L-2013-193, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) Acceptance Review Clarification Response

Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) Acceptance Review Clarification Response

ML13170A156
Person / Time
Site:	Saint Lucie
Issue date:	06/14/2013
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2013-193
Download: ML13170A156 (28)

Text

0FPLo June 14, 2013 L-2013-193 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) Acceptance Review Clarification Response

References:

1. FPL Letter L-2013-099 dated March 22, 2013, Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

2. Email from Siva Lingam, NRC, to Ken Frehafer, FPL, dated June 7, 2013, St. Lucie NFPA-805 LAR Acceptance Review Clarification Questions.

Per Reference I above, Florida Power & Light Company (FPL) requested an amendment to the Renewed Facility Operating License (RFOL) for St. Lucie Units 1 and 2 that will enable St.

Lucie to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205.

As part of the LIC- 109 acceptance review for Reference 1, the NRC forwarded questions to clarify aspects of the LAR submittal per Reference 2.

The purpose of this letter is to provide responses to the LIC-109 acceptance review questions.

The response is contained in the enclosure to this letter.

If you should have any questions regarding this submittal, please contact Eric Katzman, Licensing Manager, at 772-467-7734.

c)66 Florida Power & Light Company ý,dL 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2013-193 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on June iq ,2013.

Respectfully JD~epIi Jensen Site Vice President St. Lucie Plant JJ/KWF

Enclosure:

Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, LIC-109 Acceptance Review Clarification Response cc: Ms. Cynthia Becker, Florida Department of Health

L-2013-193 Enclosure Page 1 of 26 Enclosure Florida Power & Light Company St. Lucie Units 1 and 2 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition LIC-109 Acceptance Review Clarification Response

L-2013-193 Enclosure Page 2 of 26 Table of Contents Clarification Responses Attachments

1. Revised Table V-1

2. Revised Table V-2

3. Email from Lingam to Frehafer dated June 7, 2013, St. Lucie NFPA-805 LAR Acceptance Review Clarification Questions

L-2013-193 Enclosure Page 3 of 26 Clarification Reponses NRC Request 1:

Findings PP-C3-01, ES-D1-01, CS-A3-01 and HRA-A2-02 are identified in Table V-1 but no corresponding dispositions are provided in Table V-2. Provide an updated Table V-1 which accurately cross-references to the Findings in Table V-2 or explain the reason for these exclusions from Table V-2 and provide a revised Table V-2 that includes these findings.

FPL Response:

PP-C3-01 and PP-B7-01 were duplicate F&Os from the peer review. Added PP-C3-01 to the Table V-2 entry for PP-B7-01.

ES-D1-01 was omitted from Table V-2 due to confusion regarding the level of significance of the F&O. It has now been added to Table V-2.

CS-A3-01 has been added to Table V-2. Its omission was related to confusion between CS-A3-01 and CF-A3-01 F&Os which were duplicates in the peer review F&O database.

HRA-A2-02 was an incorrect reference for HRA-A2 supporting requirement. HRA-A2-01 is the only F&O provided in the peer review report for supporting requirement HRA-A2-02. HRA-A2-02 was deleted from Table V-I.

L-2013-193 Enclosure Page 4 of 26 Clarification Reponses NRC Request 2:

Table V-1 identifies 25 SRs as Not Met and 8 as meeting CC-I only. Examples include but are not limited to Findings ES-C2-01, HRA-A2-01, HRA-B3-01, HRA-B3-02, and HRA-A4-01. Furthermore, the following PRA HRA modeling findings are noted:

(a) Of the 12 HRA-related SRs from Part 4 of ASME/ANS RA-Sa-2009, four SRs were identified as Not Met, and three are only met at CC-I. Additionally, HRA-related findings are also written against other non-HRA SRs, e.g., FQ-C1 and ES-C2.

(b) Finding HRA-A2-01 noted that the fire-related manual actions were not included as basic events in the fire PRA model but rather "were incorporated into the model by altering the failure probability of a related equipment failure basic event" and concluded that "[the] documentation is not sufficient to support FPRA peer review and future use."

(c) The dispositions to SRs HRA-D2-01 and HRA-C1-01 note the use of "bounding" multipliers to account for dependencies between fire-related HFEs and the dispositions to SRs HRA-B3-02 and HRA-A4-01 note the use of "the screening approach for adjusting FPIE model HEPs."

Provide the results of a post-disposition self-assessment of the capability category of each of the 25 SRs identified by the peer review as Not Met or meeting CC-I only. For each SR determined to not be met or to not meet CC-Il or better, provide a justification for why this is acceptable for the NFPA 805 application (i.e., technically adequate to support the FREs and post-transition plant change evaluations). In the self-assessment, specifically address why the dispositions to the SRs identified in items (b) and (c) resolve the associated findings and why the HRA is adequate to support the NFPA 805 application. The response to this RAI should be provided in a revised Table V-2 or new Table V-3.

FPL Response:

(a) The current CC and basis for acceptability of CC-I is provided for HRA-A4, HRA-B3, HRA-C1 and HRA-D2 in the responses to questions 2(b) and 2(c) below.

Supporting Requirements HRA-A3 and HRA-B4 are considered to be met at CC-Il per the F&O disposition provided for F&Os HRA-A2-01 and ES-C2-01. The disposition of other HRA related F&Os associated with HRA and non-HRA Supporting Requirements are dispositioned with their associated F&Os in table V-2 (HRA-B2 - Met per peer review, see applicable F&O HRA-A2-01 disposition; HRA-

L-2013-193 Enclosure Page 5 of 26 Clarification Reponses El - Met per peer review, see applicable F&O HRA-A2-01 disposition; F&O FQ-A4

- Met per peer review, see applicable F&O HRA-B3-01 disposition).

(b) This Supporting Requirement is considered to be met based on actions taken to resolve this F&O, as outlined in Table V-2.

(c) Note that the peer review does not include an F&O HRA-D2-01, F&O HRA B3-01 is the only F&O listed against Supporting Requirement HRA-D2 in the peer review report. The potential confusion is partially due to a typo in the ASME/ANS standard which includes two HRA-D1 requirements with the second being incorrectly identified as HRA-D1 instead of HRA-D2.

Requirement HRA-D2 is considered to be met based on the disposition of F&O HRA-B3-03. The use of multipliers to address the potential for increased failure probability of the internal events model human failure events provides a bounding/conservative fire HEP. The HRA dependency evaluation was revised to incorporate the increased HEP values.

Supporting Requirement HRA-Cl is considered to be met at Capability Category I per the disposition of F&O HRA-Cl-01. Capability Category I is considered sufficient for this application based on the conservatism of the screening HEPs used.

Supporting Requirement HRA-B3 is considered to be met at Capability Category I based on the disposition of F&Os HRA-B-01, B3-02 and B3-03. Capability Category I is considered to be sufficient for this application based on the conservatism of the screening HEPs used.

Supporting Requirement HRA-A4 is considered to be met in conjunction with the completion of the commitment in Table S-2 (Item 11) for update of post-fire shutdown procedures and associated training.

Table V-1 has been revised to document the CC for each of the Not Met or CC-I Supporting requirements.

The results of the post-disposition self-assessment of the capability category of each of the 25 SRs identified by the peer review as Not Met or meeting CC-I only is documented in the revised tables V-1 and V-2 provided in Attachments 1 and 2 to this Enclosure.

L-2013-193 Enclosure Page 6 of 26 Attachment 1 Table V-1 PSL Fire PRA Capabiility Category and List of F&Os from Peer Review Report (Items in the Capability Category per Peer Review column in brackets "[. are associated with CC-I or Not Met Supporting Requirements - these items are addressed in conjunction with the referenced Finding F&Os)

Table V-I: Capability Categories for Supporting Requirements Covered by the PSL Fire PRA Peer Review SR Capability Capability Category Active F&Os Category per Peer Based on Resolution of Review F&O (Basis for acceptability of CC-I)

PP-Al Met PP-A1-01 (F), PP-C2-01( F)

PP-B1 Met PP-B2 CC-Il/Ill PP-B2-01 (S)

PP-B3 CC-i1/I11 PP-B2-01 (S)

PP-B4 Met PP-C3-01 (F)

PP-B5 [CC-I] CC-I PP-B5-01 (S), PP-C3-01 (F)

(CC-Il only applicable if active fire protection features are credited. No active fire protection features are credited for PSL)

PP-B6 Met PP-Al-01 (F), PP-C3-01 (F)

PP-B7 Met PP-B7-01 (F)

PP-Cl Met PP-Al-01 (F)

PP-C2 [Not Met] Met per F&O Disposition PP-C2-01 (F), PP-C2-02 (S)

PP-C3 [Not Met] Met per F&O Disposition PP-C3-01 (F), PP-B7-01 (F)

PP-C4 Met ES-Al Met ES-Al-01 (S)

ES-A2 Met ES-A2-01 (S), ES-DI-01 (F)

ES-A3 Met ES-D1-01 (F)

ES-A4 CC-III ES-A5 CC-III ES-A6 CC-III ES-B1 CC-Il ES-B2 CC-III ES-B3 N/A ES-B3-01 (S)

ES-B4 Met ES-D1-01 (F)

ES-B5 N/A ES-B5-01 (S)

ES-Cl [Not Met] Met per F&O Disposition ES-Cl-01 (F)

ES-C2 [Not Met] CC-lI per F&O ES-Cl-01 (F), ES-C2-01 (F)

Disposition ES-D1 [Not Met] Met per F&O Disposition ES-D1-01 (F)

CS-Al Met CS-A2 CC-Il CS-A3 [Not Met] Met per F&O Disposition CS-A3-01 (F)

CS-A4 [Not Met] Met per F&O Disposition CS-A3-01 (F)

Attachment 1

L-2013-193 Enclosure Page 7 of 26 Attachment 1 Table V-I: Capability Categories for Supporting Requirements Covered by the PSL Fire PRA Peer Review SR Capability Capability Category Active F&Os Category per Peer Based on Resolution of Review F&O (Basis for acceptability of CC-I)

CS-A5 Met CS-A6 [Not Met] Met per F&O Disposition CS-A6-01 (F)

CS-A7 N/A CS-A8 Met CS-A9 Met CS-A10 CC-III CS-Al1 [Not Met] Met per F&O Disposition CS-Al1-01 (F)

CS-B1 [Not Met] C-II/C-Ill per F&O CS-B1-01 (F)

Disposition CS-Cl (Not Met] Met per F&O Disposition CS-C1-01 (F)

CS-C2 [Not Met] Met per F&O Disposition CS-C2-01 (F)

CS-C3 [Not Met] Met per F&O Disposition CS-All-01 (F)

CS-C4 [Not Met] Met per F&O Disposition CS-Cl-01 (F), CS-BI-01 (F)

QLS-Al N/A Plant St. Lucie did not use qualitative screening.

QLS-A2 N/A Plant St. Lucie did not use qualitative screening.

QLS-A3 N/A Plant St. Lucie did not use qualitative screening.

QLS-A4 N/A Plant St. Lucie did not use qualitative screening.

QLS-B1 N/A Plant St. Lucie did not use qualitative screening.

QLS-B2 N/A Plant St. Lucie did not use qualitative screening.

QLS-B3 N/A Plant St. Lucie did not use qualitative screening.

PRM-A1 Met PRM-A2 Met PRM-A3 Met PRM-A4 Met PRM-B1 Met PRM-B2 Met PRM-B3 Met PRM-B4 N/A PRM-B5 CC-III PRM-B6 N/A PRM-B7 Met PRM-B8 N/A PRM-B9 Met PRM-Cl-01 (F), PRM-B9-01 (S)

PRM-BlO Met PRM-B1 1 [Not Met] Met per F&O Disposition HRA-A2-01 (F)

PRM-B12 Met PRM-B13 N/A PRM-B14 Met PRM-B15 N/A PRM-Cl [Not Met] Met per F&O Dispostion PRM-Cl-01 (F)

FSS-A1 Met FSS-A1-01 (F), FSS-Al-02 (S)

FSS-A2 Met FSS-A3 Met FSS-A4 Met FSS-A4-01 (F)

FSS-A5 CC-III FSS-A6 CC-I/Il FSS-A6-01 (F)

FSS-B1 Met Attachment 1

L-2013-193 Enclosure Page 8 of 26 Attachment 1 Table V-I: Canabilitv Cateaories for Suonortina Reauirements Covered by the PSL Fire PRA Peer Review SR Capability Capability Category Active F&Os Category per Peer Based on Resolution of Review F&O (Basis for acceptability of CC-I)

FSS-B2 CC-II FSS-Cl CC-Il FSS-H1-01 (F)

FSS-C2 [CC-I] CC-II/CC-Ill per F&O FSS-C2-01 (S)

Disposition FSS-C3 N/A FSS-C4 [CC-I] CC-Il per F&O Disposition FSS-C4-01 (S)

FSS-C5 CC-I/Il FSS-H2-01 (F)

FSS-C6 CC-I/Il FSS-C7 N/A FSS-C8 N/A FSS-C8-01 (S)

FSS-D1 Met FSS-D2 Met FSS-D3 CC-III FSS-D4 Met FSS-D5 CC-I/Il FSS-H1-01 (F)

FSS-D6 Met FSS-D7 [CC-I] CC-Il per F&O FSS-D7-01 (S)

Disposition FSS-D8 Met FSS-D9 [CC-I] CC-Il per F&O FSS-D9-01 (S)

Disposition FSS-D1O CC-Il/Ill FSS-D1 1 Met FSS-El Met FSS-E2 N/A FSS-E3 CC-III FSS-E4 [Not Met] Met per F&O Dispostion FSS-E4-01 (F)

FSS-F1 CC-I/Il FSS-F2 N/A FSS-F3 N/A FSS-G1 Met FSS-GI-01 (F)

FSS-G2 Met FSS-G3 Met FSS-G4 CC-III FSS-G5 N/A FSS-G6 CC-Il/Ill FSS-H1 [Not Met] Met per F&O Dispostion FSS-H1-01 (F)

FSS-H2 [Not Met] CC-I, Generic Damage FSS-H2-01 (F)

Thresholds used, CC-Il requires use of plant specific thresholds (not implemented), consistent with NUREG/CR-6850 Methodology FSS-H3 Met FSS-H4 Met FSS-H5 CC-Il Attachment 1

L-2013-193 Enclosure Page 9 of 26 Attachment 1 Table V-I: Caoabilitv Cateaories for SuDoortina Reauirements Covered bv the PSL Fire PRA Peer Review SR Capability Capability Category Active F&Os Category per Peer Based on Resolution of Review F&O (Basis for acceptability of CC-I)

FSS-H6 Met FSS-H7 Met FSS-H8 Met FSS-H8-01 (F)

FSS-H9 Met FSS-H1O Met IGN-Al Met IGN-A2 N/A IGN-A3 N/A IGN-A4 CC-III IGN-A4-01 (S)

IGN-A5 [Not Met] Met per F&O Dispostion IGN-A5-01 (F)

IGN-A6 Met IGN-A7 Met IGN-A8 CC-III IGN-A9 Met IGN-A10 CC-III IGN-B1 Met IGN-B2 Met IGN-B3 Met IGN-B4 [Not Met] Met per F&O Dispostion IGN-B4-01 (S)

IGN-B5 Met QNS-Al N/A Plant St. Lucie did not use quantitative screening QNS-B1 N/A Plant St. Lucie did not use quantitative screening QNS-B2 N/A Plant St. Lucie did not use quantitative screening QNS-Cl N/A Plant St. Lucie did not use quantitative screening QNS-D1 N/A Plant St. Lucie did not use quantitative screening QNS-D2 N/A Plant St. Lucie did not use quantitative screening CF-Al CC-Il/Ill CF-A2 Met CF-B1 [Not Met] Met per F&O Dispostion CF-Bl-01 (F)

HRA-A1 Met HRA-A2 [Not Met] Met per F&O Dispostion HRA-A2-01 (F)

HRA-A3 [CC-I] CC-I1 per F&O ES-C2-01 (F)

Disposition HRA-A4 [Not Met] CC-Iper F&O Disposition HRA-A4-01 (F)

- completion, allowing upgrade to CC-II, is associated with Table S-2 Item 11 commitment to update post-fire shutdown procedures and associated training.

HRA-B1 CC-III HRA-B2 Met HRA-A2-01 (F)

Attachment 1

L-2013-193 Enclosure Page 10 of 26 Attachment 1 Table V-I: Capability Categories for Supporting Requirements Covered by the PSL Fire PRA Peer Review SR Capability Capability Category Active F&Os Category per Peer Based on Resolution of Review F&O (Basis for acceptability of CC-I)

HRA-33 [Not Met] CC-I per F&O HRA-B3-01 (F), HRA-B3-02 (F), HRA-B3-03(F)

Disposition. CC-Isufficient based on use of conservative screening HEPs HRA-B4 [CC-I] CC-II per F&O ES-C2-01 (F)

Disposition.

HRA-C1 [CC-I] CC-I per F&O HRA-Cl-01 (F)

Disposition. CC-I sufficient based on use of conservative screening HEPs HRA-D1 CC-lI HRA-D2 [Not Met] Met per F&O Dispostion HRA-B3-03 (F)

HRA-E1 Met HRA-A2-01 (F)

SF-Al [Not Met] Met per F&O Dispostion SF-Al-01 (F)

SF-A2 [Not Met] Met per F&O Dispostion SF-Al-01 (F)

SF-A3 [Not Met] Met per F&O Dispostion SF-Al-01 (F)

SF-A4 [Not Met] Met per F&O Dispostion SF-Al-01 (F)

SF-A5 [Not Met] Met per F&O Dispostion SF-Al-01 (F)

SF-B1 [Not Met] Met per F&O Dispostion SF-A1-01 (F)

FQ-A1 Met FQ-A2 Met FQ-A3 Met FQ-A4 Met HRA-B3-01 (F)

FQ-B1 Met FQ-Cl Met FQ-Cl-01 (F), FQ-C1-02 (S), FQ-Cl-03 (S)

FQ-D1 Met FO-Ci-01 (F), FQ-Cl-02 (S), FQ-Cl-03 (S)

FQ-E1 [Not Met] Met per F&O Dispostion FQ-El-01 (F)

FQ-F1 [Not Met] Met per F&O Dispostion FQ-Fl-01 (F), FQ-Fl-02 (S)

FQ-F2 N/A UNC-Al [Not Met] Met per F&O Dispostion UNC-A1-01 (F), UNC-Al-02 (S), UNC-Al-03 (F)

UNC-A2 Met MU-Al Met MU-Al-01 (S)

MU-A2 Met MU-Al-01 (S)

MU-Bl Met MU-Al-01 (S)

MU-B2 Met MU-Al-01 (S)

MU-B3 Met MU-Al-01 (S)

MU-B4 Met MU-Al-01 (S)

MU-Cl Met MU-Al-01 (S)

MU-DI Met MU-Al-01 (S), MU-D1-01 (S)

MU-El Met MU-Al-01 (S)

MU-F1 Met MU-A1-01 (S)

Attachment 1

L-2013-193 Enclosure Page 11 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Requirement SRs No Significance Significance Possible Resolution Disposition CS 4kV power and 125VDC control A3 CS-A3, 01 Finding Fire PRA Plant Perform a comparison of the Reviewed component failure cables required to support the CS-A4 Response model and components identified on the MSO modes to ensure that components operation of the Containment other Fire PRA (multiple spurious operation) list for which operation is credited Spray Pump were not identified. support tasks are against the Fire PRA components include required power cables.

Fire PRA Plant Response model adversely affected. for which new cable selection was and other Fire PRA support tasks performed (i.e., components not are adversely affected. previously identified on the Appendix R safe shutdown equipment list).

Perform a comparison of the Verify that the cable selection for the components identified on the MSO common components supports all (multiple spurious operation) list credited operations.

against the Fire PRA components for which new cable selection was performed (i.e., components not previously identified on the Appendix R safe shutdown equipment list). Verify that the cable selection for the common components supports all credited operations.

CS Include all load cables and A6 01 Finding An analysis has not Assess all the load power cables Breakers with -CNTL and -PWR applicable control circuit cables as been completed and and the applicable portions of the have been added to the analysis required cables for credited needs to be associated control circuits in the Fire and to the fault tree. CNTL/PWR switchgear, since concurrent faults completed to assure PRA for their potential impact on the cable failures cause failure of the on the load cables and control this issue evaluated. Fire PRA. Concurrent damage to the bus.

circuit could prevent proper power cable(s) and control circuit tripping of the breaker and result in could affect the automatic over-loss of the switchgear. Also review current trip capability of the affected faults on CT cables for their breaker, which in turn could potential impact on breaker adversely affect the ability of the operability. These switchgear to remain energized.

recommendations apply to all This should be assessed for all credited switchgear. switchgear credited in the Fire PRA.

CS The documentation for new cable C2 01 Finding The documentation for Provide a consistent document that Documentation updates have selection and cable routing is cable selection did not shows Fire PRA components, been implemented to consolidate highly fragmented. In the include a reference to functions, cable associated, fire the cable selection and cable documents that were reviewed, plant source zone location with a reference to routing data and associated there are no references to the documents. plant source documents. methodologies.

plant source documents and document revisions to provide traceability.

Attachment 2

L-2013-193 Enclosure Page 12 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance CS There is no documented Cl 01 Finding The documentation Development a documented Documentation updates have methodology for cable location to did not exist. methodology for locating cable to been implemented to consolidate fire areas. fire areas. the cable selection and cable routing data and associated methodologies.

CS No evaluation was performed to B1 CS-C4 01 Finding The evaluation was Evaluate the new cables and A detailed review of the verify that the new components not completed at this components and verify that they are coordination analysis was and cables associated with the time. bounded by the current overcurrent performed including those power Fire PRA is bounded by the coordination analysis. supplies associated with Fire PRA existing overcurrent coordination components.

analysis.

CS There were cable location All CS-C3 01 Finding There is no Provide supporting justification and All exclusions of component/cable assumptions that were made and justification for the documentation for assumed cable fire impacts are based on documented in the scenarios task. assumed cable routing. developed component/cable fire PSL Fire PRA Scenario Report, routing, SR CS-All routing data. Eliminated Rev 1, Attachment A, has two and CS-C3 cannot be exclusions based on assumptions scenarios that made assumptions verified without the of routing.

(1_47 and 126) that cables justification and designated as Y3 were not in the documentation to fire area. The justification was a validate the statement that the cables were assumption on cable "Judged not to have cables in this routing for zone due to location of components that had component'. No other justification no cable selection or was provided to determine that the routing.

cable was not in the area. More justification is needed to document the assumption on cable routing.

FQ No identification of significant El FQ-El 01 Finding Perform the analysis of significant Added Importance measures from contributors was available. contributors in accordance with FQ- appended cutsets to Summary Appendix C of the Fire PRA El Report.

Summary report stated that this will come later.

PP Draft Report NISYS-1251-0001 B7 and C3 B7 and 01 Finding Document needs to be Provide evidence of walkdowns to Incorporated reference to report in was reviewed and provides a C3 finalized and confirm partitioning. PP/FIF report. Added Reference 9 validation of the FHA and incorporated into to the report.

documents the plant specific project documents to walkdowns performed for each fire provide the technical zone boundary. Finding written to basis.

finalize this report and incorporate by reference into the plant partitioning report.

Attachment 2

L-2013-193 Enclosure Page 13 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance PP Need list of excluded areas with C2 Al 01 Finding SR unable to be Include list in report; include for each Added Note 3 to Table 2-1 basis. Work must have been done reviewed. List is item the justification for exclusion regarding basis for exclusion of to decide what was excluded, but necessary to perform from further analysis. buildings which do not contain was not presented. Criteria is review and to ensure equipment or cables which impact clearly presented but use of the technical adequacy. the Fire PRA.

criteria is not. Necessary to support definition of Global Boundary and whether all appropriate compartments were included.

PP Evidence was presented to the Al 01 Finding Additional Analysis Document a basis for exclusion from Added Note 3 to Table 2-1 reviewer that raceways supporting required to ensure the analysis, or add compartments regarding basis for exclusion of PRA equipment exists in the "no PRA addresses fire to the fire PRA analysis and quantify buildings which do not contain man's land" area between unit 1 failures appropriately the fire failures. equipment or cables which impact and unit 2. This area is not in this area. the Fire PRA.

currently included as part of an analyzed compartment, however no analysis exists as to why it meets the criteria for exclusion presented in Section 2.1.1. of the report.

CF The basis for the conditional failure 11 01 Finding Documentation/refere Provide basis for the conditional Provided additional detail in probability used in the Altered nce supporting the failure probabilities used in the altered events table with Events table was not documented, credited conditional Altered Events table. reference to 6850 basis for value failure probabilities used.

provides the technical basis for applicability of these treatments.

ES No information was identified in the C2 ES-C2 01 Finding A review of control room Provided clarification in HRA Component and Cable Selection instrumentation should be performed report, Section 3.

Report (Report 0493060006.101, to identify, on a fire-zone basis, Revision 1) or the HRA Evaluation those instruments in which Report (Report 0493060006.102, unavailable or spurious indications Revision 0) that characterized could mislead the operator into instrument availability or spurious performing undesirable actions.

operability for individual fires.

ES Tables 4.2-1, 4.2-2 (to be C1 ES-Cl 01 Finding Expand the Component and Cable One set of SSD instrumentation completed for Unit 2), B-1 and B-2 Selection Report to address the will remains available to meet provide information on impact of a fire in each fire zone (or SSD systems for an area wide instrumentation associated with area) on instrumentation addressed fire. The correlation between SSD PRA basic events and SSEL in the HRA Evaluation Report. instrumentation and operator mapping and disposition. The HRA actions provided in the HRA Attachment 2

L-2013-193 Enclosure Page 14 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Requirement SRs No Significance Significance Possible Resolution Disposition ES Evaluation Report (Report Ci report confirms that for each HFE (cont'd) 0493060006.102, Revision 0), (cont'd) Appendix R instrumentation is Tables A A-4 and Appendix C available to support the cue for provide information on the the action. Guidance provided in instrumentation associated with SSD procedures will identify the important control room actions, instruments available post fire and Appendix R instrumentation is focus operator cues on these specifically identified by bold instruments. Since the formatting. However, no instrumentation availability is information was provided that defined on a fire area wide fire would allow the impact of a basis it will provide a conservative specific fire on the instrumentation basis for instrumentation available set to be identified. For essential for an individual scenario within instrumentation this information is the fire area. Incorporated available in the Response to Fire additional discussion in HRA procedures. The reduced set of report, Section 3.

instrumentation associated with a fire zone should be used to support estimation of the human failure probabilities associated with a fire scenario.

ES PI-03-003 provides instruction for D1 ES-A2, 01 Finding Improve component selection report, SSD and FPRA documentation circuit analysis to include review of ES-A3, address items identified in this F&O. revised to provide enhanced interlocks, instrumentation, and ES-B4, documentation of component support system dependencies. ES-D1 selection and cable selection.

Cable routing database was reviewed and confirmed that interlocks, instrumentation, and support system cables were included in equipment effects.

However, demonstration of a review of power supplies, etc. was not readily apparent in the Component Selection report.

The development of the Fire PRA equipment list inherently considers the entire component and its supporting equipment; however, it is important to document this information to support peer reviews and applications.

It is suggested that document the review to show the interlocks, Attachment 2

L-2013-193 Enclosure Page 15 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Requirement Related SRs Observation.

No Level of Significance Basis for Significance Possible Resolution Disposition ES power supplies, etc. are included D1 (cont'd) (or referenced) in the development (cont'd) of the Component Selection section.

The equipment selection report states that SSEL equipment required to place the plant in hot standby, the PRA end state, are included in the analysis while equipment only associated with taking the plant to cold shutdown were excluded from analysis. No information is provided to facilitate the assignment of individual SSEL instrumentation to specific plant states, which complicates review against this SR.

Expand Component and Cable Selection tables to allow SSEL components to be associated with specific plant states.

Components are linked to fault tree Basic Events, but suggest document all potential fire induced sequences are confirmed to be associated with a reactor trip initiating event in the fault tree.

Improve component selection report to address items identified in this F&O.

IGN Bayesian updates to generic fire A5 IGN-A5 01 Finding Revise updated frequencies to Attachment K provides the basis frequencies were performed on a include consideration of plant for reactor years used, reactor-year basis, consistent with availability. incorporating capacity factor via the Standard. The analysis does removal of outage durations.

not include consideration of plant availability as required.

IGN An analysis supporting the B4 IGN-B4 01 Suggestion Add a description of the process of Attachment K added to provide estimation of plant-specific reactor- estimating the number of plant- the basis for the reactor years years is not described (the number specific reactor years to the fire used.

of reactor-years is specified), frequency report.

Add a description of the process of estimating the number of plant-Attachment 2

L-2013-193 Enclosure Page 16 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance IGN specific reactor years to the fire B4 (cont'd) frequency report. (cont'd)

PRM Overall PRM documentation is C! PRM-B9 01 Finding Recommend a separate PRM report Added discussion in sparse and doesn't provide the that documents in a structured and Component/Cable report Section information addressed in the SRs consistent way the requirements 5.0.

associated with the HLRs described in the PRM SRs.

described in the Category 1,11and IIIcriteria of PRM-Cl. In addition, the development of changes made in Tables D1 and D3 are not described (PRM-B9).

FQ Fire-related SSD actions are C1 01 Finding Any fire-related SSD actions Incorporated multipliers applied to currently modeled only through the modeled in the final Fire PRA should cutsets with multiple screening AlteredEvents file in FRANC, be evaluated for potential HEPs. See Section 4.1 and which bypasses the dependency dependencies with other actions. Appendix B of HFE Report, analysis.

FQ Documentation of the CDF and F1 01 Finding FQ-F1 Document the CDF and LERF Additional documentation, LERF analysis to the extent analysis to the extent required in the including parametric uncertainty required in the FQ-F1 supporting FQ-F1 supporting requirement have been performed and requirement has not been should be completed as the analysis incorporated into the Fire PRA developed. CDF and LERF values proceeds. documentation.

are provided on a scenario bases, but these are not ranked. Basic event correlations have not been addressed nor have uncertainty analyses been performed.

SF Section 3.13 of the St. Lucie Fire Al SF-A2, 01 Finding The five SRs associated with HLR- The scope of seismic analyses PRA Summary report discusses SF-A3, SR-A specify five specific aspects to performed for the IPEEE is the seismic/Fire interaction issue, SF-A4, evaluate qualitatively to ensure that considered to be sufficient given 0493060006.105, Rev 1., SF-A5, the insights from the original IPEEE the low seismic event frequency concludes, with no supporting SF-B1 evaluations remain valid in light of and magnitudes expected at the evidence that there is no issue and knowledge gained from the new Fire PSL site.

pointed to a set of references as PRA. FP&L needs to upgrade the providing the requisite supporting write-up in Section 3.13 of the St.

information. A review of these Lucie Fire PRA Summary report to references indicated that they specifically discuss the items in each pertained to the seismic issues of the SRs.

associated with A-46 resolution and GL-88-20, They did not contain any discussion of seismic/fire issues such as the potential for unique fire initiators, Attachment 2

L-2013-193 Enclosure Page 17 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Requirement Related SRs Observation No Level of Significance Basis for Significance Possible Resolution Disposition SF the potential for spurious operation Al (cont'd) or failure of fire detection and (cont'd) suppression systems, the potential for common cause failure of multiple suppression systems or the impact on fire brigade response.

HRA Section 4.1 of H0493060006.102, A2 HRA-B2, 01 Finding The HRA report should be modified Additional discussion and process Rev. 0, briefly discusses reviewing HRA-E1, to provide additional information for applied for screening HEPs is fire failures to identify operator PRM- the fire-specific actions. As a added to HFE Report section 4.1.

recovery actions for these failures. B11 minimum, a table should be added It was indicated that these to list the AlteredEvent elements recovery actions were included added to cover a recovery action.

with a screening value of 0.01. No The table should define the operator additional information on these action and provide a summary recovery actions was provided in description of the action and the HRA report. A review of the associated equipment, identify the FRANC AlteredEvents File event being altered to account for indicated that these "recovery the action, the assigned probability actions were incorporated into the and the basis for the assigned model by altering the failure probability. For each recovery action probability of a related equipment retained, this basic information failure basic event to the screening should be supplemented with the value for the recovery action. The standard information needed to sole documentation was the define and quantify a human action comment field for the (e.g., timing, cues, etc.) For the AlteredEvent. The AlteredEvent file MSO-related operator actions, as a also had some additional events minimum, have a reference to the that were clearly identified as BE mapping table with an operator actions. Again, there was explanation of what the actions no related information in the HRA represent. Any that are retained, report. Discussions with St. Lucie must be fully documented.

personnel revealed that these were actions added to the model logic for several MSOs and set to 1.0. These events were listed in the BE mapping table in the Scenario Report, but were not discussed in the HRA report. The conclusion is that St. Lucie did identify these actions, but the documentation of these actions was severely limited to the point Attachment 2

L-2013-193 Enclosure Page 18 of 26 Attachment 2 Table V.2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance HRA that it was extremely difficult to A2 (cont'd) locate this information (cont'd)

HRA A number of fire-specific HFEs B3 01 Finding Additional discussion and process were identified. Some of these applied for screening HEPs is were incorporated into the model added to HFE Report section 4.1.

via the AlteredEvents table with the definition of the HFE limited to a brief statement in the comment field for the altered event. Other events were added to the model to support the MSO logic with the values set to 1.0. The intent is to determine which HFEs to retain and which HFEs to delete.

However, at this point they are in the model with limited documentation and no characterization. As such, the definition of these HFEs is not complete and provides no scenario specific information beyond the fire scenario ID in the AlteredEvents file.

FSS PSL reviewed their cable types H2 01 Finding No basis for target Recommend providing a description For PSL Unit 1 documentation is and modeled targets as non-IEEE- damage thresholds of how that determination was not needed to substantiate the 383 qualified with damage were provided as made, possibly including references use of thermoplastic cable thresholds of thermoplastic cable. required by the SR. to cable purchase orders, damage criteria. Had thermoset procurement documents, etc. and/or IEEE-383 cable damage No references or description of the criteria or flame spread cable review was provided. The characteristics been credited, Fire Scenario Report simply states additional documentation would that 'Most of the targets are cable be needed. For Unit 2 cables are trays containing non-IEEE-383 thermoset but the use of Kerite-qualified cables.' Recommend FR cables requires that the providing a description of how that thermoplastic damage criteria be determination was made, possibly used. Thermoset cable flame including references to cable spread criteria is applicable to U2.

purchase orders, procurement documents, etc.

Attachment 2

L-2013-193 Enclosure Page 19 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance FSS PSL did not postulate hydrogen Al 01 Finding PSL did not postulate Either postulate H2 and oil fires or Hydrogen for VCT tank isolated (H2) fires other than the turbine H2 fires and oil fires develop a stronger technical from other equipment generator H2 fires. PSL used the as specified by justification for their exclusion. components. AFW steam driven basis that their H2 piping contains NUREG/CR-6850, pump oil fire addressed in AFW C excess flow check valves. and minimal basis for pump fire. Located in outdoor However, this will not prevent H2 this deviation was area thus limiting impact of this fires. It's likely that plants provided. These fires fire.

experiencing H2 fires that can be risk significant contributed to the "potentially due to the potential for challenging" fire frequency also widespread damage in had excess flow check valves. the fire compartment, Recommend either postulating H2 fires or developing a stronger technical justification for their exclusion.

PSL did not appear consider all pump lube oil fire scenarios (e.g.,

AFW pumps, Charging Pumps, HPSI pumps, LPSI pumps, MFW pumps, etc.). These scenarios often involve significant quantities of oil causing widespread damage in the fire compartment. They can also contribute to multi-compartment fire risk.

Note that some lube oil scenarios appear to have been considered by PSL. Specifically, MFW and turbine lube oil fires were postulated. In speaking with the analysts, they indicated that other pumps tend not to have large quantities of lube oil and that source-target data for oil scenarios was often collected during walkdowns. However, there was little documentation of this, and very few oil scenarios were quantified in FRANC.

Attachment 2

L-2013-193 Enclosure Page 20 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Possible Resolution Disposition Requirement SRs No Significance Significance FSS 1 55E Scenario F09 (IMUX-4 A4 01 Finding Risk-significant targets Re-quantify scenario with affected Revised/Corrected.

Cabinet) was quantified with no (CCDP of 1.0) were targets failed.

targets (i.e., UNL-only). However, not modeled as during the peer review walkdowns, damaged when they a stack of five cable trays (C31, would indeed be C30, M30, M31, and L30). damaged.

However, these trays were not postulated to fail in the FRANC quantification. Failure of these trays represents a potential 1.0 CCDP (similar to adjacent heat trace panels) and CDF 1E-7.

FSS A 0.1 CCDP was modeled for main A6 01 Finding In certain scenarios, Review the scenarios in which Specific CCDPs are calculated for control room fires in which the current Fire PRA alternate shutdown is modeled. each C/R abandonment/non-operators rely on the alternate model may credit the Perform an assessment as to abandonment scenario.

shutdown panel (i.e, alternate shutdown whether the alternate shutdown Calculated CCDPs are increased abandonment). There could be panel when it is not panel can mitigate the fire-induced to account for potential impact of scenarios where the damage sufficient to mitigate failures and adjust the CCDP abandonment for the CR caused by the fire cannot be the scenario, appropriately, abandonment cases.

mitigated from the alternate shutdown panel. For example, if a particular scenario requires the HPSI pumps to function, and those pumps are not controllable from the alternate shutdown panel, then the 0.1 CCDP may not be appropriate.

FSS This Suggestion F&O is at PSL's C2 FSS-C2 01 Suggestion CC-I met. This is just Model time-dependent HRR profiles Incorporated time dependent request to provide an F&O for all a suggestion for how for risk-significant scenarios. HRR profiles and associated SRs meeting CC-I, including a to meet CC-Il. Calculate NSPs specific to the NSPs.

suggestion on how to achieve CC- timing associated with the HRR I1. profile and geometric configuration of each risk significant ignition Time-dependent Heat Release source.

Rate (HRR) profiles are required to be implemented to meet CC-Il.

This is most related to calculating non-suppression probabilities, and would require a fair amount of additional analysis (specific to each source) than the generic Attachment 2

L-2013-193 Enclosure Page 21 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Related Observation Level of Basis for Requirement SRs No Significance Significance Possible Resolution Disposition FSS NSPs currently modeled. CC-I C2 (cont'd) met. This is just a suggestion for (cont'd) how to meet CC-uI.

Model time-dependent HRR profiles for risk-significant scenarios. Calculate NSPs specific to the timing associated with the HRR profile and geometric configuration of each risk significant ignition source.

FSS This Suggestion F&O is at PSL's C4 FSS-C4 01 Suggestion CC-I met. This is just Develop severity factors specific to Incorporated scenario specific request to provide an F&O for all a suggestion for how each risk significant ignition source configuration and severity factors.

SRs meeting CC-I, including a to meet CC-II. based on the specific fire suggestion on how to achieve CC- characteristics and geometry of IH. each source.

PSL used generic, generally bounding severity factors. In order to achieve CC-lI, severity factors can be developed based on the specific geometry and fire characteristics of each scenario.

For each risk significant ignition source, this would require measuring data such as distance to the nearest target and applying fire modeling equations to calculate the fraction of fires that are non-damaging versus damaging. CC-I met. This is just a suggestion for how to meet CC-II.

Develop severity factors specific to each risk significant ignition source based on the specific fire characteristics and geometry of each source.

FSS This Suggestion F&O is at PSL's D7 FSS-D7 01 Suggestion CC-i met. This is just In order to meet CC-li, PSL should Confirmed no outlier behavior for request to provide an F&O for all a suggestion for how review plant-specific data to ensure suppression and detection system SRs meeting CC-I, including a to meet CC-Il. no outlier behavior from the generic availability.

suggestion on how to achieve CC- estimates.

Attachment 2

L-2013-193 Enclosure Page 22 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Element Discussion Supporting Requirement Related SRs Observation No Level of Significance Basis for Significance Possible Resolution Disposition FSS II. D7 (cont'd) (cont'd)

PSL developed and applied generic non-suppression probabilities by reviewing the EPRI Fire Events Database. Note F&O FSS-H1-01 to document a strong technical basis for this approach.

In order to meet CC-Il, PSL should review plant-specific data to ensure no outlier behavior from the generic estimates. CC-I met. This is just a suggestion for how to meet CC-Il.

In order to meet CC-Il, PSL should review plant-specific data to ensure no outlier behavior from the generic estimates.

FSS This Suggestion F&O is at PSL's D9 FSS-D9 01 Suggestion CC-I met. This is just In order to meet CC-Il, PSL should Qualitative analysis provided request to provide an F&O for all a suggestion for how evaluate fire risk associated with which documents that the thermal SRs meeting CC-I, including a to meet CC-lI. failures caused by smoke, and not damage criteria envelopes the suggestion on how to achieve CC- just temperature I thermal radiation. smoke and sensitive electronics II. damage criteria.

PSL did not postulate failures due to smoke damage. This is sufficient for CC-I. In order to meet CC-Il, PSL should evaluate fire risk associated with failures caused by smoke, and not just temperature / thermal radiation.

CC-I met. This is just a suggestion for how to meet CC-Il.

In order to meet CC-Il, PSL should evaluate fire risk associated with failures caused by smoke, and not just temperature/thermal radiation.

FSS PSL's multi-compartment G1 01 Finding Inappropriate Simply don't apply the 0.0074 HGL/MCA evaluation has been evaluation consisted of a two- application of the screening criteria at the first stage of revised to consider adjacent stage screening approach. During 0.0074 multiplier may the screening process. zones with fixed openings where the first stage, a 0.0074 barrier result in screening the 0.0074 criteria is not Attachment 2

L-2013-193 Enclosure Page 23 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Supporting Related Observation Level of Basis for Element Discussion Requirement SRs No Significance Significance Possible Resolution Disposition FSS failure probability (which G1 scenarios that are applicable.

(cont'd) corresponds to a solid wall) was Cont'd) potentially significant.

inappropriately applied. This resulted in several scenarios being inappropriately screened at the first stage.

FSS Documentation of PSLs multi- H8 01 Finding The methodology Document the methodology, inputs, Revised HGL/MCA analysis.

compartment analysis, as well as could not be outputs, and conclusions in a most of the FSS-related tasks, was understood without manner that can allow a Fire PRA Methods associated with panel light. These analyses seemed significant verbal engineer to understand the analysis factors and lower transient HRR technically adequate, however it explanation, without significant explanation, have been eliminated from the took a fair amount of verbal analysis.

explanation to understand.

Recommend improving documentation of this analysis.

FSS Attachment A of the Fire Scenario E4 01 No discussion of the Simply provide of uncertainties Y3 component exclusions are Report documents cases where uncertainties associated with assumed cable now based on cable routing only.

certain failures/BEs were excluded associated with this routing.

from the mapping based on an assumed routing was either assumed cable routing. provided, as required These cases were spot-checked by the SR.

and no problems were noted.

However, no discussion of the uncertainties associated with this assumed routing was provided, as required by the SR.

Note that failures/BEs appear only to have been excluded when there was a high confidence in the assumed cable routing. For example, there is a high confidence that main feedwater is not affected in containment.

FSS In several cases, PSL H1 01 Finding While these methods Simply provide stronger Beyond 6850 methods, panel implemented methods beyond seem appropriate, the documentation of the technical factor approach, has been those available in beyond industry level of documentation bases where methods beyond eliminated from the PSL Fire accepted guidance documents provided did not allow industry guidance were PRA.

(e.g., NUREG/CR-6850 and its detailed review by the implemented. For example, when The use of the 69 kW HRR for supplements). For example, PSL peer reviewers. In severity factors were developed transient fires has been limited to created their own multipliers / addition, methods based on a Fire Events Database those fire zones in which "zero severity factors for fires that cause beyond industry Review, documentation might transients" are allowed in order to damage beyond the ignition source accepted guidance include an explicit listing and written account for the potential violation Attachment 2

L-2013-193 Enclosure Page 24 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Supporting Related Observation Level of Basis for Element Discussion Requirement SRs No Significance Significance Possible Resolution Disposition FSS by reviewing the EPRI Fire Events H1 (e.g., NUREG/CR- disposition of each event. of the administrative controls.

(cont'd) Database. A second example is (cont'd) 6850 and its that PSL modeled transient fires supplements) should using the motor fire heat release have documented rate distribution, which is much technical bases of smaller than the transient fire similar quality and distribution. A third example is not magnitude to those applying the "Location Factor" to provided in account for wall/corner effects on NUREG/CR-6850.

flame height and plume temperature distribution.

While these methods seem appropriate, documentation of the technical bases for these methods was generally lacking. Methods beyond industry accepted guidance (e.g., NUREG/CR-6850 and its supplements) should have documented technical bases of similar quality and magnitude to those provided in NUREG/CR-6850.

Also, PSL should be aware that methods beyond industry accepted guidance documents may be viewed critically by the NRC.

HRA The definitions of the HFEs for B3 HRA-D2 03 Finding For existing internal events actions Use of HRA multipliers provides a existing actions used the existing included in the Fire PRA, provide a bounding assessment of the internal events definitions, which more complete definition to support impact of the fire on HEPs defined were defined in the EPRi HRA the quantification. Note, the detail of by the internal events model. HRA Calculator. Modifications were the definition can be scaled to the Calculator is used to define the made to account for general significance of the action (see HRA- new values for combination event categories of time available, Cl, Cat 2). recoveries given these revised accessibility, and complexity. This base HEP values.

appears to be adequate for Cat 1 where a task analysis is not needed. For Cat 2, a more detailed analysis of HFEs for specific fires' needs to be performed, along with a corresponding task analysis.

Attachment 2

L-2013-193 Enclosure Page 25 of 26 Attachment 2 Table V-2 FIRE PRA PEER REVIEW RESULTS

SUMMARY

Supporting Related Observation Level of Basis for Possible Resolution Disposition Element Discussion Requirement SRs No Significance Significance UNC The referenced SRs (e.g., QU-E3) Al 03 Finding Provide an estimate of the Uncertainty evaluation performed requires an estimation of the uncertainty of fire-initiated CDF (or and incorporated into the uncertainty distribution for fire- propagate CDF uncertainty), summary report.

induced CDF, which is not included in the Fire PRA.

UNC The uncertainty analysis Al 01 Finding See requirements of Add a LERF-specific section to the Added sensitivity and uncertainty documented in Appendix D of the UNC-Al, specifically uncertainty analysis and document analysis for LERF for both PSL Fire PRA Summary Report covers reference SRs LE-F2 the unique impacts of Fire PRA on units.

the major sources of uncertainty, and LE-F3 the LERF analysis and results.

except for those associated specifically with LERF.

HRA Screening HEP quantification was Cl 01 Finding To satisfy Cat 2 requirements, Use of HRA multipliers provides a used to adjust the existing internal perform detailed human reliability bounding assessment of the event PRA to account for fire analyses for the significant HFEs in impact of the fire on HEPs defined impacts. This included feasibility the context of specific fire scenarios, by the internal events model. HRA factors (cues availability, Calculator is used to define the accessibility of local action) and new values for combination event adjustment factors based on time recoveries given these revised available and complexity. This base HEP values.

approach is appropriate for the stage of the Fire PRA.

HRA For new fire-related actions, there 23 02 Finding Once the fire response procedures The use of the screening is no evidence of any definition of are finalized, the HFE definitions approach for adjusting FPIE the HFE beyond the title in the should be completed for operator model HEPs and the use of AlteredEvents table. actions modeled sufficient to support screening HEPs is sufficient to the quantification. Note, the detail of support this application.

the definition can be scaled to the significance of the action (see HRA-Cl, Cat 2).

HRA A review of modeled actions is A4 01 Finding Once fire response procedures are The use of the screening planned to be performed once finalized, perform talk-throughs with approach for adjusting FPIE draft procedures are generated plant operations and training model HEPs and the use of from the Fire PRA. However, at personnel, at least for risk-significant screening HEPs is sufficient to present no such review has been actions, to support the HRA for support this application. A review performed except for a limited these actions. against the draft post fire board walkthrough documented in procedure revision is identified as Appendix C of the Human Failure an implementation item in LAR Evaluation report. Table S-2, Item 11.

Attachment 2

L-2013-193 Enclosure Page 26 of 26 Attachment 3 Frehafer, Ken From: Ungam, Siva [SIva.Lingam@nrc.gov]

Sent: Friday, June 07, 2013 5:29 AM To: Frehafer, Ken Cc: Quichocho, Jessie; Poole, Justin; Rodriguez, Rafael; Klein, Alex; Poole, Justin

Subject:

St. Lucie NFPA-805 LAR Acceptance Review Clarification Questions Follow Up Flag: Follow up Flag Status: Flagged Below is the summary of the supplemental FPRA information needed to complete our acceptance review for St Lucie. Please provide the responses on the docket. Thank you.

(1) Findings PP-C3-01, ES-DI-01, CS-A3-01 and HRA-A2-02 are identified in Table V-1 but no corresponding dispositions are provided in Table V-2. Provide an updated Table V-i which accurately cross-references to the Findings in Table V-2 or explain the reason for these exclusions from Table V-2 and provide a revised Table V-2 that includes these findings.

(2) Table V-1 identifies 25 SRs as Not Met and 8 as meeting CC-I only. Examples include but are not limited to Findings ES-C2-01, HRA-A2-01, HRA-83-01, HRA-83-02, and HRA-A4-01. Furthermore, the following PRA HRA modeling findings are noted:

(a) Of the 12 HRA-related SRs from Part 4 of ASME/ANS RA-Sa-2009, four SRs were identified as Not Met, and three are only met at CC-I. Additionally, HRA-related findings are also written against other non-HRA SIRs, e.g., FQ-C1 and ES-C2.

(b) Finding HRA-A2-01 noted that the fire-related manual actions were not included as basic events in the fire PRA model but rather "were incorporated into the model by altering the failure probability of a related equipment failure basic event" and concluded that "[the] documentation is not sufficient to support FPRA peer review and future use."

(c) The dispositions to SRs HRA-D2-01 and HRA-CI-O1 note the use of "bounding" multipliers to account for dependencies between fire-related HFEs and the dispositions to SRs HRA-83-02 and HRA-A4-01 note the use of "the screening approach for adjusting FPIE model HEPs."

Provide the results of a post-disposition self-assessment of the capability category of each of the 25 SRs identified by the peer review as Not Met or meeting CC-I only. For each SR determined to not be met or to not meet CC-Il or better, provide a justification for why this is acceptable for the NFPA 805 application (i.e.,

technically adequate to support the FREs and post-transition plant change evaluations). In the self-assessment, specifically address why the dispositions to the SRs identified in items (b) and (c)resolve the associated findings and why the HRA is adequate to support the NFPA 805 application. The response to this RAI should be provided in a revised Table V-2 or new Table V-3.