ML22264A305
| ML22264A305 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/30/2022 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Coffey B Florida Power & Light Co |
| Wall S | |
| References | |
| EPID L-2022-LLA-0106 | |
| Download: ML22264A305 (8) | |
Text
September 30, 2022 Mr. Bob Coffey Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd Juno Beach, FL 33408
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST REGARDING RISK-INFORMED APPROACH FOR CLOSURE OF GENERIC SAFETY ISSUE-191 (EPID L-2022-LLA-0106)
Dear Mr. Coffey:
By letter dated July 29, 2022 (Agencywide Documents Access and Management System Accession No. ML22210A086), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted license amendment and exemption requests for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed amendments would revise the licensing basis described in the Point Beach Updated Final Safety Analysis Report (UFSAR) to include a risk-informed method of evaluating the effects of loss of cooling accident (LOCA) generated debris on long-term core cooling (LTCC). The requested exemption would allow the use of risk-informed methods to evaluate the LTCC effects of debris generation resulting from a postulated LOCA in order to address the safety issues described in Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors. The proposed license amendments and exemption requests are part of NextEras final resolution to Generic Safety Issue (GSI-191), Assessment of Debris Accumulation on Pressurized-Water Reactor Sump and Performance, and for responding to GL 2004-02.
The U.S. Nuclear Regulatory Commission (NRC) staff has found the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that requires docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit virtually via Teams using a licensee-established electronic portal available to NRC staff from approximately October 10, 2022, through February 24, 2023, with formal audit meetings to be scheduled during this period as needed. The detailed audit plan is enclosed with this letter.
B. Coffey If you have any questions, please contact me at (301) 415-2855 or by e-mail at Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST REGARDING RISK-INFORMED APPROACH FOR CLOSURE OF GENERIC SAFETY ISSUE-191 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301
1.0 BACKGROUND
By letter dated July 29, 2022 (Agencywide Documents Access and Management System Accession No. ML22210A086), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted license amendment and exemption requests for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed amendments would revise the licensing basis described in the Point Beach Updated Final Safety Analysis Report (UFSAR) to include a risk-informed method of evaluating the effects of loss of cooling accident (LOCA) generated debris on long-term core cooling (LTCC). The requested exemption would allow the use of risk-informed methods to evaluate the LTCC effects of debris generation resulting from a postulated LOCA in order to address the safety issues described in Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (ML042360586). The proposed license amendments and exemption requests are part of NextEras final resolution to addressing the concerns of Generic Safety Issue (GSI-191), Assessment of Debris Accumulation on Pressurized-Water Reactor Sump and Performance, and for responding to GL 2004-02.
The staff from the Nuclear Regulatory Commissions (NRC) Office of Nuclear Reactor Regulation (NRR) has initiated its review of the license amendment request (LAR) in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures, Revision 6, dated July 31, 2020 (ML19248C539).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will 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 (ML19226A274), with exceptions noted within this audit plan.
The NRC staff performs the audit to support its evaluation of whether the licensees LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit. The audit will assist the NRC staff with understanding the licensees approach described in the application, as supplemented, including use of NRC staff guidance applicable to the resolution of GL 2004-02.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY NRCs objectives of the audit are the following:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information, Revision 1, dated August 9, 2021 (ML21141A238).
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff requests information and audit meeting(s) throughout the audit period. The NRC staff uses an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The NRC staff provides the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff provides the licensee with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with NRC staff. Any information accessed through the licensees portal is not held or retained in any way by NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the audit items list to be readily available and accessible for the NRC staffs review via a Web-based portal.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR and contractors.
Scott Wall, Plant Licensing Branch III (LPL3)
Andrea Russell, Technical Specifications Branch (STSB)
Steve Smith, STSB Charles Moulton, PRA Licensing Branch B (APLB)
Daniel Ju, APLB Bryce Lehman, Structural, Civil, Geotech Engineering Branch (ESEB)
Phyllis Clark, Environmental Review Materials Branch (ELRB)
Eric Reichelt, Piping and Head Penetrations Branch (NPHP)
John Tsao, Vessels and Internals Branch (NVIB)
Matthew Yoder, Corrosion and Steam Generator Branch (NCSG)
Paul Klein, NCSG Benjamin Parks, Nuclear Methods and Fuel Analysis (SFNB)
Osvaldo Pensado, Southwest Research Institute (SWRI)
Stuart Stothoff, SWRI The NRC staff may request access for additional staff as the audit progresses.
6.0 LOGISTICS To support the review schedule communicated to the licensee when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a Web-based portal or other virtual meeting space created by the licensee. NRC information requests and communications with licensee staff is coordinated through the NRCs licensing project manager.
A desktop audit will take place between October 10, 2022, through February 24, 2023. The NRCs licensing project manager informs the licensee of the entrance and exit meeting dates when they are established. The NRC intends to set up audit meeting(s) (e.g., a single, multi-day audit meeting; periodic audit meetings throughout the audit period) on mutually agreeable dates and times (to be determined) to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times when deemed necessary. Audit meeting agenda and questions will be sent in advance of the audit meeting.
The NRC staff requests the licensee to have the information referenced in Section 4.0 of this audit plan available and accessible for the NRC staffs review via an internet-based portal within 2 weeks of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within 1 week of the date of the NRCs notification to the licensee of the new requests. The NRCs licensing project manager informs the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the NRC licensing project manager when an audit item is added to its portal by sending an e-mail to the NRC licensing project manager.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password protected. A separate password will be assigned to each member of the NRC staff and NRC contractors taking part in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, via NRR Office Instruction LIC-115 and issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.
Attachment Appendix Initial Audit Items List Item #
Audit Item 1
Files to verify the computer-aided design (CAD) model debris generation and NARWHAL software results. Specifically, the NRC staff requests:
(a) Excel files with debris generated and transported, itemized by weld location, break size, and orientation. This will allow examination for testing limits being exceeded.
(b) Excel files with the list of breaks that result in failure, the failure cause, the break size causing failure. Provide this information for the different pump configurations.
(c) The list of all weld locations, with coordinates and weld diameters (d) Examples of time-varying head loss to compute strainer failure due to physical limits (e.g., flashing, void fraction, structural load), including independent variables (e.g., temperatures, flow rates, debris generated and transported to strainers) to compute the head loss and the physical limits. Provide examples causing physical failure, if they occurred, or just confirm that the only kind of strainer failure computed is exceeding strainer test limits.
ML22264A305 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLB/BC NRR/DSS/STSB/BC NAME SWall SRohrer JWhitman VCusumano DATE 09/21/2022 09/22/2022 09/27/2022 09/28/2022 OFFICE NRR/DSS/SFNB/BC NRR/DEX/ESEB/BC(A) NRR/DNRL/NPHP/BC NRR/DNRL/NCSG/BC NAME SKrepel BLehman MMitchell SBloom DATE 09/27/2022 09/27/2022 09/27/2022 09/30/2022 OFFICE NRR/DNRL/NVIB/BC NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME ABuford NSalgado (JWiebe for)
SWall DATE 09/30/2022 09/30/2022 09/30/2022