ML16036A307

Regulatory Audit Plan in Support of the License Amendment Requests to Implement Risk-Informed Technical Specifications Initiative 4b

ML16036A307
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	02/18/2016
From:	Perry Buckberg Plant Licensing Branch II
To:	Nazar M Nextera Energy
Buckberg P, NRR/DORL/LPL2-2
References
CAC MF5372, CAC MF5373, CAC MF5455, CAC MF5456
Download: ML16036A307 (9)

Text

. UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2016 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

FLORIDA POWER & LIGHT COMPANY - ST. LUCIE PLANT, UNIT NOS. 1 AND 2, AND TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4, REGULATORY AUDIT PLAN IN SUPPORT OF THE LICENSE AMENDMENT REQUESTS TO IMPLEMENT RISK-INFORMED TECHNICAL SPECIFICATIONS INITIATIVE 4b (ST. LUCIE CAC NOS. MF5372 AND MF5373; TURKEY POINT CAC NOS. MF5455 AND MF5456)

Dear Mr. Nazar,

This letter documents the U.S. Nuclear Regulatory Com.mission (NRC) staff's plan to conduct regulatory audits of the Florida Power & Light Company - St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie), and Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), license amendment requests (LARs) to implement changes to their technical specifications (TSs) program. that establish a risk-informed approach for voluntary extension of completion times for Limiting Conditions for Operation based on the Nuclear Energy Institute (NEI) 06-09 methodology, "Risk-Informed Technical Specification Initiative 4b Risk-Managed Technical Specifications (RMTS) Guidelines." The proposed amendments would modify TS requirements to permit the use of risk-informed completion times in accordance with Technical Specification Task Force (TSTF) Traveler-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 4b." The availability of this TS improvement was described in the Federal Register on March 15, 2012 (77 FR 15399).

This letter provides the enclosed regulatory audit plan based on the St. Lucie LAR submitted December 5, 2014, and the Turkey Point LAR submitted December 23, 2014. The subject audits will take place the week of February 22, 2016, at the NextEra Energy Offices, 700 Universe Boulevard, Juno Beach, Florida.

The NRC Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing staf; Division of Risk Assessment staff, including the branch chief from the Probabilistic Risk Assessment Licensing Branch; Division of Safety Systems staff from the Technical Specifications Branch; and the Division of Engineering staff from the Instrumentation and Controls Branch; along with NRC contractors from the Pacific Northwest National Laboratory, plan to be in attendance at the audit. NRC regional staff may also be present as observers.

M. Nazar If you have any questions, please contact me at (301) 415-1383 or Perry.Buckberg@nrc.gov.

P r . Buckberg, Senior Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-3~5, 50-389, 50-250, and 50-251

Enclosure:

Regulatory Audit Plan cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEARREGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT. UNIT NOS. 1 AND 2 TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED TECHNICAL SPECIFICATIONS INITIATIVE 4b DOCKET NOS. 50-335, 50-389, 50-250. AND 50-251

1.0 BACKGROUND

Florida Power and Light Company (FPL) - St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie), and Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), have submitted license amendment requests (LARs) (References 1 and 2) to modify technical specification (TS) ,

requirements to permit the use of risk-informed (RI) completion times (RICTs) in accordance with Technical Specification Task Force (TSTF) Traveler-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 4b." The availability of this TS improvement was described in the Federal Register on March 15, 2012 (77 FR 15399).

The U.S. Nuclear Regulatory Commission (NRC) staff's review of the LARs has commenced in accordance with the Office of Nuclear Reactor Regulation's (NRR) Office Instruction LIC-101, "License Amendment Review Procedures." The NRC staff has determined that a regulatory audit of the St. Lucie and Turkey Point LARs should be conducted in accordance with the NRR Office Instruction LIC-111, "Regulatory Audits," for the staff to gain a better understanding of the licensee's proposed RICT program.*

A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily nondocketed information. *A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit of the licensee's information is expected to assist the staff in efficiently conducting its review or gain insights on the licensee's processes or procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR), Section 50. 71, "Maintenance of records, making of reports," and/or *10 CFR 54.37, "Additional records and record-keeping requirements," which, although not required to be submitted as part of the licensing action, would help the staff better understand the licensee's submitted information.

Enclosure

The objectives of this regulatory audit are to:

• Gain a ~etter understanding of the detailed calculations, analyses, and bases underlying the RITSTF Initiative 4b LARs and confirm the staff's understanding of the LARs;

-* Review the approach for developing and implementing nuclear power station risk-managed TSs programs;

• Identify further information that is necessary for the licensee to submit in order for staff to reach a licensing or regulatory decision;

• Discuss requests for additional information (RAls); and

• Determine the extent that the licensee's proposed amendments to modify TS requirements for RICTs are in accordance with TSTF-505.

2.0 REGULATORY AUDIT BASIS The basis of this audit is the licensee's LARs (References 1 and 2) and the Standard Review Plan (SRP), Section 19.2, "Review of Risk Information Used to Support Permanent .

Plant-Specific Changes to the Licensing Basis: General Guidance" (Reference 3).

References 4 through 6 provide additional information that will be used to support the audit.

3.0 REGULATORY AUDIT SCOPE OR METHOD The staff will review the licensee's RICT program and its application to the TSs completion times as proposed in the LARs. The NRC staff will include in the scope of the audit a review of the findings and observations for the internal events and fire probabilistic risk assessment (PRA) models; the RICT program implementation, including both technical and programmatic aspects, and discussion of inspection-related aspects.

• The NRC audit team will review the RI approach for establishing the extended completion times and confirming the consistency with the philosophy of NRC Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis." ,

The team will review the PRA methods used to determine the risk impact from which the revised completion times are obtained, including the PRA technical adequacy that is .addressed through NRC RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk.

Assessment Results for Risk-Informed Activities." The quantification of risk due to internal fire and other significant external events is also necessary for this application, through PRA or bounding methods.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC audit team will require access to licensee personnel knowledgeable on all technical aspects of the St. Lucie and Tukey Point RITSTF Initiative 4b LARs. At a minimum, a hard copy

and electronic copy of the following documentation should be available to the audit team on the first day of the audit. In addition, presentations and specific discussion topics will be requested 1 week prior to the audit.

Documents

• Analyses supporting PRA success criteria that differ from design-basis criteria

• Internal events and fire PRA documentation logic models should be available on computer with licensee support

• Internal events and fire events PRA peer review reports

• Risk management action procedure

• LARs

• Plant and PRA configuration control procedures Presentations

• PRA functional definition, development, and use presentation

• RICT program presentation

• Configuration Risk Management Program (CRMP) demonstration (including presentation of user interface for evaluations)

• Walkthrough sample RICT calculations Discussions

• Discuss how external events are considered for the RICT

• Discuss how risk management actions are determined and implemented

• Discuss reviews and acceptance testing of the CRMP model *

• Discuss how the CRMP is maintained, consistent with the baseline PRA model

• Discuss how cumulative risk will be evaluated and tracked 41 Discuss LARs and RICT program

• Discuss inspection-related aspects of RITSTF Initiative 4b 5.0 TEAM ASSIGNMENTS The audit will be conducted by NRC staff from NRR, Division of Risk Assessment, Probabilistic Risk Assessment Licensing Branch (APLA); Division of Engineering, Instrumentation and Controls Branch; and Division of Safety Systems, Technical Specifications Branch (STSB).

NRC contractors from the Pacific Northwest National Laboratory (PNNL) will support the technical audit team members. Staff knowledgeable in PRA and TSs will comprise the audit team, with support from an inspector from the region or headquarters. Observers at the audit may include NRR project managers and various regional inspectors.

The NRC audit team leader will be Leslie Fields. The NRC technical lead will be Jonathan Evans (APLA). The audit team leader will conduct daily briefings on the status of the review and coordinate audit activities while on site. The tables below show (1) audit milestones and schedule, and (2) planned audit team composition and the assigned areas for review during the audit.

Audit Milestones and Schedule Activitv Timeframe Comments Teleconference from NRC headquarters to provide RAI Clarification Call 02/15/16 or later clarification of draft RAls.

NRC will present a brief team introduction and discuss the scope of the audit. The licensee should introduce team 02/22/16 (St. Lucie)

Onsite Audit Kick-Off Meeting members and give logistics for the week. In addition, the 02/24/16 (Turkey Point) licensee should be prepared to give a virtual tour (if needed) of the protected area in the plant.

End of Day Summary 02/22/2016 - Meet with licensee to provide a summary of any significant Briefings 02/25/2016 findings and requests for additional assistance.

Provide Rooms for Focused 02/22/2016 - Facilitate discussions between site and staff technical Topic Discussions 02/25/2016 areas.

02/23/16 (St. Lucie) NRC staff will hold a brief exit meeting, with licensee staff to Onsite Audit Exit Meeting 02/25/16 (Turkey Point) conclude audit activities.

Audit Summary (see 8.0) 90 days after exit To document the audit.

Requlatorv Audit Team and Assiqnments SRP 19.2 Audit Plan Review Areas Lead Support Section 111.2 Engineering evaluations, previous approval Team Team 111.2.1 Defense-in-depth and safety margins J. Evans, S. Dinsmore PNNL 111.2.2 Risk Assessment J. Evans, S. Dinsmore PNNL 111.2.2.1 External Hazards Risk Contribution J. Evans, S. Dinsmore PNNL 111.2.2.4.1 PRA Technical Adequacy J. Evans, S. Dinsmore PNNL 111.2.2.5.2 Uncertainty/Assumptions J. Evans, S. Dinsmore PNNL 111.2.2.5.4 Documentation, Configuration Control, Quality J. Evans, S. Dinsmore PNNL 111.2.2.5.4 Risk Management Actions J. Evans, S. Dinsmore PNNL 111.3 Monitoring Program J. Evans, S. Dinsmore PNNL 111.3 PRA Functionality J. Evans, S. Dinsmore PNNL 111.2.2.4.1 PRA Technical Adequacy J. Evans, S. Dinsmore PNNL 111.2.2.5.2 Uncertainty/Assumptions J. Evans, S. Dinsmore PNNL 111.2.2.5.4 Documentation, Configuration Control, Quality Team Team Plant-specific Technical Specifications M. Chernoff, N. Carte 6.0 LOGISTICS The St. Lucie portion of this regulatory audit is planned to start February 22, 2016, and will last approximately 2 days. The Turkey Point portion of this regulatory audit is planned to start February 24, 2016, and will last approximately 2 days. The dates in the milestone chart are subject to change, based on mutual agreement between the licensee and the NRC. An entrance meeting for the St. Lucie and Turkey Point audit portions will be held on the first day at 9:00 a.m., and an exit meeting will be held the final audit day at 12:00 noon or later, as shown in the milestones and schedule above, based on a mutually agreed upon time after delivery of this audit plan. The NRC audit team leader will provide daily progress briefings to licensee personnel on the first and second day of the audit.

The audit will take place at a location agreed upon by the licensee and NRC audit leader, where the necessary reference material and appropriate FPL technical reviewers will be available to support the review. Visitor access will be requested for the entire audit team. We recommend that security paperwork and processing be handled on the first day of the audit week.

7 .0 SPECIAL REQUESTS The regulatory audit team will require the following to support the regulatory audit:

• Two computers with internet access and printing capability in the NRC room, access to the site portal, and wired or wireless internet access.

• Two or three private conference rooms with conference calling capability should be made available. The main. NRC conference room should be set up for six to eight NRC staff and contractors. An additional conference room should be available to accommodate up to twenty people for PRA technical discussions. Another room should be arranged for up to ten people for TSs and instrumentation and control discussions.

• Access to licensee personnel knowledgeable in the PRA, TSs, and instrumentation and control. In addition, FPL staff who participated in preparing the LARs should be available.

8.0 DELIVERABLES Draft RAls will be sent to the licensee prior to the audit. Formal RAls will be sent separately to the licensee after the audit. A regulatory audit summary will be issued to the licensee within approximately 90 days after the completion of the audit. The summary will use the guidance of NRR Office Instruction LIC-111 for content. *

9.0 REFERENCES

1. Letter from Joseph Jenson, Site Vice President, St. Lucie Plant, Unit Nos. 1 and 2, Florida Power & Light Company, to U.S. Nuclear Regulatory Commission, "St. Lucie Plant Units 1 and 2, License Amendment Request to Revise Technical Specifications to Implement TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b'," dated December 5, 2014 (ADAMS Accession No. ML14353A016).

2. Letter from Michael Kiley, Site Vice President, Turkey Point Unit Nos. 3 and 4, Florida Power & Light Company, to U.S. Nuclear Regulatory Commission, "Turkey Point Units 3 and 4, License Amendment Request to Revise Technical Specifications to Implement TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,' " dated December 23, 2014 (ADAMS Accession No. ML15029A297).

3. U.S. Nuclear Regulatory Commission Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, NUREG-0800, Section 19.2, "Review of Risk

Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis:

General Guidance" (ADAMS Accession No. ML071700658).

4. Regulatory Guide 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities,"

March 2009 (ADAMS Accession No. ML090410014).

5. Nuclear Energy Institute (NEI) 06-09, "Risk-Informed Technical Specification Initiative 4b Risk-Managed Technical Specification Guidelines," Revision 0, November 2006 (ADAMS Accession No. ML063390639).

6. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation for Nuclear Energy Institute Topical Report 06-09, 'Risk-Informed Technical Specification Initiative 4b Risk-Managed Technical Specification Guidelines,'" Revision 0, May 2007 (ADAMS Accession No. ML071200238).

M. Nazar If you have any questions, please contact me at (301) 415-1383 or Perry.Buckberg@nrc.gov.

Sincerely,

/RA/

Perry H. Buckberg, Senior Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335, 50-389, 50-250, and'50-251

Enclosure:

Regulatory Audit Plan cc w/enclosure: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 R/F RidsNrrDssStsb Resource JEvans, NRR RidsNrrPMStlucie Resource RidsNrrDeEicb Resource LFields, NRR RidsNrrDorllpl2-2 Resource SDinsmore, NRR BHarvey, NRO RidsNrrLABClayton Resource MChernoff, NRR RidsRgn2MailCenter Resource RidsNrrDraApla Resource NCarte, NRR RidsACRS_MailCTR Resource ADAMS Accession No.: ML16036A307 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/PM DORL/LPL2-2/LA DORL/LPL2-2/BC DORL/LPL2-2/PM PBuckberg A Klett BClayton BBeasley PBuckberg NAME (LRonewicz for)

DATE 02/18/16 02/16/16 02/18116 02/18/16 02/18/16 OFFICAL RECORD COPY