ML22213A117
| ML22213A117 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/28/2022 |
| From: | Marshall M NRC/NRR/DORL/LPL1 |
| To: | Coffey B Florida Power & Light Co |
| Marshall M, NRR/DORL/LPL1 | |
| Shared Package | |
| ML22213A121 | List: |
| References | |
| EPID L-2022-LLT-0002 | |
| Download: ML22213A117 (35) | |
Text
OFFICIAL USE ONLY PROPRIETARY INFORMATION July 28, 2022 Mr. Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd.
Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNITS NOS. 3 AND 4 -
REGULATORY AUDIT PLAN IN SUPPORT OF REVIEW OF DEFENSE IN DEPTH AND DIVERSITY EVALUATION (EPID L-2022-LLT-0002)
Dear Mr. Coffey:
By letter dated May 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22123A231), Florida Power & Light Company (FPL, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) review the defense in depth and diversity (D3) evaluation for the Turkey Point Nuclear Generating, Units 3 and 4 (Turkey Point).
As stated in your letter, the D3 evaluation is part of a planned license amendment request that will be submitted to the NRC in the second quarter of 2022 to support the digital instrumentation and control (I&C) modernization project at Turkey Point.
During the initial review of the D3 evaluation, the NRC staff identified several items that require further clarification and detailed explanations and determined that a regulatory audit would assist in the completion of the review. The NRC staff will conduct a regulatory audit to support its review of the D3 evaluation in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information. The audit will be conducted to increase the NRC staffs understanding of the D3 evaluation and identify information that will require docketing to support the NRC staffs regulatory finding on the planned license amendment request.
NOTICE: The Attachment to the Enclosure to this letter contains PROPRIETARY INFORMATION. Upon separation from the Attachment, this letter is DECONTROLLED.
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION B. Coffey The audit will start on August 10, 2022. The audit will consist of a series of open or partially closed public meetings using video conferencing tools and online portal(s) (also known as electronic portal, ePortal, electronic reading room, or eDocs web portal). The end of the audit will be scheduled after the acceptance review of the planned Turkey Point digital instrumentation and controls license amendment request is completed.
If you have any questions, please contact me by telephone at 301-415-2871 or by email to Michael.Marshall@nrc.gov or Bhagwat BP Jain by telephone at 301-415-6303 or by email to Bhagwat.Jain@nrc.gov.
Sincerely,
/RA/
Michael L. Marshall, Jr.
Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Audit Plan cc: Listserv OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION AUDIT PLAN REGARDING DEFENSE IN DEPTH AND DIVERSITY EVALUATION FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNITS 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 BACKGROUND
By letter dated May 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22123A231), Florida Power & Light Company (FPL, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) review the defense in depth and diversity (D3) evaluation for the Turkey Point Nuclear Generating, Units 3 and 4 (Turkey Point).
As stated in your letter, the D3 evaluation is part of a planned license amendment request that will be submitted to the NRC in the second quarter of 2022 to support the digital instrumentation and control (I&C) modernization project at Turkey Point.
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ADAMS Accession No. ML19226A274).
Defense-in-depth and diversity are methods that can be used to protect against common cause failures. The audit will assist the NRC staff in evaluating whether the scope and level of detail in the D3 evaluation are sufficient to demonstrate that the new instrumentation and control architecture meets the design criteria described in Section 1.3.3 of the Turkey Point Updated Final Safety Analysis Report.
Enclosure OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION 3.0 PURPOSE AND SCOPE The purpose of the audit is to gain a more detailed understanding of licensees D3 evaluation for Turkey Point.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will use the open items summary list to identify the information to be audited. The open items summary list will be initially shared as an attachment to the audit plan. Consistent with the Special Request Section below, the licensee should place the open item list and the information to be audited on an online portal (i.e., electronic portal, ePortal, electronic reading room). The open items summary list will be updated prior to or during each of the public meetings described in the Logistic Section below. A set of expectations for the use of the open items summary list is attached to the audit plan.
5.0 AUDIT TEAM The members of the audit team are:
Richard Stattel, Senior Electronics Engineer and Audit Team Lead Summer Sun, Senior Nuclear Engineer David Rahn, Senior Electronics Engineer Justin Vazquez, Reactor Operations Engineer Steven Alferink, Reliability and Risk Analyst Eric Reichelt, Senior Materials Engineer Chang Li, Senior Safety and Plant Systems Engineer Sean Meighan, Reactor Scientist Bhagwat BP Jain, Senior Project Manager Michael Marshall, Senior Project Manager 6.0 LOGISTICS The audit will start on August 10, 2022. The audit will consist of a series of open or partially closed public meetings using video conferencing tools and an online portal (i.e., electronic portal, ePortal, electronic reading room). The end of the audit will be scheduled after the acceptance review of the planned Turkey Point digital instrumentation and control license amendment request is completed. The NRC project managers assigned to the audit team will coordinate any changes to the audit schedule and location with the licensee.
The first open or partially closed public meeting will be held on September 22, 2022. At the first public meeting and at subsequent meetings, the audit team and representatives from FPL will agree on the date and time for the next meeting. The NRC staff will use the periodic public meetings to discuss the information identified in the open items summary list.
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION 7.0 SPECIAL REQUEST The NRC staff would like access to the documents through an online portal (i.e., electronic portal, ePortal, electronic reading room) that allows the audit team access via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:
the online portal will be password-protected, and separate passwords will be assigned to each audit team member the online portal will be sufficiently secure to prevent the audit team from printing, saving, downloading, or collecting any information on the online portal conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each audit team member The licensee should ensure any information uploaded to the online portal is appropriately marked regarding sensitivity. NRC staff will confirm with the licensee the sensitivity of any information uploaded to the online portal.
Username and password information should be provided directly to the NRC staff on the audit team. The NRC project managers assigned to the audit team will provide FPL the names and contact information of the NRC staff who will be participating in the audit. All communications should be coordinated with one of the NRC project managers on the audit team. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. At the latest, NRC staff access to the online portal should be terminated no later than 30 days after the end of the audit.
8.0 DELIVERABLES An audit summary, which may be public, will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue requests for additional information to the licensee.
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY - PROPRIETARY INFORMATION Turkey Point D3 Analysis Evaluation Open Item List Table 2 - Requested Documents Audit List Source Requested Information to be Available on Portal for Audit Reference Available Portal Item Branch Open Item (Y/N) Location ZIF-007-21, Small Break LOCA Dose Evaluation as Part of Engineering Support of Turkey 1 ARCB Point D3 Validation, July 26, 2020. 11 N TBD 2 EICB Reference 5. System Architecture Drawing 02-9321047-D Rev 004 8 N TBD Reference 25. Framatome Doc. No. 56-9321451, Rev. 004, Turkey Point Unit 3&4 3 EICB RPS/ESFAS/NIS Project Quality Plan. --- N TBD 4 EICB Reference 33. Westinghouse WCAP-10858-NP, AMSAC Generic Design Package. 8 N TBD 5 EICB Reference 51. FPL Logic Diagram 5613/4-T-L1 Sheets 33 A, B, C. 8, 9 N TBD Reference 74. Framatome Doc. No. 102-9321586, Rev 003, Turkey Point Unit 3&4 6 EICB RPS/ESFAS/NIS Project Management Plan (PMP). --- N TBD Reference 75. Framatome Doc. No.158-9324081, Rev. 002, Turkey Point Unit 3&4 7 EICB --- N TBD RPS/ESFAS/NIS Software Development Plan (SDP).
Reference 76. Framatome Doc. No. 09-9321605, Rev. 000, Turkey Point Unit 3&4 Software 8 EICB --- N TBD Quality Assurance Plan (SQAP).
Reference 77. Framatome Doc. No. 136-9321606, Rev. 001, Turkey Point Unit 3&4 Software 9 EICB --- N TBD Verification and Validation Plan (SVVP).
Reference 78. Framatome Doc. No. 158-9321019, Rev. 000, Turkey Point Unit 3&4 10 EICB --- N TBD RPS/ESFAS/NIS Software Configuration Management Plan (SCMP).
11 EICB Reference 106. 5610-T-D-17 Sht 1, Rev. 5, Steam Generator Level Control and Protection 8, 9 N TBD The Turkey Point critical operator action procedure to identify the manual operator actions required to mitigate the small break LOCA event, including containment isolation and RHR 12 SCPB initiation. 13 N TBD 13 SNSB Ref. 56 (on page 172 of the D3 report) - Framatome Doc. Number 32-9332101-000, Rev. 0, 14 N TBD OFFICIAL USE ONLY - PROPRIETARY INFORMATION
OFFICIAL USE ONLY - PROPRIETARY INFORMATION Turkey Point D3 Analysis Evaluation Open Item List Table 2 - Requested Documents Audit List Source Requested Information to be Available on Portal for Audit Reference Available Portal Item Branch Open Item (Y/N) Location Zachry Development of Turkey Point3 RETRAN-3D Main Steam Line Break from Hot Full Power Model, 5/24/2021.
Ref. 58 - Framatome Doc. Number 32-9332105-000, Rev. 0, Zachry Development of Turkey Point3 RETRAN-3D Rod Withdrawal from Subcritical Model, May 21, 2021.
14 SNSB 14 N TBD Ref. 59 - Framatome Doc. Number 32-9332097-000, Rev. 0, Zachry Development of Turkey 15 SNSB Point3 RETRAN-3D Rod Withdrawal at Power Model, May 21, 2021. 14 N TBD Ref. 60 - Framatome Doc. Number 32-9332098-000, Rev. 0, Zachry Development of Turkey 16 SNSB Point3 RETRAN-3D Excess Feedwater Model, May 7, 2021. 14 N TBD Ref. 61 - Framatome Doc. Number 32-9332100-000, Rev. 0, Zachry Development of Turkey 17 SNSB Point3 RETRAN-3D Locked Rotor Model, May 24, 2021. 14 N TBD Ref. 63 - Framatome Doc. Number 32-9332102-000, Rev. 0, Zachry Steam Line Break at Hot 18 SNSB Zero Power for D3 at Turkey Point Units 3&4 Using RETRAN-3D, 5/19/21. 14 N TBD Ref. 64 - Framatome Doc. Number 32-9332103-000, Rev. 0, Zachry Development of Turkey 19 SNSB Point3 RETRAN-3D Rod Ejection Model, May 24, 2021. 14 N TBD Ref. 57 - Framatome Doc. Number 32-9332084-000, Rev. 1, Zachry Development of Turkey 20 SNSB Point 3 RETRAN-3D Base Model. 14 N TBD Ref. 66 - Framatome Doc. Number 32-9332104-000, Rev. 0, Zachry Development of Turkey 21 SNSB Point3 VIPRE-01MODEL, May 24, 2021. 14 N TBD OFFICIAL USE ONLY - PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION Turkey Point D3 Evaluation Open Item Summary List Expectations and Usage What it is:
A document containing a table of NRC questions and comments (i.e., open items) and a separate table listing documents for audit concerning the Turkey Point defense-in-depth and diversity (D3) evaluation for tracking by the NRC staff and licensee.
A document identifying information to be audited by the NRC staff.
It is an informal tool for promoting communication between the NRC staff and NextEra/FPL.
o The information in the document will not be relied upon by the NRC staff in making any regulatory decisions.
o It is not immediately known if the responses to the questions and comments will need to be docketed by the licensee.
o Some of the questions may eventually be dispositioned as request for additional information (RAIs), request for confirmatory items (RCIs), audit information needs, or responses provided by licensee as supplement(s) to the Turkey Point D3 evaluation.
Why it is used:
To increase shared understanding with respect to potential RAI, potential RCI, and audit information needs.
To promote open communications with licensee for complicated or complex reviews to help NRC bin questions into the RAI, RCI, and audit information needs.
Where it is located:
Initially, the open items summary list will be provided to the licensee as an attachment to the audit plan for the Turkey Point D3 evaluation review.
o Electronic communication of proprietary information from the NRC staff to NextEra/FPL will be done through the BOX service.
The licensee will upload the open items summary list to an online portal maintained by the licensee.
o The licensee will make all updates to the list on the online portal consistent with the Special Request Section of the audit plan.
o The licensee will inform the NRC staff of the location of the list (e.g., folder location on the online portal).
NRC Usage:
NRC staff will create the initial open item summary list. Each item will be assigned a unique number to identify the question or comment (e.g., open item #1 or audit item #1).
NRC staff will send additional questions and comments to the licensee to be added to the list through the NRC project manager. Only questions or comment provided by the NRC staff through the NRC project manager should be added to the open item summary list.
NRC staff will denote the questions or comments in the list as potential RAI, potential RCI, audit information need, or no follow-up during discussions with NextEra/FPL. This designation can occur before or after the licensee responds to a question or comment.
NRC staff will send any questions and comments denoted for RAIs or RCIs formally via the RAI/RCI process so that the licensee can respond formally on the docket and under oath &
affirmation.
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION NRC staff will mark information that the licensee or its vendor has identified as proprietary using (( bolded double brackets )).
NRC staff will make a copy of the open item summary list (with appropriate redactions) publicly available that will be discussed during public meetings between the NRC and NextEra/FPL.
NRC staff, during or prior to meeting with the licensee, will provide the licensee with an update of the status of open items (e.g., OPEN to CLOSED, OPEN to CONFIRM).
Licensee Usage:
Licensee will upload open items summary list containing a table of NRC questions and comments (i.e., open items) and a separate table listing documents to an online portal.
Licensee will update and maintain the document for the duration of the audit. Only questions or comment provided by the NRC staff through the NRC project manager should be added to the open item summary list.
Licensee will update the open item summary list with responses to NRC staff questions and comments.
Licensee will provide the NRC staff proprietary and nonproprietary copies of the updated open item summary list at least one week prior to any meetings to discuss the questions or comments in the list.
Licensee will ensure proprietary and other restricted information are clearly marked (e.g.,
use of (( bolded double brackets ))) for information it adds to the document.
Licensee will update Status and Audit, RAI, or RCI Number columns of the open items summary list based on feedback form NRC staff during meetings to discuss the questions or comments in the list.
OFFICIAL USE ONLY PROPRIETARY INFORMATION