L-2022-148, Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication

Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication

ML22252A032
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point
Issue date:	09/16/2022
From:	Strand D Florida Power & Light Co
To:	Thomas Hipschman Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2022-148
Download: ML22252A032 (1)

Text

L-2022-148 Mr. Thomas Hipschman, Chief Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments on NRC Inspection Procedure (IP) 71111.21 N.03, "Commercial Grade Dedication" Florida Power & Light Company on behalf of itself and of its affiliates, NextEra Energy Seabrook, LLC, and NextEra Energy Point Beach, LLC (collectively, "NextEra") appreciates the opportunity to comment on NRC Inspection Procedure (IP) 71111, Attachment 21 N.03.

NextEra endorses the comments provided by the Electric Power Research Institute (EPRI)

(ML22234A204, ML22234A207 and ML22234A208) and the Nuclear Utility Group on Equipment Qualification (NUGEQ) (ML22249A229), on behalf of the industry related to this NRC IP 71111 .21 N.03, "Commercial Grade Dedication ."

NextEra has similar concerns as summarized below:

• The scope as written is well beyond the focused subject of CGD

• References identified are old and IP does not consider documents that were published as part of the efforts to clarify CGD requirements and methodology (e.g., RG 1.164 and EPRI 3002002982)

• Focus on Design Control (10 CFR 50 Appendix B Criterion Ill) is outside of CGD process

- CGD is an acceptance activity providing reasonable assurance and the suitability of design is already established prior to pursuit of CGD

• With a Corporate/Fleet Centralized CGD Program, separate inspection for each Region (I - SEA, II - PSL/PTN, and Ill - PB) will result in redundant inspection burden for the Integrated Supply Chain (ISC) resources required for each inspection We look forward to continued engagement on this matter.

Sincerely yours, 17,"-(_ r Dianne Strand General Manager, Regulatory Affairs Florida Power & Light Company Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408