRI HRA Calculator. The HRA Calculator is a software program that is designed to implement consistency within the field of human action analysis by creating a standard methodology for quantification and documentation of HEPs in the context of the PRA.
After this conversion was complete, the resulting HEP values were then compared to the previous BV2REV3B SLIM/FLIM HRA model (see Table 3-4 of the HRA Notebook, Revision 1 drafted for BV2REV4), to verify consistency in overall trends between events.
Since these BV2REV3B PRA Model SLIM/FLIM HEPs were compared to Page 284 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact& Observation                     BVPS-2 Final Resolution               Impact to Fire ID  Requirement   Level        Closed                                                                             PRA Y/N the BV2REV4 PRA Model HRA Calculator HEPs to check their reasonableness, there is a de facto consistency check in the HEPs.
HR- HR-D2, HR-    Finding      Y      The method for quantifying pre-       Pre-initiators are now quantified     No impact to Fire PR- D3, HR-D4,                        initiator misalignment errors as      using the THERP methodology as        PRA, because this 003 HR-1i, HR-12                      described on page 8 of the "Beaver    presented in the EPRI HRA             issue was Valley Power Station Unit 2 PRA       Calculator. This is documented in     addressed in the Notebook - Human Reliability          Sections 2.2 & 3.4 and Table 3-5 of   base PRA model Analysis," Revision 2, dated          the HRA Notebook. The pre-initiator   prior to building the 10/01/07, relies on the use of a      human error probabilities were        Fire PRA.
generic Error of Omission rate that   determined using BVPS operator does not reflect any detailed          input and BVPS specific procedures assessment of the HEPs. The           and processes. The process now process also does not consider the    considers the plant specific written quality of plant-specific written      procedures, administration controls, procedures, administrative controls   and man-machine interface.
or the man-machine interface and does not include an explicit          A list of the pre-initiator HFEs and assessment of the potential for       their probabilities was added to recovery that specifically delineates  Section 3 in Table 3 5.
which procedures and processes influence the potential for identification and recovery.
Furthermore, the method for quantifying post-maintenance miscalibrations relies on a single generic error of omission rate.
Page 285 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O  Supporting. Significance Status Fact & Observation                       BVPS-2 Final Resolution              Impact to Fire ID   Requirement   Level        Closed                                                                               PRA YIN A complication in reviewing the pre-initiator Human Failure Events (HFEs) was that the HRA notebook does not include a list of the pre-initiator HFEs or their probabilities.
The system notebooks provide evidence of the search for and identification of misalignments but they do not present a list of such events or their probabilities.
HR-   HR-C2        Finding      Y      Post-maintenance misalignments           Section 2.2 and Appendix C of the    No impact to Fire PR-                                    were excluded for normally operating HRA Notebook document the review         PRA, because this 004                                    system based on the assumption that of BVPS procedures (OSTs, BVTs,           issue was misalignments on normally operating      and MSPs) to identify potential      addressed in the systems would be quickly detected        misalignments. Section 2.2 and       base PRA model and corrected. Post-maintenance          Appendix D of the HRA Notebook       prior to building the unavailabilities were included for       documents the review of historical   Fire PRA.
standby    systems as appropriate,       event data for misalignment However, nowhere in the HRA             identification. A search of the BVPS notebook or the system notebooks         1&2 Corrective Action Program that were reviewed was there any         (CAP) was performed to identify pre-indication that BVPS had performed      initiators that have occurred at a review of their                       BVPS. A review was also performed operating/maintenance data to look      with the BVPS operator I_                                for post-maintenance misalignments.
HR-  HR-13        Finding      Y      The BVPS HRA is documented in the Section 7of the Unit 2 HRA notebook          No impact to Fire PR-                                    "Beaver Valley Power Station Unit 2     (PRA-BV2-AL-R05a) was added to        PRA, because this 005                                    PRA Notebook - Human Reliability        document HRA assumptions.             issue was Analysis", Revision 2, dated                                                  addressed in the 10/01/07. This notebook does not                                              base PRA model have an explicit assumptions section                                          prior to building the to identify and characterize                                                  Fire PRA.
assumptions. A review of this         I Page 286 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status   Fact & Observation                     BVPS-2 Final Resolution               Impact to Fire ID  Requirement  Level        Closed                                                                                PRA YIN    I notebook revealed assumptions scattered throughout the text.
HR- HR-F2        Finding      Y        In reviewing the set of post-initiator The "Success Criteria/ Basis of       No impact to Fire PR-                                    HFEs in Table 3-1, It was noted that   Timing" for ZHEMA2 was revised to     PRA, because this 006                                    for the HFE ZHEMA2, the specified      reflect the proper timing basis. The  issue was time window, 13.26 hours, was not      present BV2REV5A value for HFE        addressed in the consistent with the information        ZHEMA2 is 795.6 minutes = 13.26       base PRA model provided in the "Success Criteria/     hours (based on MAAP-DBA Run          prior to building the Basis of Timing" for that HFE. A       U2_SBO2) which is consistently        Fire PRA.
review of the referenced MAAP case     stated in both Table 3-1 and indicates that the 13.26 hours is the  Appendix B of this notebook appropriate timing. Furthermore, continued review of table 3-1 indicated that this seemed to be an isolated event.
HR- HR-B1        Finding      Y        In general, BVPS excludes virtually    ASME/CNRM Inquiry 09-56 states        No-impact to Fire PR-                                    all miscalibration events based on     that miscalibrations are included in  PRA, because this 007                                    the assumption that events related to  the Common Cause Failure (CCF)        issue was instrument miscalibrations are         events for the NRC CCF Database.      addressed in the captured in the equipment failure rate Since BVPS includes miscalibrations   base PRA model data and the On-line Maintenance       in the CCF events, it would be        prior to building the program precludes common-cause         double counting to also include them  Fire PRA.
miscalibration by scheduling work on   as pre-initiators. As a result, it is opposite trains in different weeks. believed that BVPS's current Post-maintenance misalignments         treatment of miscalibrations as part were excluded for normally operating   of the CCF events and not pre-system based on the assumption that    initiators meets Capability Category Page 287 of 301

Table 2-3. Summary of BVPS-2 HRA Focused Peer Review - Facts and Observations Resolutions F&O Supporting. Significance Status Fact & Observation                     BVPS-2 Final Resolution                Impact to Fire ID  Requirement  Level        Closed                                                                               PRA W/N misalignments on normally operating    II (instead of Capability Category I).
systems would be quickly detected and corrected. While these rules seem reasonable, they are applied to classes of maintenance and test activities to screen them from further consideration. This is sufficient for  An exception to this is the SSPS Capability Category I but not for      model, which did include instrument Capability Category II.                string miscalibration errors in the fault tree model.
A search of the Corrective Action database in April 2010 did not reveal any such miscalibration errors between trains at Beaver Valley Unit 2 to date.
Page 288 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation              BVPS-2 Final Resolution                    Impact to Fire PRA ID      Requirement Level        Closed Y/N IFPP-   IFPP-B1,    Finding      Y      The documentation               This F&O was entered into the BVPS         No impact to Fire PRA, Bl-01   IFSO-B1,                        generally does not facilitate    Notification System as BV2 Notification   because this issue was IFSN-B1,                        peer review. The technical      #600689091, Task 17, to track and          addressed in the base IFEV-B1,                        aspects of the analysis are      resolve the issues. As a resolution to    PRA model prior to IFQU-B1                         documented in a manner          this IFPRA Peer Review finding, Section    building the Fire PRA.
that cannot be readily          2 of the Internal Flooding Analysis understood by individuals        Notebook (PRA-BV2-AL-R05a) was outside the staff. The           revised in order to facilitate the Peer ordering of the                  Review process. Figure 2-1 provides an documentation is                 overview of the ASME/ANS PRA significantly different from     Standard requirements and their the standard; a detailed         relationships to the analysis and graphical roadmap of the         information contained in the various analysis process would           sections/appendices/tables of the report.
enable peer reviewers to         This documentation mapping is relate the order of the          consistent with that presented in the documentation to the             EPRI Final Report 1019194, Guidelines standard.                        for Performance of Internal Flooding I                                                                 Probabilistic Risk Assessment.
IFPP-   IFPP-B2    Finding      Y      The process described the        This F&O was entered into the BVPS        No impact to Fire PRA, B2-01                                  identification of site           Notification System as BV2 Notification   because this issue was buildings and flood areas,      #600689091, Task 6, to track and           addressed in the base but the documentation does       resolve the issues. As a resolution to     PRA model prior to not clearly establish the        this IFPRA Peer Review finding, the       building the Fire PRA.
basis for the set of buildings intent of Table 3-1 was clarified prior to considered in the analysis.      Section 3.1 (Identify Flood Areas) in the The references to source         Internal Flooding Analysis Notebook material are not sufficiently    (PRA-BV2-AL-RO5a) to plainly indicate specific to allow replication    the table represents a complete list of of the process. The              plant buildings/structures based on documentation will be easier referenced materials and that it includes to follow if the basis for the   the preliminary building screening.
selection of buildings         II Page 289 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation              BVPS-2 Final Resolution                 Impact to Fire PRA ID     Requirement Level        Closed YIN considered in the analysis is enhanced. There is reference to review of plant documentation including the fire analysis, but no statement that the list of buildings in Table 3-1 is the complete list of buildings.
IFPP-  IFPP-B3     Finding      Y      The process used to             This F&O was entered into the BVPS      No impact to Fire PRA, B3-01                                  determine the plant             Notification System as BV2 Notification because this issue was partitioning requires some      #600689091, Task 7, to track and        addressed in the base level of assumptions            resolve the issues. As a resolution to  PRA model prior to concerning how the plant        this IFPRA Peer Review finding, plant   building the Fire PRA.
partitions are established,     partitioning assumptions were The current plant               documented in Section 3.5 of the partitioning has no             Internal Flooding Analysis Notebook discussion of the               (PRA-BV2-AL-R05a).
uncertainties and assumptions associated with the plant design features used to create flood areas.
Page 290 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation               BVPS-2 Final Resolution                   Impact to Fire PRA ID     Requiremen t Level        Closed YIN IFSO-  IFSO-A4      Finding      Y      The potential flooding           This F&O was entered into the BVPS        No impact to Fire PRA, A4-01                                   effects is not listed within     Notification System as BV2 Notification   because this issue was any of the tables               #600689091, Task 3, to track and           addressed in the base documenting the potential        resolve the issues. As a resolution to    PRA model prior to flooding sources. The            this IFPRA Peer Review finding, Section   building the Fire PRA.
ASME/ANS standard                4.1 (Flood Source Failure Mechanisms requires the inclusion of the    and Failure Modes Summary) was potential flooding               added to the Internal Flooding Analysis mechanisms when                  Notebook (PRA-BV2-AL-R05a) to describing the flood sources     specifically address: a) a discussion of used in the model.               failure modes and mechanisms associated with each flood source with direct reference to latter documentation sections for further discussion, and b) the EPRI methodology which embeds failures of all piping system components as part of the piping segment failures averaged on a per linear foot basis.
Furthermore, Section 4.2 was added to address any flood source identification assumptions with direct reference to latter documentation sections for further discussion.
IFSO-  IFSO-A5      Finding      Y      This supporting requirement      This F&O was entered into the BVPS        No impact to Fire PRA, A5-01                                    identifies information used     Notification System as BV2 Notification   because this issue was to characterize the flooding     #600689091, Task 5, to track and          addressed in the base sources. Most of the            resolve the issues. As a resolution to    PRA model prior to information is provided in      this IFPRA Peer Review finding, all       building the Fire PRA.
Sections 4 and 7 of the         normal operating flooding sources internal flooding PRA           documented in the Internal Flooding reports. The information        Analysis Notebook (PRA-BV2-AL-RO5a) identified by this SR was not   (Table 4-1. Water Sources) have provided in its entirety. For   updated system flow information Page 291 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact &Observation                 BVPS-2 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed Y/N I
example, system                 (including normal operating temperatures are not            temperatures) based on available captured in the                 information provided in the references documentation and some          noted in the table.
systems (primarily oil) pump HP and RPM are captured but not the flow rates.
IFSO-  IFSO-B3     Finding      Y        No clear documentation was      This F&O was entered into the BVPS        No impact to Fire PRA, B3-01                                    provided of related             Notification System as BV2 Notification   because this issue was assumptions for the             #600689091, Task 4, to track and          addressed in the base identification of flood         resolve the issues. As a resolution to    PRA model prior to sources. The sources of         this IFPRA Peer Review finding, section   building the Fire PRA.
model uncertainty are           12.4.5 of the Internal Flooding Analysis documented in Section 12        Notebook (PRA-BV2-AL-R05a) contains of the internal flooding PRA    a review of the impact of all assumptions reports, 2294706-R-001,         mapped to uncertainty along with Rev. 0 and 2294706-R-002,       sensitivity analysis that was evaluated.
Rev. 0, but itcould not be      Table 12-7 contains a cross reference of determined how these            all the assumptions in the development sources of model                of the BVPS-2 internal flooding uncertainty were connected      notebook related to the frequency to the various assumptions. uncertainties in Table 12-2.
Page 292 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation              BVPS-2 Final Resolution                   Impact to Fire PRA ID     Requirement Level        Closed YIN IFSN-  IFSN-Al     Finding      Y      The description of the          This F&O was entered into the BVPS        No impact to Fire PRA, Al-01                                  propagation paths is not        Notification System as BV2 Notification   because this issue was complete. Table E-1             #600689091, Task 14, to track and         addressed in the base identifies the "source"         resolve the issues. As a resolution to    PRA model prior to location and the next           this IFPRA Peer Review finding, Section   building the Fire PRA.
locations to which it water     7.3 of the Internal Flooding Analysis can propagate. To               Notebook (PRA-BV2-AL-RO5a) was determine the complete          augmented to clearly explain with an propagation path, these         example the differences in Table E-1 source/next pairs can be        and E-2 due to subsuming of flood combined until the water        propagation paths, and a separate reaches the accumulation        column was added to Table E-2 to point (no "next" location). indicate all of the flood propagation However, the scenario           pathways that were subsumed for each descriptions in Table E-2 do    documented flooding scenario so that it not consistently account for    will be clear that all pathways have been the propagation paths           accounted.
identified in Table E-1. For example, scenario PA3C FWLP-3 propagates to several locations per Table E-2 (PA-3C, PA-3, PA-31, PA-3H) but Table E-1 indicates that PA-3 can propagate to PA-S2, PA-S6, PA-3G, PA-3A, PA-3B, PA-3C, PA-3H, PA-31; several of these are not accounted for in the propagate path in Table E-2. If the missing locations are not possible due to plant features, that should be stated to Page 293 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance  Status Fact & Observation              BVPS-2 Final Resolution                   Impact to Fire PRA ID     Requirement Level         Closed IY/N                                                                            I complete the accounting.
Other examples of this deficiency were observed (PA4-FWLP-1, PT1-FWLP-1 from Unit 2, and PA1A-FWLP-1, FA1A-FWMP-1 from Unit 1). The propagation paths must account for the various possible flow paths.
Combination presented in the documentation that are not considered brings into question the completeness of the analysis.
IFSN-  IFSN-B2,    Finding       Y      The process to identify         This F&O was entered into the BVPS        No impact to Fire PRA, B2-01  IFSN-A5,                         scenarios lacks several of      Notification System as BV2 Notification   because this issue was Page 294 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation              BVPS-2 Final Resolution                  Impact to Fire PRA ID     Requirement Level        Closed IFSN-A6                         the suggested areas that        #600689091, Task 15, to track and        addressed in the base should be included              resolve the issues. As a resolution to   PRA model prior to (recognizing that the SR list   this IFPRA Peer Review finding, a        building the Fire PRA.
is NOT a required set). The     graphical depiction of the overall flood propagation pathways            scenario development was provided as description is not complete     Figure 7-1 in Section 7 of the Internal in that it does not include all Flooding Analysis Notebook (PRA-BV2-potential propagation paths     AL-R05a).
identified in Table E-1 of the PRA reports. The impacted (failed) SSCs for each scenario are not clearly referenced (identified as needing to be "addressed" in a REMARKS column in Table E-2). Assumptions used in the scenario discussions are incomplete.
Scenario screening is not clearly documented. The documentation has many weaknesses in capturing the suggested types of information to adequately document this topic.
Page 295 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status Fact & Observation               BVPS-2 Final Resolution                    Impact to Fire PRA ID     Requirement Level        Closed W/N IFSN-  IFSN-B3,    Finding      Y      The use of the Excel VBA         This F&O was entered into the BVPS         No impact to Fire PRA, B3-01  IFSN-A4                         code to predict flow rates       Notification System as BV2 Notification    because this issue was and failures of equipment        #600689091, Task 8, to track and           addressed in the base has provided a great deal of     resolve the issues. As a resolution to     PRA model prior to realistic insight to plant flood this IFPRA Peer Review finding, Section    building the Fire PRA.
response. Section 9.0 of the     9.5 (Summary of Assumptions) of the internal flooding PRA            Internal Flooding Analysis Notebook reports does not explicitly      (PRA-BV2-AL-R05a) was expanded to discuss all assumptions          include Microsoft EXCEL VBA program regarding the use of             specific assumptions and documentation equations to predict flood       pointers to flooding scenario specific heights, and the scenarios       assumptions.
modeled in Appendix H of the PRA reports have some assumptions applied to each analysis.
IFEV-  IFEV-A7     Suggestion   Y      Maintenance and human-           This F&O was entered into the BVPS         No impact to Fire PRA, A7-01                                  induced errors causing a         Notification System as BV2 Notification    because this issue was flooding event can be            #600689091, Task 9, to track and           addressed in the base important to the overall plant   resolve the issues. As a resolution to     PRA model prior to risk. A more detailed            this IFPRA Peer Review suggestion, an      building the Fire PRA.
analysis of those activities     Operating Manual (OM) procedure within the plant that could      review of at-power open maintenance lead to a system breach          was produced as Table 7-4 in the potential should be              Internal Flooding Analysis Notebook analyzed. Maintenance            (PRA-BV2-AL-RO5a) that evaluates activities which could           systems 15, 26, 28, 29, 30, 31, and 33 potentially breach               for potential actions on equipment that pressurized systems could        could cause human-induced flooding lead to internal flooding        scenarios. Some of the systems (i.e.,
events. By not evaluating all    26 and 29) are indirectly reviewed based potential online                on other systems. The OM procedures maintenance activities for      for the condenser waterbox, CCR heat     I Page 296 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation                BVPS-2 Final Resolution                    Impact to Fire PRA ID     Requirement Level        Closed YIN the potential breaches, the       exchangers, and CCT heat exchangers flood-induced risk                are based on a frequency that is based associated with these             on SAP work order record queries. The activities could be               screening categories for the open underestimated.                   maintenance and human-induced review are shown in Table 7-5.
IFEV-  IFEV-B2     Suggestion   Y      Documentation of the              This F&O was entered into the BVPS         No impact to Fire PRA, B2-01                                  process that identifies           Notification System as BV2 Notification    because this issue was applicable flood-induced          #600689091, Task 18, to track and          addressed in the base initiating events is required     resolve the issues. As a resolution to     PRA model prior to to satisfy this SR. The flood     this IFPRA Peer Review suggestion,         building the Fire PRA.
scenario frequencies are          and as part of an expanded analysis to provided in Tables 8-10, F-       address probabilistic pipe failure during 1, and J-1 of the internal        the 24-hour mission time after an flooding analysis reports         initiator and for system-based initiators, (2294706-R-001, Rev. 0            Section 8.1.3 and Tables 8-11 and 8-12 and 2294706-R-002, Rev.           of the Internal Flooding Analysis 0). The associated HEPs for Notebook (PRA-BV2-AL-R05a) illustrate isolating the flood and           the scope of flooding elements (pipe, adjustment factors used to        expansion joints) contained within the refine the flood frequencies      existing internal events model.
are also provided in Table F-1. A qualitative screening value of 1.OE-12 was used.
The process does not clearly identify the relationship of the information provided in the various tables.                 I Page 297 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O     Supporting. Significance Status Fact & Observation                BVPS-2 Final Resolution                    Impact to Fire PRA ID      Requirement Level        Closed Y/N IFEV-   IFEV-B3     Finding      Y      The different values that go      This F&O was entered into the BVPS         No impact to Fire PRA, B3-01                                   into the calculation of the       Notification System as BV2 Notification    because this issue was internal flooding initiating      #600689091, Task 10, to track and          addressed in the base event frequency are subject       resolve the issues. As a resolution to     PRA model prior to to uncertainties. These           this IFPRA Peer Review finding, Section    building the Fire PRA.
uncertainties need to be          12.4.5 of the Internal Flooding Analysis well documented to address        Notebook (PRA-BV2-AL-RO5a) contains all of the model impacts.         a summary of the review of the impact of all assumptions mapped to uncertainty The current flooding              along with sensitivity analysis that was frequency    calculations factors to determine    theuse    evaluated.
reference ofTable   12-7 all the    contains aincross assumptions      the actual initiating event           development of the BVPS-2 internal frequency used within the         flooding notebook related to the model. The pipe lengths,          frequency uncertainties in Table 12-2.
location factors, directional factors, and operator action failures all have some levels of assumptions and uncertainties associated with them. These need to be addressed in order to meet the SR.                         I IFQU-   IFQU-A5    Finding      Y      It appears that no inter-HEP      This F&O was entered into the BVPS         No impact to Fire PRA, A5-01                                   dependency analysis               Notification System as BV2 Notification    because this issue was (between flood and non-           #600689091, Task 16, to track and          addressed in the base flood HEPs) was performed. resolve the issues. As a resolution to            PRA model prior to Dependency between HEPs this IFPRA Peer Review finding, Section              building the Fire PRA.
can significantly increase         10.4.6 (Dependencies between Human the probabilities of               Interactions) of the Internal Flooding combinations of HEPs.             Analysis Notebook (PRA-BV2-AL-R05a)
However, Section 10.4 of          was revised to state that an HRA the internal flooding PRA         dependency analysis was performed Page 298 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O   Supporting. Significance Status   Fact & Observation              BVPS-2 Final Resolution                      Impact to Fire PRA ID    Requirement Level        Closed Y/N    I reports states                  (documented in Reference 13.4) and "Dependencies between the       that a discussion on the "HFE flood mitigation human          Dependencies in Internal Flooding PRA actions and the non-flood       Accident Sequences" is provided in the human actions modeled in        Human Reliability Analysis PRA the remaining part of the       Notebook, Section 2.3.
PRA model were judged to be minimal due to the significant difference in the   Section 10.4.6 was also expanded to nature of the actions (e.g.,    reiterate Section 10.4.3 (Screening and flood mitigation actions        Detailed Analysis) discussion on the require field investigation by  multiplier factor applied to HEPs the auxiliary operators, etc.)  included in the Internal Events PRA and separation in time, etc.,   based on such factors as the location of and as such no additional       the action, the timing of the action, and dependency treatment was        stress, etc., and to include a discussion considered needed." An          of the Riskman modeling analysis evaluation of the HEP           approach which human actions included combinations should be          are evaluated conditionally based on the documented to demonstrate       success or failure status of the this conclusion,                preceding human action(s). As such, dependencies among the human failure events in the Internal Events model (i.e.,
non-flood human actions) were fully accounted.
IFQU-  IFQU-A7    Finding      Y         Performance of the internal    This F&O was entered into the BVPS           No impact to Fire PRA, A7-01                                   flood events quantification      Notification System as BV2 Notification     because this issue was should be consistent with       #600689091, Task 12, to track and            addressed in the base the quantification of the        resolve the issues. As a resolution to      PRA model prior to internal events PRA. The       this IFPRA Peer Review finding,              building the Fire PRA.
quantification of the internal  analysis and discussion has been flooding requires that           provided for performance of I applicable requirements         quantification with the applicable         I Page 299 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance Status Fact & Observation              BVPS-2 Final Resolution                     Impact to Fire PRA ID     Requirement Level        Closed Y/N from the Internal Events        requirements. QU-B3 requirements Quantification section be       have been documented in Section met. The current section on     12.4.4 of the Internal Flooding Analysis Internal Flooding does not      Notebook (PRA-BV2-AL-R05a),
include a discussion of the     Truncation Evaluation. The QU-B7 topics addressed in Section     requirements have been documented in 2-2.7 of the ASME/ANS           Section 12.5.3, Mutually Exclusive Combined PRA Standard.          Events. QU-Cl & QU-C2 requirements have been documented in Section 12.5.4, HFE Dependency (see References 13.4 and 13.5). QU-D1 &
QU-D2 requirements have been documented in Section 12.5.5 Significant CDF Sequences and Accident Category (for CDF) and Section 12.5.8 Significant LERF Sequences and Accident Category (for LERF). QU-D4 requirements have been documented in Section 12.5.2 Internal Flooding Comparison Between Plants and Table 12-5. QU-D6 requirements have been documented in Sections 12.5.5 - 12.5.7, and 12.3 for significant contributions to CDF. QU-D7 requirements have been documented in Section 12.5.6 for system importance that is based on importance for I components and basic events.              I Page 300 of 301

Table 2-4. Summary of BVPS-2 Internal Flooding Focused Peer Review - Facts and Observations Resolutions F&O    Supporting. Significance   Status   Fact & Observation              BVPS-2 Final Resolution                  Impact to Fire PRA ID     Requirement Level          Closed IFQU-  IFQU-A10    Suggestion I YIN Y        Internal flooding contribution  This F&O was entered into the BVPS INo impact to Fire PRA, Al0-                                       to LERF should be               Notification System as BV2 Notification  because this issue was 01                                         documented in some way          #600689091, Task 11, to track and        addressed in the base so that the apparent impacts    resolve the issues. As a resolution to   PRA model prior to on LERF from the flooding       this IFPRA Peer Review suggestion,       building the Fire PRA.
events could be reviewed.       Section 12.5.8 of the Internal Flooding The discussion concerning       Analysis Notebook (PRA-BV2-AL-R05a) the impacts on LERF for         contains a review of internal flooding internal flooding events        LERF sequences and accident could be improved to            categories which describes impacts that discuss flooding impact on      are evaluated in internal flooding LERF the different features used     analysis.
to mitigate releases.
IFQU-  IFQU-B2,    Finding        Y        The process used for            This F&O was entered into the BVPS       No impact to Fire PRA, B2-01  IFQU-B1                             quantification documents        Notification System as BV2 Notification  because this issue was the calculation, screening,     #600689091, Task 13, to track and        addressed in the base scenarios deleted and           resolve the issues. As a resolution to   PRA model prior to walkdowns. However, there       this IFPRA Peer Review finding, the      building the Fire PRA.
is not enough                   supporting requirements listed in HLR-documentation of the            QU-D have been completed in the quantification process          Internal Flooding Analysis Notebook specifically concerning the     (PRA-BV2-AL-RO5a) Section 12.5 PRA Standard requirements       Results and Insights.
listed in HLR-QU-D. The SR requires that documentation must be consistent with the requirements described in HLR-QU-D. These requirements are not discussed at any point in the internal flooding PRA I reports.
Page 301 of 301}}