ML19149A210
| ML19149A210 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/01/2019 |
| From: | Dennis Galvin Plant Licensing Branch II |
| To: | William Gideon Duke Energy Progress |
| Galvin D, NRR/DORL/LPL2-2, 415-6256 | |
| References | |
| EPID L-2018-LLA-0008 | |
| Download: ML19149A210 (8) | |
Text
July 1, 2019 Mr. William R. Gideon Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE (M/C BNP001)
Southport, NC 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - REGULATORY AUDIT
SUMMARY
REGARDING LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER PLANTS (EPID L-2018-LLA-0008)
Dear Mr. Gideon:
By letter dated January 10, 2018, as supplemented by letters dated November 2, 2018, February 13, 2019, and April 8, 2019, Duke Energy Progress, LLC (Duke Energy) submitted a license amendment request for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick). The proposed amendment would modify the licensing basis to allow for implementation of the provisions of Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power plants, of Title 10 of the Code of Federal Regulations.
To support its review, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit that consisted of a remote audit, an onsite audit at the Duke Energy Corporate office in Charlotte, North Carolina, from July 17-19, 2018, and an onsite audit at Brunswick from August 21-23, 2018. The staff reviewed documents, held discussions with members of Duke Energy on the license amendment request, and performed a walkdown of plant features relevant to the NRC staffs review of the license amendment request. The collective results of the regulatory audit were used by the NRC staff to finalize requests for additional information, which were issued on October 9, 2018.
An audit summary for the July 2018 onsite audit was issued on November 14, 2018. The audit summary for the remote audit and the August 2018 onsite audit is enclosed.
W. Gideon If you have any questions, please contact me at 301-415-6256 or Dennis.Galvin@nrc.gov.
Sincerely,
/RA/
Dennis Galvin, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
Regulatory Audit Summary cc: Listserv
OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT
SUMMARY
BRUNSWICK LICENSE AMENDMENT REQUESTS TO ADOPT 10 CFR 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER PLANTS DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324
1.0 BACKGROUND
By letter dated January 10, 2018 (Reference 1), as supplemented by letters dated November 2, 2018 (Reference 2), February 13, 2019 (Reference 3), and April 8, 2019 (Reference 4), Duke Energy Progress, LLC (Duke Energy, the licensee) submitted a license amendment request for the Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick). The proposed amendment would modify the licensing bases to allow for the implementation of the provisions of Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power plants, of Title 10 of the Code of Federal Regulations (10 CFR).
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensee's submittal and determined that a regulatory audit would assist in the timely completion of the licensing review process. The regulatory audit consisted of a remote audit, an onsite audit at the Duke Energy Corporate office in Charlotte, North Carolina, from July 17-19, 2018, and an onsite audit at Brunswick from August 21-23, 2018. The remote audit and the August 2018 onsite audit were focused on the high winds (HW) and external flooding (XF) probabilistic risk assessments (PRAs) while the July onsite audit focused on the overall categorization process. The NRC staff issued corresponding audit plans (References 5-8). An audit summary for the July onsite audit was issued on November 14, 2018 (Reference 9). This audit summary addresses for the remote audit and the August onsite audit.
The regulatory audit was performed consistent with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits (Reference 10).
2.0 AUDIT ACTIVITIES AND OBSERVATIONS 2.1 Remote Audit The remote audit was conducted in the NRC headquarters from the issuance of the audit plan on May 9, 2018 (Reference 5), until the issuance of the requests for additional information (RAIs) on October 9, 2018 (Reference 11). The purpose of the audit was to (1) gain a better understanding of the technical acceptability of the licensees HW and XF PRA models used to support the categorization process, (2) identify additional information necessary for the NRC Enclosure
staff to reach a licensing or regulatory decision, and (3) determine the need for an onsite audit at Brunswick, and if so, to facilitate the preparation of audit information needs for the onsite audit.
The NRC staff identified audit information needs for the remote audit in the May 9, 2018, audit plan (Reference 5). The NRC staff reviewed documents that were responsive to the information needs and were made available by the licensee in an electronic reading room. As a result of the remote audit, the NRC staff determined that an onsite audit at Brunswick, including a walkdown, would assist in the timely completion of the licensing review process. The onsite audit is discussed in Section 2.2 of this audit summary.
As discussed further below, the licensee identified an important change to the XF PRA during the onsite audit that was not included in the information from documents available to the NRC staff. The licensee made the information remotely available following the onsite audit. The NRC staff used the information from the remote audit to inform its RAIs, which were issued on October 9, 2018 (Reference 11). With the issuance of the RAIs, the remote audit was completed.
2.2 Onsite Audit The onsite audit was conducted at Brunswick from August 21-23, 2018, in accordance with the August 7, 2018, supplement to the audit plan (Reference 8). The supplement identified detailed audit information needs relevant to the use of the HW and XF PRAs in the categorization process in Attachment 1 and a walkdown items lists to support a site walkdown related to the review of the technical acceptability of the HW and XF PRAs in Attachment 2.
The NRC staffs observations from the onsite audit, including the site walkdown, were included in the RAIs on the HW and XF PRAs that were transmitted on October 9, 2018 (Reference 11).
Onsite Walkdown As part of the August 2018 onsite audit (Reference 10), the NRC staff conducted an onsite walkdown consistent with the walkdown item lists. For certain items on the lists involving higher radiation areas, contaminated areas, or other areas more difficult to access, the NRC staff and the licensee identified alternate means of obtaining walkdown information, such as through photographs and discussions with the licensees staff.
The walkdown was related to the NRC staffs review of the technical acceptability of the HW and XF PRAs and was performed to ensure the adequacy and acceptability of key information collected by the licensee during its walkdown and subsequently used in the development of the HW and XF PRA models. To facilitate the walkdown, the NRC staff identified dominant contributors (structures, systems, and components) to the HW and XF PRAs, dominant operator actions that were credited, and topographical features at the site that were considered in the XF PRA.
Audit Discussions As part of the audit discussions, the licensee provided an overview presentation of the Brunswick HW and XF PRAs and information to support the onsite walkdowns. The overview provided useful information to the NRC staff on various technical elements that are important in the development of Brunswick HW and XF PRAs.
The NRC staff and the licensee discussed each of the information needs provided to the licensee via the audit plan. The technical discussions were focused on the peer-review process, hazard development, plant response development, PRA acceptability and maintenance, and the categorization process.
During the audit discussions, the licensee identified an important change to the XF PRA related to the XF hazard model. The NRC staff became aware that the change had not been peer-reviewed. As the information relevant to the change had not been made available during the remote audit, the discussions with the licensees staff allowed the NRC staff to obtain a better understanding of the model. The NRC staff and the licensee also discussed the inclusion of an implementation item as part of the condition to the licensees implementation of the 10 CFR 50.69 program to address the lack of a peer-review of the change to the XF hazard model.
3.0 RESULTS OF THE AUDIT During the remote and onsite audits, the NRC staff did not make any regulatory decisions regarding the license amendment request. The audits identified information that the licensee was expected to provide to the NRC on the docket and the audits informed the final RAIs issued. After the regulatory audits, the NRC staff finalized and transmitted the RAIs on October 9, 2018 (Reference 11).
4.0 AUDIT PARTICIPANTS NRC
Participants:
Dennis Galvin, Project Manager, NRC Mehdi Reisi-Fard, Acting Team Lead, PRA, NRC Stephanie Devlin-Gill, Acting Chief, Hydrology and Meteorology Branch, NRC Andy Campbell, Deputy Director, NRC Shilp Vasavada, technical reviewer, PRA, NRC Jason White, Meteorologist, NRC Kevin Quinlan, technical reviewer, hazard analysis, NRC Nebiyu Tiruneh, technical reviewer, hazard analysis, NRC Duke Energy
Participants:
Jennifer Varnedoe Heather Szews Robert Rishel Jeff Sciaudone Robert Isbell Stephen Kimbrough Rom Sherrill Phillip Palmer Davood Karimi Ed Wiegert
5.0 REFERENCES
- 1. Gideon, W. R., Duke Energy Progress, LLC, letter to U.S. Nuclear Regulatory Commission, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated January 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18010A344).
- 2. Donahue, J., Duke Energy, letter to U. S. Nuclear Regulatory Commission, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated November 2, 2018 (ADAMS Accession No. ML18306A523).
- 3. Snider, S., Duke Energy, letter to U. S. Nuclear Regulatory Commission, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated February 13, 2019 (ADAMS Accession No. ML19044A366).
- 4. Snider, S., Duke Energy, letter to U. S. Nuclear Regulatory Commission, Response to NRC Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated April 8, 2019 (ADAMS Accession No. ML19099A035).
- 5. Galvin, D., U.S. Nuclear Regulatory Commission, e-mail to Zaremba, A., Duke Energy, RE: Brunswick - Adoption of 10 CFR 50.69 - HWPRA and XFPRA Audit Plan and Setup of Online Reference Portal (EPID: L 2018-LLA-0008), dated May 9, 2018 (ADAMS Accession No. ML18130A021).
- 6. Barillas, M., U.S. Nuclear Regulatory Commission, letter to Capps, S., Duke Energy Corporation, "Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Audit Plan RE: Application to Adopt 10 CFR 50.69,
'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated July 2, 2018 (ADAMS Accession No. ML18180A418).
- 7. Barillas, M., U.S. Nuclear Regulatory Commission, letter to Capps, S., Duke Energy Corporation, "Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Audit Plan Questions RE: Application to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors, dated July 11, 2018 (ADAMS Accession No. ML18191A997).
- 8. Galvin, D., U.S. Nuclear Regulatory Commission, e-mail to Zaremba, A., Duke Energy, Brunswick - Adoption of 10 CFR 50.69 - Supplement to the HWPRA and XFPRA Audit Plan for BSEP Onsite Audit (EPID: L 2018-LLA-0008), dated August 7, 2018 (ADAMS Accession No. ML18220A790).
- 9. Barillas, M., U.S. Nuclear Regulatory Commission, letter to Capps, S., Duke Energy Corporation, "Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Regulatory Audit Summary Regarding License Amendment Requests to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Plants (EPID L-2018-LLA-0008 and EPID L-2018-LLA-0034), dated November 14, 2018 (ADAMS Accession No. ML18282A224).
- 10. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Office Instruction LIC-111, Regulatory Audits, dated December 29, 2008 (ADAMS Accession No. ML082900195).
- 11. Galvin, D., U.S. Nuclear Regulatory Commission, e-mail to Zaremba, A., Duke Energy, Brunswick RAIs - LAR to Allow Implementation of the Provisions 10 CFR 50.69 (EPID L-2018-LLA-0008), dated October 9, 2018 (ADAMS Accession No. ML18282A149).
ML19149A210 *via email OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA* DORL/LPL2-2/BC DORL/LPL2-2/PM NAME DGalvin BClayton (JBurkhardt for) UShoop DGalvin DATE 06/21/19 06/20/19 07/01/19 07/01/19